Labeling items

[Former_Member]

I am having the hardest time figuring out how in the world am I going to permanently label hair clips. Does any one have any information on how they are wanting us to label hair accessories and so forth??

[wigglysee]

If I am reading the information correctly and hopefully someone else will correct me if I am wrong. With hair clips you can label the packaging not the hair clip itself.

[Former_Member]

What exactly does the label have to include?

[wigglysee]

The label need to include:
(company name and location along with date of manufacturer, which is the date of completion)

Separately,you need to keep track of all components that are going into the item and be able to identify what specifically was used in any individual item. This is for your records and does not need to be included with the hair clip.

[TheWrapScrapPony]

Please read the CPSC's guidance on labels

http://www.cpsc.gov/about/cpsia/sect103policy.pdf

It specifically answers your question :)

[Former_Member]

So come Aug. 14th all items have to be labeled and 3rd party tested??

I am so confused and losing so much sleep over all of this added stress! :(

[Former_Member]

Yes that is rite

[Former_Member]

Bella - The testing doesn't come into effect until February 2010, but you are correct about the labeling. I, too, make hair clips and have lost sleep over this but was so relieved to hear just the other day that we can label our packaging instead of the clips!

A fellow Etsian, BuggaLove, has an awesome blog and really keeps on top of things with CPSIA. Check it out -

http://buggalove.blogspot.com/2009/07/cpsia-labeling-guidance-issued.html

[Former_Member]

Does anyone have the actual link stating that third party testing does not have to be completed until Feb?

[TheWrapScrapPony]

Just go to the CSPC website. They have FAQ about all the different issues on the CPSIA, including the stay of testing until feb 2010.

[ballyhoocreates]

The rules specifically call out hair accessories as an item that doesn't need a permanent label - packaging label is fine.

The rules are only 6 pages long. I don't even make children's products and I've read them several times.

[Former_Member]

Great advise to read later.

[Former_Member]

I believe we have to have permanent labels on headbands, hats, etc since those are big enough to label, but the hair clips themselves are too little and that is the reason we can just label those on the packaging.

[Former_Member]

What about this lead testing stuff? What are you doing about it? As far as I read about it, I can't afford it. My items are made in very small collections, using differnt fabrics for the next collection. I probably will have to stop making a children's line. bummer. Hoping that someone knows more than me....

[Former_Member]

If you go to the CPSIA website you will see a frequently asked question by hand crafters that explains that you only need to mark your items with an identifing label so that the consumer can contact you in case of a recall. In you home records you need to keep a record of the items you sell. When they were made and the components. You also are suggested to keep all your receipts so you can identify where and when you purchased your components. These records should be kept in case of any recalls. I already keep records of all the items I sell and who I sold them to. I just have to add the components included in the items to my records. Seem simple enough to me. I am keeping my shop open.

[Former_Member]

Thank you very much for this posting BellaPrincess, my wife and I really appreciate all of the information here. We are new to Etsy and will now make sure that anything that could go to or be considered for children is properly labeled.

[HELLOhappy]

If you read this > http://www.cpsc.gov/about/cpsia/sect103policy.pdf

"Question 4: when can only the packaging be marked and not the product?

answer 6: if the aesthetics would be ruined and it can't be placed in an accessible but inconspicuous location."

Very very very grey area.

[SoCuteSewing]

marking

[NotMyTreeStore]

I don't believe it's a gray area at all. I think they've clarified the labeling requirement very well.

[MossMountain]

couple Q's ...

1. is there a place that talks about what the labels should be made of? for instance, if they are permanent, you can't just pring them on paper and sew them in, can you? i suppose they need to be fabric labels. how/where do you get those done? is it expensive?? :o i'm about to lose sleep too.

2. as far as the third part testing ... this is ... really scaring me. we have to do this after feb. 10 on any products intended for children under 12? again, how/where do you get it done?

after feb. 10 i may have to call it quits on children's items. most of my stuff is for adults are people over 12 anyway ... but i was hoping to sell some child safe toys. maybe not.

[Former_Member]

hellohappy says:
If you read this > http://www.cpsc.gov/about/cpsia/sect103policy.pdf

"Question 4: when can only the packaging be marked and not the product?

answer 6: if the aesthetics would be ruined and it can't be placed in an accessible but inconspicuous location."

Very very very grey area.
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jakboutique says:
I don't believe it's a gray area at all. I think they've clarified the labeling requirement very well.

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Oh, it's grey. Extremely grey. And that's a GOOD THING. Trust me when I say you DO NOT WANT a black and white guideline on this. It would be extremely detrimental to most of us.

Take my products for example. I could EASILY say that my mobiles cannot be labeled because there is no place on them that is both accessible and inconspicous. That statement would be 100% true. HOWEVER, I have made a choice to label them anyway. The label will not be inconspicous (it will be very obvious) and may affect the aesthestic of the product. But I'm doing it anyway. See the grey?

[NotMyTreeStore]

No, I don't see the gray. The clarification the the CPSA states that if it does affect the aesthetic and that there is no place for a label, then the labeling requirement may be modified to fit the product. Sellers who choose to label anyway are obviously able to do it if they want to, but the clarification of the requirements makes it clear that they understand that not *everything* can be labeled. That's not gray.

[Former_Member]

Ok, let me try again.

One mobile seller chooses to label their mobiles. Another mobile seller can choose to only label the packaging of their mobiles. BOTH sellers will be in compliance with the labeling regulation.

That is grey. Because a SELLER is choosing how to comply with the law and not being made to fit their square product into a round peg.

[NotMyTreeStore]

>BuggaLove says:
One mobile seller chooses to label their mobiles. Another mobile seller can choose to only label the packaging of their mobiles. BOTH sellers will be in compliance with the labeling regulation.

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Exactly. That's why I don't think it's gray. They've clarified what sellers need to do to be in compliance, and the parameters for being in compliance are wide - they're not fuzzy or undefined. They're just allowing people to use common sense and are not mandating a one-size-fits all way of doing things. I think it's good for everyone.

[HELLOhappy]

@ jakboutique
What I meant was, they basically say if it makes your item ugly you don't have to attach a label to the item. Ugly is a very relative term so that's what makes it grey.