Labeling for August

[Former_Member]

I am struggling to understand the labeling requirements, specifically what needs to be on them and how to make them permanent. It says it needs to be: "the source of the product, the date of manufacture and more detailed information on the manufacturing process such as a batch or run number".
What is the source of the product? Where it is made?
I get the date thing, but detailed info on the manufacturing process???? Like, I sat at sewing my sewing machine at my dining room table and stitched these things together? (just kidding), and I need to make up some kind of batch number and keep records...it is all hurting my head.
I need to make a decision here. I only do craft fairs in the fall season, the deadline for applying for my big fairs is fast approaching, with non refundable registration fees...I figured, I could squeeze out this year (before the Feb. 2010 date), but now I am just not sure.
Anyone have any insight? I have read and re read until my head hurts.

[Former_Member]

Oh, and what really bugs me is that I know that if I decide not to do these fairs due to this issue, I KNOW that there will be plenty of people set up at the fairs that have no idea about this whole thing or just don't care.

[Former_Member]

I didn't know these things were required for the type of products you have in your shop. I would have thought it's more important for bath/skincare products, food etc. but not individually handmade products that are not for skin/internal application/consumption - how on earth are we going to fill out the requirenment of a 'batch' or 'run number'?? Lol!

[Former_Member]

I wouldn't have thought it's such a big issue - I don't really see how it applies to your work as every item is individually handmade (aren't they?).

[Former_Member]

Yes, Ovgilliesdesigens, they are handmade, but will still apply because they are for children under the age of 12. This new labeling law goes into effect August 14th. If you don't make items for children under the age of 12, you don't have to worry about it.

[BebeChicBoutique]

Counting Bunnies
I have been struggling with the same issues. I will be doing two shows in Nov. I'm worried sick what the CPSIA will say about the labeling issue that takes place in Aug. There has not been a lot said about this issue yet. But I think in Aug. we will see more on it. The law says we have to label, so I think we have to proceed with labeling, I'm just not sure about the batch and all that. Actually labeling laws as far as care and content have been in place for a while. I just don't think craft show people pay attention to it.

[Former_Member]

BebeChic and CountingBunnies, one idea that was put forth several months ago addressing the batch/run numbers problems was to use a date (I believe this was following Gymboree's lead, but don't quote me on this point). So our labels would have my business logo/name/2009 (or 2010, etc.). If the volume of your business warrants, you could split the year in quarters (Summer 2009, Fall 2009, etc.) to help track the items.

Frankly, like many of us who have a closer working relationship with our customers, to do this makes little sense. I can see the rationale, but it's definitely geared toward the bigger concerns and not cottage producers.

Good luck with your craft shows!

[Former_Member]

I use item numbers in my website to id items - you could label them with your name as the source of the product, the date of manufacture (year?), for the process put something like 'made by hand at home by myself' (smoke or pet free home for more info) and give each item a unique number (for batch/run number), say something like A00001 etc. (I use J for jewellery, A for art, C for cards etc) You might be able to use a stamp with changeable numbers for this part of the label with the appropriate ink

[germandolls]

marking this one. no clue how to handle this...

[Former_Member]

Marking-

Ditto to BebeChicBoutique, Fabric content and care labels have been required for years now.

[MomNMiaDesigns]

As with many of the issues raised by the CPSIA, the labeling requirements have not yet been clearly laid out by the CPSC . . . *sigh*

[FayeMaloneDesigns]

Well, guidelines have not been issued by the CPSC, and we may not get any until August. Sooooooo, I wouldn't worry about it. If the date is Aug 14, and they don't issue guidelines until then, and it takes 6-8 weeks to get labels then you won't have labels until Oct. And since the CPSC doesn't have a clue how to "mark with permanant labels where practicable" how can they expect us to know. If you are already following the labeling required, if any, for your product, and you keep records of what you make and what supplies you used, and records of who you sold to and what, then at this point, you are doing far more that WalMart is doing to keep track of who is buying a baby onsie from their baby dept.

Are you that use textiles already using the guidelines for labeling from the FTC? http://www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm#covered

If you are then you are already on the way to being "compliant".

[Former_Member]

marking...

[Former_Member]

marking too. I need info on this as well. It's too confusing. (like most everything concerning the CPSIA!)

[Former_Member]

Also need to keep track of this issue (for my other shop).
Where are people going to get their lables made? And are labels required if you use materials that are exempt from testing (wool, cotton)?

[Former_Member]

I don't remember exact days of past children's creations though the material will be obvious. Hopefully there won't be a problem.

[Former_Member]

Do the labels themselves need labels saying the labels are safe?????
And so on and so on... :P

[Former_Member]

Knit2getherInLove says:
Do the labels themselves need labels saying the labels are safe?????
And so on and so on... :P

~~~~~

lol, that's coming next, knit2!

[BebeChicBoutique]

Thank you FayeMaloneDesigns for the link. Everyone needs to go there and read the labeling laws. I was surprised about a lot of things that are not necessary to permanently label. But...I guess CPSIA may change all that if the items are intended for children.

[Former_Member]

Despite all the efforts to get Congress to create a reform CPSIA bill the labeling portions were never challenged and this is what will sink any changes that could come in regard to testing.

The OP asks how a label would need to read - if you test the final item it would read like this -

Made by XYZ Toys at Philadelphia, PA July 4, 2009 Batch 15 Run 32 Dog Puzzle Toy 1

Now try to get that on a permanent label on the example dog toy puzzle. Now imagine if you are making something smaller - how are you going to fit this on a permanent label? And each batch and run and date requires a NEW printing of labels.

Let's say you make fabric items. The usual thing is to have fabric labels printed and sew them into the doll, quilt, sweater... Now, how few labels can you get printed this way since every batch, run, date requires a new label? Not possible! This is NOTHING like fabric content and care labels which can be mass printed because the bulk of the items made share the same content and require the same care.

If component testing is allowed if the CPSIA reform bill passes then each component will have to be reported on the label - since you are not testing the final item. Imagine the length of that label.

The law does say - “to the extent practicable,” and many have seen this as an out - BUT- who decides whats practicable? If you decide that and CPSC disagrees and finds your abbreviated label in violation you are guilty of a Federal crime.

This is not to be discouraging, but it is intended to get you to make this problem known to your Congressmen and Senators along with the need for changes in the testing requirements. This all must be changed or everyone who makes things for children under 12 is going to have to make a conscious decision to stop and start making adult items or knowingly break the law and risk hefty fines and worse.

[Former_Member]

Read the FAQ from CPSC directly - this has nothing to do with the current textile labeling requirements - this is in addition to those and applies to all items intended for children under 12 -
http://www.cpsc.gov/about/cpsia/faq/103faq.html

[Former_Member]

Now, my head hurts.
I use a fabric marker for my label when I do I quilt. Do you think this would count as a permament label on my kids's items?

[Former_Member]

Micro print with a super-extra-fine permanent marking ink. Must be read under microscope!

[Former_Member]

Thanks everyone for posting. I appreciate the input. I can see there are plenty just as confused about this as me. I currently do attach content and care labels to my dress up clothes, but this is easy - sewn on fabric label, the new label presents the problem and also has the potential to make the item to not look as nice.
Not sure what I will do for the craft shows, but I must decide by the end of the month.

[Former_Member]

marking