You may want to contact the FTC directly to double check about their labeling regulations concerning cloth diapers. They have excluded diaper liners from their labeling regulations but cloth diapers themselves are not specifically mentioned.
"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.
- Belts
- Suspenders
- Arm bands
- Neckties that are permanently knotted
- Garters
- Diaper liners
- Labels (individually and in rolls)"
from
http://www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm#coveredIf the diapers are excluded and you do choose to include any of the FTC style care and content info on the product itself beyond your company name on the CPSIA tracking label then you must include all of it on a label possibly a separate from the CPSIA tracking label. Both agencies want their information on the front of a label so either you would have to make one large enough for all the required info or 2 seperate ones, & keep in mind that neither agency has said officialy at this point that the label info from the 2 spearate agencies can be combined in 1 label. They are two seperate agencies with different requirements to be compliant under the different laws that each agency is in charge of overseeing.
The CPSIA tracking labels are required on all childrens item producted after Aug 14th 2009 you need a permanantly attached tracking label according to the CPSIA, there are no exemptions to this even if your raw materials are exempt from lead testing. This label's purpose is strictly so when the CPSC issues a recall on a product there is an easily identifiable and similarly formated label that any adult can readily read to see if that specific item is on the recall list.
For a crafter the CPSIA label must include at minimum :
* Your company, shop name, or RN#
* The city, state/territory, & country where the item was completed
* The date of manufacture or completion of the product
* If you making several identical items from the same batch of raw materials or repeat a popular design several times during the year out of seperately purchased raw materials you may also need to put a lot # on the labels to know which ones were produced at the same time out of the same materials. For more info read these Tracking labels
http://www.cpsc.gov/about/cpsia/sect103policy.pdf and CPSIA's FAQ page
http://www.cpsc.gov/about/cpsia/sect103.html#103q8 You can use iron-ons if you want a tagless style of labeling, just remember if you use iron-ons to get the GCC or test results on the tranfer media, it's not exempt like fabric labels or the CMYK ink jet process. There are several companies that make iron-on transfer media that you can run through your printer to make the labels with the information that you need to comply with either agency as you need them. I don't have any suggestions on which brand to use, but I do suggest that if you decide to go this route to test how many washes the iron-on stands upto using the same washing instructions as your finished product.
