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

[pancakeandlulu]

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!

[BarkingDogDesigns]

Here's mine:
http://www.flickr.com/photos/barkingdogdesigns/3769071582/

Rescanned with a coin alongside for scale:
http://www.flickr.com/photos/barkingdogdesigns/3773268803/

[pancakeandlulu]

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).

[BarkingDogDesigns]

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:
http://www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm

[Former_Member]

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
http://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
http://www.cpsc.gov/about/cpsia/sect103policy.pdf
CPSIA's FAQ page
http://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.

[Former_Member]

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 http://www.cpsc.gov/businfo/frnotices/fr09/leaddeterminationsfinalrule-draft.pdf

[TheFairiesNest]

here's mine;
http://thefairiesnest.blogspot.com/2009/10/cats-and-tags.html

[pancakeandlulu]

thank you--this is all very great info.

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

[Former_Member]

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!

[Former_Member]

marking

[Former_Member]

marking

[Former_Member]

marking

[Former_Member]

marking

[Former_Member]

Wow the examples are great! I just ordered some to be on the safe side with my nursing covers. I get so nervous about anything dealing with the law so this has my stomach in knots sometimes! I understand the need for the law but sometimes I wish it would just go away!

[Former_Member]

marking...thanks!

[FayeMaloneDesigns]

There shouldn't really be a reason to be upset, nervous, stomach in knots about these tags. All they are asking for is who are you, where are you from, where was this made, where are the materials from, and when did you make it. Not FBI questions.

Try to think of these tags as advertising for the future.
Put your store name where you can be reached if someone would like to buy something more from you:

FayeMaloneDesigns.com Or Fayemalonedesigns/etsy.com

Where are you located:

Kinsman. Ohio. USA

Where was this made and where are the materials from:

Made in the USA of Imported Materials

(lets face it, the USA doesn't make anything, almost
all of our supplies come from Mao's Communist China)

DOM
I use a code. 09ASONDJFMAMJJ10

(Really complex. 09 last year Aug, Sept, and so on until 10 this year. Covers 12 months. I make a pin dot mark using a fabric pen used on quilts sold at every fabric store and online to make a small dot underneath the year and month of my date. Take me to jail for not having testing results from a CPSIA approved for 2 miniscule dots of washable ink on a label, it will be laughed out of court. Lets be real this is not going to happen, When we have Toyota killing people with gas pedals that are getting stuck causing accidents, do you really think that any AG in the country is going to give a flying leap that I have used a fabric pen that I didn't send off to be tested to make 2 tiny dots?)

Maybe our government has no common sense when they write these laws, but use your own common sense. Follow the law using materials that you know are exempt, skip those items that you know are not approved (bling crystals, cheap metal cast jewelry stuff etc,) get manufacturers testing results for other things, attach your labels ,NO BIG THING, put on the FTC labels and get on with your creating. Don't be so concerned with someone elses labels look like, FTC labels are easily found even here on ETSY or other places on line. Search clothing care labels, CPSIA labels, size labels.

Please feel free to convo me if you need help on specific labeling for your items or other questions that you may have. I can direct you to easy places that stock standard labels that you can use, especially for your FTC labels. Look at the clothing that you have purchased. You will probably find 2-4 labels on each garment, don't stress on this, think of it as what any other business does.

[BikiniSandi]

I go through the knots in the gut just making the labels under the FTC rules. Its not that difficult. Its just different. I never had to worry about it before. And there is the fear of making a mistake. Just reading the book made me drool and pull my hair out for days on end. And it was easy to read and understand if I wasn't stressed out with all the hurdles I've had to jump as it is.

I always thought only big-time manufacturers had to worry with this stuff. I gave a piece of paper to my customers with use and care instructions and that made them happy. I could glance at the item and tell you what yarn I used or what fabric and where it was bought. I stopped running long lengths of ribbon through baby blankets years ago when I heard a newborn could strangle to death on one in a few seconds.

So, I'm a little bit uptight about the government expecting me to spend hundreds of dollars I don't have to get baby items tested and make labels I didn't used to know how to do.

I'll get over it.

[Former_Member]

Faye - It's not the details of the tags that are difficult or causing me anxiety. Anything I'm forced to do makes me nervous. It's money out pocket and according to everything I've read it will be strictly enforced. I was hoping that my nursing covers wouldn't need them but since they lay on the baby I'm guessing they do, so I went ahead and ordered them.

I ordered mine from an etsy supplier but have seen some other online places with large quantities for a really decent price. I just like the seller. :)


Yourandi-- exactly!

[Former_Member]

lovestruckbaby, your nursing covers are beautiful! I noticed that you use boning. I've used that in dresses and it comes in plastic or metal. Do you know if it needs testing?

[Former_Member]

I'm guessing that if it is plastic it will need to be tested for phthalates and if it is metal it will need to be teted for lead unless you can get the results directly from the manufacturer....check and see if if is on the exempt list on the CPSIA website...

[FayeMaloneDesigns]

quite often the boning is not plastic, but acrylic. Not all things are "plastic". Many buttons are now made of acrylic and do not need to be tested.

[Former_Member]

I never realized that acrylic buttons wouldn't need to be tested, I should have since acrylic yarn is exempt. Do we still need a certificate of compliance from the button manufacturer about the acrylic buttons? Thanks, FayeMaloneDesigns, for all the information!

[MagnoliaSurprise]

marking, and thanks for the info!

[Former_Member]

The boning I use is 100% polyester so I assumed it would not need to be tested. A few helpful people here have informed me that if it is enclosed and a child cannot put there mouth on it it would also be exempt. :)

[Former_Member]

Marking....Good info.