Actually if the retailer is requesting that the labels are to be left off that they can include their own branding labels then that makes them a private labeler in the CPSC's and FTC eyes. AS a prvate labeler they are now responsible for all the testing, records maintainance, and mandated labeling.
Rewrite your wholesale or consignment contract w/ the help of a legal professional to reflect that as long as your products are sold under your "branding" you will provide all required testing and paperwork, maintain those files, and include all required federal labels. Though if a retailer or consignor requests that you leave off any mention of your company or brand or if they remove any required tags themselves that they have now assumed the full responsibility for meeting all federal laws and regulations by becoming a private labeler. You can even include a disclaimer right on the GCC that if the product is altered, by additions to or subtractions from, in any way after delivery that the person that affected the alterations is now the new "final" creator of the product and that the GCC only covers the original rendition of the product.
