CPSIA labels AND FTC labels?????

[#1]

I am SO confused!!

For my CPSIA labels I have:
my business name and contact info.
Care instructions
What the shirts are made of (cotton and polyester)
DOM
Batch # info

What do I need on my FTC labels? I read the FTC website info and I'm still confused. Where do I put the FTC label and what is supposed to go on it????????

[Former_Member]

Thanks! i will check it out. I hope that the crafters that do the shows also know about all of this I will for sure pass it on to the ones i know from other shows I have done or been to where I know the people.

[Former_Member]

lindaandcompany, maybe I missed something but I don't see any exemptions from the FTC's care & content labeling requirements based solely on the fact something is handmade. The only 2 instances where a otherwise non-exempt product is excluded from the FTC labeling is in the case of custom ordered clothing where the customer provides the fabric to the seamstress or tailor and for rugs that are certified to be made by Navajo Indians by the Indian Arts and Crafts Board.

Some of the people that you see at craft shows maybe hobbist that just don't know that they need these or the CPSIA labels. Just like there are people at these same shows that sell bath and body products that may not realize that there are certain labeling procedures under the FDA that they need for certain products or that they can not even make a claim that a product acts as a moisturizer without certain proofs or testing. The same hold true for persons making ready to eat food items at these same fairs, but many show organizers know enough to ask for all pertinent licenses before accepting those applications. Though policing every local summer festival or school fundraiser is not on any government agency's priority list all it takes is one valid cunsumer complaint to the right office to start an investigation of the person that made the products and if the person is found at fault the government can decide to levy fines & penalties against them the same as they would against a multi-national corporation.

"Exemptions
The following items don't need permanent care labels, but must have conspicuous temporary labels at the point of sale:

Totally reversible clothing without pockets.
Products that may be washed, bleached, dried, ironed, and drycleaned by the harshest procedures available, as long as the instruction, "Wash or dryclean, any normal method," appears on a temporary label.
Products that have been granted exemptions on grounds that care labels will harm their appearance or usefulness. You must apply for this exemption in writing to the Secretary of the FTC. Your request must include a labeled sample of the product and a full statement explaining why the request should be granted.
The following items don't need care instructions:

Products sold to institutional buyers for commercial use. For example, uniforms sold to employers for employee use in job-related activities, but not purchased by the employees.
Garments custom-made of material provided by the consumer.
Products granted exemptions under Section (c)(2) of the original rule because they were completely washable and sold at retail for $3 or less. If the product no longer meets this standard, the exemption is automatically revoked." from http://www.ftc.gov/bcp/edu/pubs/business/textile/bus50.shtm#Complying with the Rule

"The following items are not covered by the labeling requirements:7

Upholstery or mattress stuffing (unless it’s reused — then the label must say that it contains reused stuffing)
Outer coverings of upholstered furniture, mattresses, and box springs
Linings, interlinings, filling, or padding used for structural purposes
However, if they are used for warmth, the fiber must be disclosed, (see p.11). In addition, if you make any statement about the fiber content of linings, interlinings, filling, or padding, they are no longer exempt.

Stiffenings, trimmings, facings, or interfacings (see p.8 for more explanation of “trimmings”)
Backings of carpets or rugs and paddings or cushions to be used under carpets, rugs, or other floor coverings8
Sewing and handicraft threads
Bandages, surgical dressings, and other products subject to the Federal Food, Drug and Cosmetic Act9
Waste materials not used in a textile product
Shoes, overshoes, boots, slippers and all outer footwear. But, socks and hoisery are covered; in addition, slippers made of wool are covered under The Wool Rules (see p.6)
Headwear (hats, caps or anything worn exclusively on the head). But, a wool hat is covered under The Wool Rules (see p.6)
Textiles used in: handbags or luggage10, brushes, lampshades, toys, feminine hygiene products, adhesive tapes and adhesive sheets, cleaning cloths impregnated with chemicals, or diapers.


The following items also are excluded, unless you choose to make a statement about the fiber content. If you make any representation about fiber, all of the requirements for fiber content disclosure, described on pages 7-19, apply.11

Belts
Suspenders
Arm bands
Neckties that are permanently knotted
Garters
Diaper liners
Labels (individually and in rolls)
Looper clips intended for handicraft purposes
Book cloth
Artists’ canvases
Tapestry cloth
Shoe laces
All textile products manufactured by operators of company stores and sold exclusively to their own employees
Coated fabrics and those parts of textile products made of coated fabrics
A coated fabric is any fabric which is coated, filled, impregnated, or laminated with a continuous-film-forming polymeric composition, and the weight added to the base fabric is at least 35 percent of the weight of the fabric before coating.12
Secondhand household textile items that are obviously used or marked as secondhand
Non-woven disposable products intended for one-time use only
Curtains, casements, draperies, and table place mats that are made primarily of slats, rods, or strips that are composed of wood, metal, plastic, or leather
Textile products purchased by U.S. military services according to specifications
However, textile products sold and distributed through post exchanges, sales commissaries, or ship stores are covered. In addition, if the military sells textile products for nongovernmental purposes, the fiber information must be furnished to the buyer for labeling the products before distribution.

Hand-woven rugs made by Navajo Indians with the attached “Certificate of Genuineness” supplied by the Indian Arts and Crafts Board of the U.S. Department of Interior" from http://www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm#covered

[Former_Member]

We just ordered some nice fabric labels from a seller here, it was only about $35 for 600 labels. Its a real pain in the buns but its not THAT bad I don't think.......anyone figured out a way to make it super manageable? Also if you purchase a onesie, for example, wholesale....shouldn't it already have the fiber content label there? Mine sure do!

[Former_Member]

Remember if you use another person or company to make your labels regardless if they are for FTC care & content or the CPSIA tracking label that you get a GCC, COC, or test results for the lead content reported in PPM and if your final products fall into the phthalate testing criteria you will need those test results as well. If the label maker states that they are using 100% exempt materials have them put that in a physical note on their letterhead along with a list of what products and processes they used that you have it on file if there is ever a question that you did not do your "due diligence" in making sure every component of your final product is in compliance.
Also the way the FTC wants their labels done is that the font used for all of their information must fill 70% of the label size, so you may not be able to fit the CPSIA tracking info along with the FTC care and content info into 1 label. SO do carefull research on what you legally need for either label and on the label maker before ordering anything. There is another thread here in the CPSIA section where someone went ahead ordered labels only to find out after they recieved them that the fray check used to seal the label's edges has no test results and the manufacturer of the fray check is claiming that they do not need to test since fray check is not a child's product. Now the purchaser, just because of the one untest non-exempt component on her label, needs to find a way to test the labels before it can be added to her otherwise exempt products.

[Former_Member]

Yes, but if you add any sort of embellishment such as an applique, you have to list the fiber content for what you are adding....

[Former_Member]

Thanks I am looking all this over again you are a big help jewelrydesignsbyME

[Former_Member]

Marking

[ballyhoocreates]

Just in case this helps anybody out there confused about FTC label rules:

I wrote a blog tutorial a long time ago for the FTC rules regarding clothing labels (company, care & content). It's my interpretation - but the summary may be easier than the full FTC pages. I also wrote up how to print your own fabric labels. Hopefully that helps some people around here, especially the one of a kind items since you can print one label at a time if needed.

http://duhbe.com/blog/?p=627

[EllaJoeCouture]

DuhBe - Your blog was incredibly helpful! Everyone else... don't sweat it check out the blog at:

http://duhbe.com/blog/?p=627

Making labels actually sounds like fun now :) Thank you again!

[Former_Member]

All I can say is, OMG!!! I'm nauseous. Thank you jewelrydesignsbyME and DuhBe. I'm deflated. I have to take off all of the hand-crocheted items I was tirelessly working on and hoping to sell to help offset my husband's very sad paychecks for the past year. I'm going to cry.

[Former_Member]

At the last craft fair that I went to (which was a big one) I checked for labels on all sorts of children's items and toys and hardly anybody was using them.

[Former_Member]

For some guidance I look at labels on kids' items in mainstream stores. If you look at the tag on, say, a child's T-shirt from Target, you'll see the required information either all on one tag or on two tags sewn together, so that when you lift the first tag you can find the other one with the fiber content and care instructions and so on, or the other tag might be sewn down the side of the shirt in a side seam.

But you can see how the information is listed and formatted and use that as a guide for your own.

This is why I've cut way back on my kids' items and am selling off what I've already made rather than making more. I want to avoid the chicken-with-my-head-cut-off thing I was headed for trying to comply! LOL

[CreativeDragonfly]

Marking.

[Former_Member]

Thanks DuhBe for a great tutorial.

[Former_Member]

saving

[alwaysdaddysgirl]

I am assuming that us Canucks have to follow the same guidelines?

[alwaysdaddysgirl]

I am so confused! Do importers need to put these labels on their products? Are both label only required for toys?

[Former_Member]

I thinl I will make my own lables it looks easy enough to do. i hope others will be able to make theirs too. Great onfo GenerationsTieDye I love your site and it is really good to navigate

[Former_Member]

What can happen if an internation seller ships something without the proper documentations and tags to the USA is that if customs inspects the item they can halt the delivery with no notification to the sender or the recipient. But here's the catch it the customer's responsibilty that they make sure you do the testing, paperwork, and tagging to be legal under this US law. Unfornutnately the testing can cost a pretty penny and ETSY does not allow you to make a seperate charge for additional services required to make something legal to ship somewhere, unless you build it into the shipping charge. Then you will have many customers questioning why there is such a large increase to ship to the USA, testing at the cheapest starts at $75 USD per component needing testing for lead testing plus the cost of the destroyed sample sent in for the test report. You could use supply component manufacturer's test results to cut down on testing cost but many are claiming their products as is are not for the use of a child so they are not testing. Once you have the test result, one way or the other, there still is the tagging and paperwork. The FTC label is require on most items made from fabric regardless of the age of the user, the CPSIA tracking label is required for all products made or marketed towards a child under 13. Additional a GCC must accompany a child's product being shipped to the USA, the GCC is filled out based on the test results or the use of exempt items used on the final product. Basically if you miss something the customshouse can declare the item a "hazardous substance" under the CPSIA and destroy the product being sent.

[Former_Member]

Interesting makes one almost want to not ship anything anymore.I never would of thought that they would destroy the product if it is not labeled right I have been looking at a lot of stores and their clothes etc is not really labeled any different. How would they differ from a person selling items they make to make a living? another thing I have been wondering about is how these laws are going to be imposed especially in little shops?
I have been tagging all my blankets in my store I have made. My customers said they did not even know about this law.

[Former_Member]

lindaandcompany, many of the items that you see in a B&M retailer are made a year or more in advance. If you are ever able to goto a toy or children's clothes expo you will see that in addition to staples ready for immediate delivery that many of the fashionable items that are being shown will not ship for at least 6 months and the items from overseas have a additional wait upto 8 weeks for customs inspection before being sent to the distributor or shipping company.
The tracking label portion went into effect on 8-14-09 for items made on & after that date so there is a chance that there are many children's things out there yet that will not have the mandated tracking label yet. Basically if you can prove the item was made before the cut off for the labeling date then you don't have to label but most crafters don't keep as detailed of a production log as the big companies do. The laws are primarily on the products themselves though there are penalities if a retailer is caught selling items that they know are not compliant, that's why for many ETSIANS it's a double whammy the government could fine us for both as the manufacturer of the item and as the retailer.
A big problem with this law is that many do not know it even exsists or to the extent that it covers in reality. I can almost clearly remember the outcry this time last year from people at thrift and second hand shops when they resalized that the law impacted more than just lead in toys. They where literally throwing in the trash items that where perfectly legal to sell on Feb 9th 2009 but where considered a "hazardous substance" on Feb 10th 2009 because there was no way for these shops to contact the items' original manufacturers to see if this jean's zipper & rivets or that shirt's buttons had ever been tested. Then you have posts here on these forums from people that went to national big box retailers that where they where told when they brought an item to the checkout that the store could not sell the item because the cash register was telling the cashier that the item was recalled, yet no proper recall notices where ever posted at those stores or on recall websites so that people who previous bought the same item could return it for a refund or be alerted to whatever the risk the product posed.

[Former_Member]

marking

[Former_Member]

marking!

[Former_Member]

marking!

[Former_Member]

headache....