Labeling for personalized items?

[Former_Member]

I sell personalized items for kids and adults here on Etsy and my own website. If component testing was allowed then that would make things a lot easier for me, but the labeling is a nightmare.
Does that mean each lunchbox or tote I personalize is its own batch number? And what info has to be on this label...production date, place, cohort information, etc.
Headache...makes me sad but seriously thinking of getting out of the kid game come August. Too much to keep up with and exhausting to keep fighting.
Any ideas?

[FayeMaloneDesigns]

Monkeysprout, we don't know what is required yet, the CPSC has not issued exact quideline. Reading the latest on the labeling, it appears that whatever works for you is currently allowed. Obviously, since kids products range from jewelry, to booties, to blankets, toys, clothing and books to just name a few, a one size fits all label won't work.

Since you make each item personalized, then you know who each customer was, and the specific info on each item. Autograph each item with your shop name, and date. Keep a card file with each customer's name, and other info, and write down what you used to make the item, vendor and their batch info from a label, or attach their label to the card.

I don't think the label police are going to come after us, we are only making 1 or a few of each item. I think that you can work out a system if you don't worry about the "rules". The issue is tracking of supplies used if there is a problem in the "food chain" where lead is found.

[Candejo]

Labeling information:

Section 103
http://www.cpsc.gov/about/cpsia/summaries/103brief.html

FAQ for Section 103
http://www.cpsc.gov/about/cpsia/faq/103faq.html

[BebeChicBoutique]

OK, I'm stressing over this permanent labeling.
Would source be something like made in USA or my business name?

Date I understand. I think someone said they do Spring 2009 etc.

Cohort information has me puzzled. That is batch and run, right?

Do you think keeping an inventory of each item noting the fabric manufacturer from the selvage edge, giving it a number, and using that number on my permanent tag would work?

Just trying to keep doing what I do within the law.

[FayeMaloneDesigns]

Read this PDF from the CPSC http://www.cpsc.gov/businfo/frnotices/fr09/trackinglabels.pdf

Go to the bottom right of the first page and you will see cpsia labeling. It continues on to the next page. You have 24hrs. to respond to cpsc's request for questions and respond to the questions they posed. Ask them your specific questions. Answer their questions specificaly based on what you make.

This entire law was written by aides to Waxman and Bobby Rush without any clue on how any part of it was going to be implemented. Nearly one year after it was passed no one still knows how the heck to comply, or to enforce the thing, and how many people have been put out of business and the loss of income in this economy.

And if you read the 1st link that Candejo listed above, congress has given them the authority to require labeling on ALL CONSUMER PRODUCTS! This is an absolutely impossible rule to follow. Can you see your wedding rings... you won't be able to inscribe on the inside. It will be taken up with a permanant label, that will probably have to continue on to the front. And are you going to have to have a permanant label hanging from your earings?? And how would you put a permanant label on a bar of soap???? Wouldn't using the soap wash it off? We are being ruled by idiots.

[Former_Member]

I absolutely appreciate the responses but.....
I have been in and out of CPSIA forums on lots of websites, including the cpsc.gov website, since September. I've read, reread, commented, and asked a lot of questions.
Nothing in the links given above or written in the law give any real guidance on batch numbers, labeling, etc. The labeling sections of the law are vague at best and cannot work for the many industries and products it's meant to apply to.
Anyone doing personalized items doesn't work in batches....period. The assumption is that everyone sits and makes a batch of 500 of the same product and then sells those products. Wrong. I don't make my "batch" until I get the order with the personalization the customer requests. I've done my component testing and XRF testing but that eventually will not be good enough. Soon, I will have to produce two personalized items...one to be destroyed for testing and one to sell to my customer (nevermind the cost). If I sell 200 personalized lunchboxes in July then I will have 200 batch numbers....fabulous.
So sorry for the rant, but any links to the CPSIA pdfs and the CPSC website regarding labeling requirements is no help to anyone because this law, as we ALL know, is so poorly written.
Thanks for letting me blow off some steam, but would appreciate any info specifically for the personalized product business!

[Former_Member]

To my knowledge there have been no specifics in this CPSIA law that address the situation for the personalized product business & as a seller of personalized products,I find this whole CPSIA mess a useless piece of legislation that serves no purpose as is.

[Candejo]

While I totally understand your frustration, the only thing you'll get here is opinions - some of which scare me. LOL Such as "ignore it", "you don't have to follow it" and "since there are no CPSIA police who cares, they won't come after you". MPO only - I think that's dangerous.

The reason I posted just the links are because those are the facts. They do address what needs to be on the labels...sort of. My only other suggestion would be to converse with Kathleen at Fashion Incubator about what labeling for small (0-10) batchs might consist of. Here's a jumping off point with her thoughts about what it means in this blog post:

http://www.fashion-incubator.com/archive/cpsia-and-tracking-label-requirements/

[Former_Member]

The fact is when it comes to this labeling stipulation, nothing has been addressed for those of us who make personalized wood products &/or wood toys, as well as a number of non fabric products. The bottom line is this law was passed without the thought processes in how all these changes are expected to be carried out by the small home business.

[Candejo]

Maybe a good place to ask/get info about the type of products you're talking about would be the Handmade Toy Alliance? Here's a link to a quick search on their site about product labeling:
http://www.handmadetoyalliance.org/system/app/pages/search?q=label+requirements

I think there's a contact button there also. I'm pretty sure they have a facebook also, maybe you could ask specific questions unique to your business?

[FayeMaloneDesigns]

You are all right. Nothing has been done about the small item maker or the personized maker or the one off maker. It's because the whole law wasn't written with us in mind. They have their heads up their butts in the DC rarified air. That's why the CPSC asked for comments. If you don't speak up and address the issue with the CPSC by April 27th then we all again are silenced. I make one of a kind garments either custom from a customer's measurements, or as individual OOAK garments in a given size. Putting a label with a batch, run, whatever number would mean nothing to anyone. I keep a cardfile on every item I make. I put a sample of the fabric, trim, buttons. etc. I have the customer it was sold to, the shipping info, the date the cost of the goods, and the selling and shipping price. I don't know what more I could do to make anything any more clear to the gov. So should I put a 4th label besides the size label, the care label and my designer label? One that says April 26, 2009 batch 1 of 1? And what really does it mean if I don't have the date the fabric, buttons, thread and any embellishments are made, batch # run # and on and on? And are all of those items going to have to have a permanent marking? The whole thing is insanity! We all will be drowned in meaningless paperwork, while the Chinese products that have caused all the recalls will still be imported with lead, phthalates and lead paint. They can just phoney the paperwork.

[Former_Member]

Marking

[Former_Member]

I hope none of you think I was being rude when I said that about posting links from the CPSC website...especially Candejo...not my intention at all!! I absolutely appreciate it and more than agree that the "don't worry about it" approach is so dangerous and a risk I'm just not willing to take. I, too, believe there is a lot of misinformation on this forum and poor advice being given.
I have posted comments and questions on the CPSC site, written the letters, signed petitions, spoken to my district politicians, etc. I have done what I can as so many of us have.
I have ideas of how to permanently mark my items, but the batch number thing is ridiculous for the types of things we make here which are generally one of a kind.
Thank you so much for any info and I apologize if I sounded rude...just frustrated!!

[FayeMaloneDesigns]

Monkeysprout, You weren't rude, you're just as frustrated as the rest of us. And I truly believe that Nancy Nord is as frustrated. She's been given this law that is far reaching, with no real implementation rules, without the authority to overide it's wording, and without the forethought of the writers of what it would do to the businesses that it affects.

I hope no one really thinks I'm just saying go about your business, and ignore the whole thing. I've hardly ignored it. I've just stopped losing sleep over it. I'm working to comply, but remember, the labeling rules have not been written, they are still in the public question stage, we won't know what the final rules are until they are written. You can't order labels until then, then it's going to take some time. In the mean time you could always use a permenant micro point pen and write a code of some kind on a label and sew it in a seam.

I looked at the back of my hanes nightshirt this morning. There is a tagless label in the back of the neck. The only thing large enough to read is Hanes, and the size. The 8 lines of info below that is twice as small as the link printing at the bottom of this page. One would need a microscope to read it. So maybe they are following the letter of the law, but what good is it.

I'm really not worried about the cpsc knocking on my door and throwing me in jail for not having a permanant label with meaningless information about a OOAK custom made dress out of cotton. I keep detailed records. I could do the micro point pen notation or I could charge $75 additional for another custom label for each dress.

Then again, since we now have a Czar for everything in DC, maybe we will start having a Lead Nazi, a Label Nazi, a Phthalate Nazi. Think of all the "good jobs" that will be created.

[Former_Member]

Labelling for non-fabric items is equally frustrating...how to permanently label jewelry or wood products is a challenge all on its own. Until this aspect of the law is resolved, there is little we can do. We can't comply with anything permanent until the CPSIA comes up with their solution to this problem. In the meantime, all we can do is affix labels to packaging.

[Former_Member]

I have said this in other threads - no matter what changes COULD come in the testing, it will be the labeling that will finally bring all of us down. And because - as has been the history of all aspects of CPSIA - there is no notice of a pending problem until the hammer is about to fall.

The CPSC faq is very specific about what needs to be on the labels - there is no question of that. And the amount of text required is staggering. Where in other labeling regulations here and internationally standard symbols or codes are used to designate what is required, there is no such allowance here - and no way to do that with the specific things that must be on the label.

A personalized or custom item must meet the exact same requirements of a stock item.

It is time to get the word to Washington that not only are the testing requirements putting cottage businesses out of business but even if they fix that the labeling requirements will follow in accomplishing our demise.