Keeping Up With CPSIA FTC & CPSIA Labels - Specific Info on Labels

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Original Post

I have been researching these 2 labels like crazy the past 2 days . I am not sure if I have it 100 % correct . I thought I did but then realized some of my information is repetative . Perhaps I made a mistake? Can someone tell me if this is right, or if I have to much info or not enough on the labels. Thanks!

FTC Label:

Front of tag:
RN# or business name
100 % Cotton ( fiber contents)
made in USA of imported fabric

back of tag:
cleaning/care instructions
batch #
date made
SF, Ca (specific location made)

CPSIA Label:

date made
place made ( USA)
batch#
cohort info ( ??) is this my business name or web site address?)

Just curious if the batch & date had to be on both . I am going to print some at home & try to order the other. However if both require all this info like the date & batch then it seems I will have to make both myself to fill this in properly as I go.
Thanks for reading!

Posted at 8:31pm Nov 2, 2011 EDT

Responses

*too - not enough o's in that too . haha

Posted at 8:40pm Nov 2, 2011 EDT

Okay, FTC labels can be ordered ready made, or you can have them custom made.

The ones I use are woven

100% imported cotton
Machine Wash
in cold water
tumble dry low
romove promptly
no bleach

Then I use a woven size labe

Then I print my own CPSIA label

FayeMaloneDesigns.com
Kinsman, OH, USA
Handmade in the USA
of imporrted fabric
11JFMAMJJASOND12

I make my CPSIA labels on printable cotton with my ink jet printer. I follow the directions of "curing" the fabric, then I cut them out with pinking shears.

The date coding you use can be whatever you want it to be. I came up with this coding as I can use the same one for 2 years, and I simply take a couple of stitches with colored thread under the coresponding year and month before I sew it in. I've shared this tag with the group and I think a lot of people are using it, or have adapted it with seasons instead of months. It's simple and straight forward

Not knowing what you make, you probably don't need a batch number, nor cohort information. Are you making your product one at a time, or just a few a month using the same supplies? Or are you making hundreds or thousands of exactly the same item?

I also use a clear top loading sheet protector to put a copy of etsy listing, with attached information about costs, where and when purchased, snippets of fabric, trim, and buttons. Any testing information I have is also included. And when the items sells i put a copy of the invoice inside. The whole mess goes inside a binder.

Posted at 10:29am Nov 3, 2011 EDT

Well thank you so much! I will be making lots of different things but an example is girls skirts . If I want to keep producing the design I will probably make at least 12 from the same bolt of fabric, then start with a new bolt & do the same . So probably a few a month. I was thinking something like that would require a batch # .
I'm still not entirely clear on what "cohort" info means . I will look into that a bit more . I really like the idea of the date reflecting the season & year ! I can see me now really not liking to stitch each label with a mark ! Great idea though & I appreciate you sharing it. I finally stopped using double sided business cards & stamping the back with my info, & that was progress for me from silk screening them with a gocco myself. They are now printed by someone else . Any little detail I can pay someone else to do along the way is a big help , because as we know running your own small business, there are so many little details to take care of !! So I have read up on the printable fabric sheets . Seems they fray a bit . So is the curing method you spoke of on the instructions of the fabric paper? Is this to help fraying or just set the ink? Thank you!!

Posted at 11:04am Nov 3, 2011 EDT

So for exempt materials like woven fabric labels , and labels you make yourself , made of exempt ingredients like cotton & CMYK ink process printing do you make a statement on paper about the ingredients in the garments tag & file that with the other info as well , or would this info just go on the COC for that specific item ?
My next post is going to be asking about the Certificate of Conformity. I found the template on the CPSIA web site but do not understand each point I am supposed to write about .

Posted at 11:32am Nov 3, 2011 EDT

Keep in mind all woven labels (commericial or crafted) are not exempt. You will need a statement from the printer of the labels that states they used only exempt materials like non plasticized (laminated) fabric and CYMK inks with no additions like screen print, fray check, or ink setting chemicals. Once those products are used the label is no longer exempt and will require testing for lead and possibly phthalates testing. If the label maker did use those chemicals and can provided the testing information then you will not need to have the labels tested personally by batch.

The only piece of information that is the same on the FTC care and content labels and the CPSIA tracking label is the name of the company. Though the FTC label can have a brand name instead of a company name if the RN # is also included. Also the CPSIA has stated if the is another permanant place on the product that contains the company name then it need not be on the tracking label. All other required information from the 2 seperate agencies is different the FTC wants any consumer to know what the fibers are use to make the item with and how to care for the item while the CPSIA wants the items to be trackable through many hands if the item is ever passed down or sold secondhand in case of recalls. Both agenies want their certain required information on the front of the labels and the FTC has font size requirerments based on the overall size of the label that usually takes up around 70% of the available label space. Neither agency has issued a statement saying that you can or can not combined the two labels .

Personally I think "cohort" information is something that helps distinguish more exactly production origin and applies to the mega corporations for things like assembly line designation or building # for "multi-plant " campus operations at a single address. I do think you may need seprerate batch numbers if you will not be able to tell exactly which production sheet goes with each item sold. But if 12 skirts are made with one bolt and the same lot # of accesssories or fasteners during the same production time frame they can all have the same batch # and 1 product sheet.

A GCC or COC is only needed if you are going to be offerring the product for sale through someone other than yourself where you are not collecting the money from the final consumer or where you will be exporting the item out of the USA. So another business purchasing the pieces from you for resale will need a GCC that covers each piece or batch they purchase. This is because the other business owner needs a permanant record of the product, even after all the pieces are sold, that they made their original wholesale purchase or consignment agreement in good faith that the product meet all applicable laws and regulations in place at that time. So most crafters are keeping their product records in a similar format including extra things like supply samples, packaging proving exemption, &/ or listing information as part of their permanant files, in case they ever have the opportunity to expand into wholesale or exporting. An offical formated GCC is not needed if you will remain the direct seller of your products even if there is a government investigation as long as you keep a permanant record for each product or batch.

What needs to on a self issued GCC for your products:
The required information must be provided in English.
+ A description of the product or batch covered by this certification in enough detail to distinguish it fron your other products.
+ List separately each law, standard or regulation by subsection that is apply to the product or batch.
+ Provide your name, full mailing address, and telephone as the manufacturer certifying the product or batch.
+ Provide the name, full mailing address, e-mail address and telephone number of the person maintaining test records in support of the certification. This may be you or it maybe the supplies' manufacturers, it depends on whom obtained the original testing information from the lab and retains the original reports.
+ Provide the date(s) when the product was finished by at least month and year. (Should match the tracking label.)
+ The place of manufacture provide at least the city and country or the place where the product was finally manufactured or assembled. (Should match the tracking label.)
+ Give the date of the tests or test report(s) on which certification is being based on and the address and telephone of the lab where the testing was preformed. Preferably with the name of a direct contact at the lab.
+ What procedure or a testing code for the methodology used to test either the components or the finished piece as required by the CPSC. Also the numerical value assigned to the test results for "hazadous substances" in PPM, or pass/fail results for things like small parts or use and abuse.
Interpeted from
From www.cpsc.gov/about/cpsia/faq/elecertfaq.pdf
At the very least this check list should be used to determine if a supplier obtained testing reports contain enough information to count currently as a reasonable testing program.

FTC label needs at the very least:
- Your company's registered business name, or a brand/label name with RN#
- Fiber content by %
- Fiber's country of origin
- Washing and care instructions
Other info may be required depending on the exact fabrics use like registered trademark info for fabrics that are followed by a ® or the international symbols for care instructions.
Interpeted from
business.ftc.gov/selected-industries/clothing-and-textiles
www.ftc.gov/bcp/edu/pubs/business/textile/bus50.shtm#Complying
www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm#covered
www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm

For a crafter the CPSIA tracking label must include at minimum :
* Your company's or shop name, or searchable RN# (not required to repeat if able to find it elsewhere permanantly on the product like on a FTC care and content label).
* The city, state/territory, & country where the item was completed.
* Contact information, website, or business registered address. - If different from where made an address or unsearchable by the city & state info so a consumer can contact the manufacturer / designer.
* At least the season with year of manufacture or date of completion of the product, but the governmnet would prefer you to be more specific.
* If you make repeats of the designs then you may also need a batch number, but only if the pieces are mostly identical looking and made of the same looking raw materials as each other.
Tracking labels
Interpeted from
www.cpsc.gov/about/cpsia/sect103policy.pdf
www.cpsc.gov/about/cpsia/sect103.html#103q8

Posted at 3:13pm Nov 3, 2011 EDT

I order woven FTC and Care labels from NorthWest Tag They are white woven ribbon with black thread wording. When the whole CPSIA mess is finalized for small business, I will probably order custom CPSIA labels from them. So no need for testing by you, or having testing results from them as they are soft ribbon, just like you see on better garments.

Posted at 4:49pm Nov 3, 2011 EDT

Thank you both so much! I have been working all day & just read this post . I was hoping Mary would show up on this thread! I have been reading posts from over the past 2 years, the past week while researching . So much helpful info!! So grateful someone has a business like brain where as I do not. As my friend told me tonight . I was slightly hurt but suppose it is true.
I have been emailing & asking label companies about the CMYK but never thought to ask about the other stuff, so thank you!

Next research project was getting info on how to write a COC. but I guess it is a GCC. I am unsure what that one stands for.
I do want to sell wholesale to retailers eventually . So I did write down all the things listed here about this when on the CPSIA site the other day. Several points I am unclear on though.

1)+ List separately each law, standard or regulation by subsection that is apply to the product or batch.
O.K would this be sec.101 & 103 ? I watched a webinar on the CPSIA website & it said something about 3 points i need to be concerned with was 101, 103 & labeling. Or am I completely out of it?
O.k I am so overtired. I must end here for now. I wanted to respond tonight to let the posters know how much I appreciated their response, but I better get back to this on my next day off when I can look at my notes & be more clear on the points I need help with writing a GCC.
I also am going to look up your company you order from Beverly! Thank you all ! Goodnight .

Posted at 12:54am Nov 5, 2011 EDT

Jennifer from DaydreamingGifts says
Edited on Jan 8, 2012

Does anyone have a website where they order their labels that have already been tested and approved?

Or can I do both labels on my own with an inkjet printer and fabric labels?

Posted at 11:20am Jan 8, 2012 EST

Can you combine them both into one tag or does it have to be two tags?

Posted at 12:02pm Jan 8, 2012 EST

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