CPSIA Tracking Label Examples, would you, could you share examples?

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Original Post

Hi,
I am new to all this and wading through the info because I am thinking of including in my shop some new items I make for children.

Would any of you sellers who have labels, be able to share photos of them? I am curious as to what some of you have done to comply with the CPSIA label regulations.

Thanks!

Posted at 9:25am Oct 23, 2009 EDT

Responses

wow--very professional! Thanks for sharing.

One question: do the labels themselves need to fit under some "made of such and such material" guidelines? Like the ink, for example, does it need to meet some sort of criteria? Do we need a label on our labels? ;p (just kidding on the last one).

Posted at 10:24am Oct 23, 2009 EDT

CPSIA compliant labels can be made of woven or non-woven fabric, which are exempt materials. Check the specs on the ink to make sure it's non-toxic and lead-free. This information (the Material Data Safety Sheet or MDSS) is usually available on the manufacturer's website.

The labels also need to be permanent - meaning that they will last the life of the article to which they are attached and that they can not be removed by the customer without being damaged.

Check out the FTC website for more information on labeling clothing and textiles:
www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm

Posted at 10:58am Oct 23, 2009 EDT

Just remember there has been no official response from either the CPSIA or the FTC if you can combine the 2 separate agencies required labels and still be compliant to the two separate laws.
The FTC is in charge of what items require a care and content labels. FTC Labeling requirements can be read about here
www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm#covered
The CPSC is in charge of overseeing the tracking labels for recall purposes on all childrens items. More info on tracking labels at these 2 links
www.cpsc.gov/about/cpsia/sect103policy.pdf
CPSIA's FAQ page
www.cpsc.gov/about/cpsia/sect103.html#103q8

Remember since the labels are part of the finished product the raw materials they are made from are subject to the same testing requirements for lead and for certain product categories for phthalates as well. If the labels are ink set or fray checked with a process other than by heating then you have to test the entire finished product the label is on even if everything else on the product is made with exempt materials. For now a GCC or COC from the label manufacturer is enough to show a "good faith effort" in compliancy for the testing. Come Feb 10th 2010 the entire product, unless made of entirely exempt materials including the labels, must go for 3rd party lab testing. Right now the only approved type of ink on the exemption list is CMYK inks for ink jets printers which is for most part water soluable and does require some sort of ink bleed setting. The CPSIA has said they will not exempt screen print and iron on transfers.

Posted at 11:10am Oct 23, 2009 EDT

BarkingDogDesigns says:
CPSIA compliant labels can be made of woven or non-woven fabric, which are exempt materials. Check the specs on the ink to make sure it's non-toxic and lead-free. This information (the Material Data Safety Sheet or MDSS) is usually available on the manufacturer's website.
_________________________________________________________

Here's the CPSIA's reasoning as to why the MSDS sheet do not comply with their COC and GCC requirements. Sorry to say that it looks like they will not accept MSDS sheets as proof of compliance even during the stay.

"15. Issues Related to Component Part Testing.
Some commenters indicated that the materials they use should not require testing because the material safety data sheets (MSDS) already show that the materials do not contain lead.
As the Commission stated in the procedures rule, material safety data sheets are insufficient for purposes of demonstrating compliance with the lead limits under the CPSIA (74 FR at 10478). Since regulations concerning MSDS require reporting only for chemicals with content levels that exceed 1000 ppm, the MSDS sheets cannot be used to show that a product complies with the lead limits of the CPSIA, which are 600 ppm for products sold after Febr~ary 10, 2009, 300 ppm for products sold after August 14, 2009, and 100 ppm for products sold after August 14, 2011 (if deemed to be technologically feasible) ." page 53 & 54 of the www.cpsc.gov/businfo/frnotices/fr09/leaddeterminationsfinalrule-dra...

Posted at 11:16am Oct 23, 2009 EDT

thank you--this is all very great info.

fairiesnest--your tags are great and so the source on your blog is very helpful!

Posted at 12:54pm Oct 23, 2009 EDT

Sewplicity says

Barkingdogdesigns, a bit off topic, but did you file for your trademark yourself or have a professional do it? I find the application process a bit overwhelming!

Posted at 4:23pm Oct 23, 2009 EDT

KiwiSoup says

marking

Posted at 2:28pm Jan 22, 2010 EST