I just read the compliance interpretation they posted to the site...at the very end on page 6 ---
"Small volume manufacturers and crafters may be unlikely to use lot, batch or run numbers, and, again, the Commission does not interpret Section 103(a) to require them to create such a system. Nevertheless, reasonable practices should be in place by such manufacturers to keep records of components used in their products."
It seems like their interpretation is for large batch manufacturers where there is a question where they might be manufactured or which lot of product was used, etc. Think recalls...I don't think that applies to crafters/small "manufacturers" of one of a kind hand made things!