FTC & CPSIA Labels - Specific Info on Labels

[Former_Member]

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!

[Former_Member]

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

[FayeMaloneDesigns]

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.

[Former_Member]

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!!

[Former_Member]

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 .

[Former_Member]

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

[FayeMaloneDesigns]

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.

[Former_Member]

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 .

[Former_Member]

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?

[TurkandBean]

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

[FayeMaloneDesigns]

NWTags labels are woven ribbon labels, so no printing. They are exempt from testing and very professional looking

As to printing your own FTC labels, there is a strict type size and style to use. That is why I buy mine. They are very professional looking and not expensive.

Can they be combined . Care, content and size can be combined. The ones I get from NWTag.com combine content and care, but I buy seperate ribbon size labels. They are two agencies, and they haven't said, but If I put my CPSIA information on the same label, it would be pretty darn big. Bigger that I would want to put in a child's garment.

Children don't like tags. Which is why I use the soft woven NOT PRINTED ones . I do use cotton ones printed on my printer for CPSIA, but I stitch them down on the facing or waistband so they are going to poke them.

[Former_Member]

Getting ready to reopen my shop after a 2 yr hiatus. Wow this is all so confusing!!

Couple of questions.

Beverly or Mary would you mind posting a pic of your labels? Beverly I checked the site you gave and it is really reasonable. For the CPSIA label that you said you print do you have to use special ink?

Oh, one more question. Is it ok to sew these into the side seam?

I really appreciate all your help!

Hugs,
Gina

[Former_Member]

Maybe I'm thinking too hard about this... My brain hurts. But here goes...

RE: the following on http://www.cpsc.gov/ABOUT/Cpsia/faq/103faq.html#premiums

"cohort information (including the batch, run number, or other identifying characteristic) and any other information determined by the manufacturer to facilitate ascertaining the specific source of the product by reference to those marks."

If you're making only a few products every now and then and batch/run numbers don't apply to you, would including an "item number" on the CPSIA tag be considered an "identifying characteristic"?

I guess in the event of a recall, for instance, you could figure out what the item was based on the year and month it was made (which is on the CPSIA label).

But hypothetically speaking, let's say I made two identical looking bibs in the same month and year but one used snaps made from company A and the other from company B. For some reason, let's say, company B's snaps are getting recalled. So therefore, that bib would also get recalled. In the event I have to identify exactly which bib needs recalling, the date and year system wouldn't help me. In this instance, wouldn't an "item number" be a better idea?

I was thinking of making a file of all the details of all the component parts I'm using on any given item with and assigning an "item number" to these items. That way in the event of a recall, I can track all the components used on a particular item.

I guess then the problem becomes printing a different label for each item....


aaaagggghhhhh. Need help

[FayeMaloneDesigns]

You do not need cohort information. You may not need batch information. But in your hypothetical case, you may want to put a batch letter or number on the tag, if on the same date you use different snaps. If on different days, just keep track by the date, if you are putting more exact dates on your tags

[Former_Member]

If you are making similar products using different batches or lots of raw supplies then yes you will need something on your tracking label to distinguish them from each other if your unable in any other to tell which group of supplies the product was made from. You can choose to call this distinguishing factor anything you want such as lot , style , batch , version, or even use an unlabeled code that only has meaning to you, that's why the government uses the wording of cohort information. BUt if you have a way of telling by the tracking label the difference between 2 or more similar items of yours to exactly what group of raw materials went into their making then you you don not need to include additional identifiers.

[Former_Member]

Thank you both so much for all your help!

[Former_Member]

I have been researching and asking in some different places trying to understand all this information and I think I understand it. To be safe I am planning on labeling everything. I was planning on using 1 tag with all the required information. Is this legal or do I have to have 2 tags. Most of the items I make are not that big so 2 tags would be hard to put on.

I do not have anything in my shop at the moment but you can look at the blog that is attached to my shop. The things that I would be doing right now are the yarn items since I have to do more research on whether or not the fabric items would have to be tested. Things such as hats, slippers, toy bears (all made with yarn/embroidery thread and stuffed), toy balls (same as bears), scarfs etc. Now I've read that hats and slippers do not need a tag for the FTC requirements but would they need a tag for CPSIA or is that something that I can put on a hang tag (tag insert type thing) when it is packaged up. I do have to do all hand sewing since it is going to be crocheted items so I would need a place where I could get the tags (whether it is 1 or 2 tags) so what are your suggestions?

One last question. I've started making some towel toppers obviously I don't make the towels I buy them...would I have to label the top part of the towels?

I really need to figure all this out before I open up again and I really need to get working on some items to get opened up.

[Former_Member]

Can someone point me in the right direction for labeling requirements for cloth diapers????

I *heard* that we're not required to have the labels ON the diapers, but I'm thinking that's probably inaccurate? It just sounds too simple for how complicated all this is!

THANKS SO MUCH!!!

[earthgrowncrayons]

Will someone give me feedback on my labels. I am hoping I did this right. I use a slim-sized business card that I place in each of my crayon boxes.

Front of tag (card): Business name and logo.

Back of card: 2-3 sentences of general information about my crayons. Then for the required information I have:
Ingredients: soy wax, nontoxic pigments (certified AP Seal from ACMI)
Made in Minneapolis, MN USA
Batch Number:

I think I will hand write in the batch number of each set? I'm at a loss. Thanks for your feedback!

Melissa

[Former_Member]

Ok, so, wait - if we print our own clothing tags, do we have to get a GCC on the ink/toner used? And for the printable fabric?

[FayeMaloneDesigns]

Corrine, NO. The fabric is exempt if it is sew in. The ink used by ink jet printers is CMYK also lead free, exempt. The majority of home computers in use are using ink jet printers.

[TheBebeCouture]

I am so frustrated with all of this CPSIA stuff. Just when I think I am getting everything in order I find out something new, and get so lost again. I was all ready to order some tags and found out there has to be a CPSIA and FTC one and they have to have all this different information and the FTC has to be a certain size and font. I am so beyond lost and have a customer who ordered something and I cant send it out until I get this label thing together and am afraid I am going to do it all wrong. I am so lost and confused!!!!

[Former_Member]

Beverly from FayeMaloneDesigns says

As to printing your own FTC labels, there is a strict type size and style to use. That is why I buy mine. They are very professional looking and not expensive.


Beverly: where did you find this info about the required size and font. I couldn't find a reference for this on the FTC site. maybe I missed it??

[FayeMaloneDesigns]

it's on the FTC site. Truthfully, I think some of you are spending too much time, remember time also =$$$ fretting over this FTC tag situation. You can buy beautiful FTC tags already made very reasonably and they are perfect. You don't have to spend the time finding the printable fabric, setting up the template, printing them, curing them, cutting them apart, yada-yada. Done!

http://nwtag.com/html/stockcare.htm

I use number 7

Stock Woven Care/Content Labels
White background with Black Woven Lettering
Labels are Appx. 1" wide with various lengths
Packaged One Care/Content Per Bag

Bag of 100 $9.00
Bag of 250 $15.00
Bag of 1,000 $35.00
Back To Top

http://nwtag.com/html/stockst.htm

Stock Woven White Size Tabs
White Background with Black Lettering
Approx. 1/2" x 3/4" folded

100 5.00
250 $8.50
1000 $20.00
One Size per bag.
White Woven Size Tabs available in these popular sizes:
P, XS, S, M, L, XL, XXL, XXXL 1, 2, 3, 4, 5, 6, 7, 8, 9, 10 11, 12, 13, 14, 15, 16, 17, 18, 20, 22, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 38, 40, 42, 44, 46, 48, 50 3mo., 6mo., 9mo., 12mo., 18mo., 24mo. 1T, 2T, 3T, 4T 1X, 2X, 3X, 4X, 5X, 6X One Size Fits All,
Dry Clean Only, Made In U.S.A., 100% Cotton, 100% Rayon, 100% Silk, 100% Wool

Stock Label Order Forms

[Former_Member]

I completely agree that stock tags are the way to go if you can. I have been working with a graphic designer to redesign my logo...which means new clothing tags. I wanted to make sure I had the other tags right too.