"I make hand-crafted goods in my home. What do I need to do to be in compliance on August 14, 2009?
The Commission has received a great deal of comment and input from hand-crafters regarding the implementation of Section 103(a). As noted in the Statement of Policy, the Commission anticipates that there will be a period of education after the new requirements go into effect and expects that each manufacturer, large and small, will consider how to apply these requirements to their business.
Hand-crafters should consider the following:
1. What kind of tracking system do you currently use? You do not necessarily have to create a new system of lot, batch or run numbers to identify when you made your products, however your products and their packaging should identify your company in sufficient detail to enable a consumer to reach you so that the required information may be ascertained.
2. What information can be ascertained about your product? If someone handed you one of your products sold last year, what would you be able to tell them about the materials used? Keeping your receipts and purchase orders will help you to better know the source of your product and its components and when you began using them. Ask your fellow hand crafters if they have any tips or ideas that can help.
3. How is your product marked? If someone had one of your products sold last year, would they know who to call if there was a problem? Absent any unusual circumstances, your business name should be on your product with sufficient detail to enable a consumer to reach you. Congress recognized that there could be instances where marking a product might not be practicable, such as where the product is very small. Consider the examples outlined in the Statement of Policy where it might not be practicable to mark a product.
4. How is your packaging marked? Can a retailer of your product see from the packaging (or from the product if the product marking is still fully visible) information that they could use to take just your products from the shelf in the event of a recall?
Compliance with the new requirements will call on a number of small hand crafters to rethink the way they maintain their records and mark their products.
Posted 07/21/2009.
Back to FAQ Page | Section 103 Page
I make children’s wooden blocks that have twenty in a set. How do I mark these products?
Congress recognized that it might not be practicable to mark every part of a child’s game that has a board and small game pieces. Apply this idea to your product and it may be unnecessary to mark all twenty of the blocks in each of your sets. Depending on the nature of your blocks it might also be reasonable to mark one side of one block. If the blocks come with a storage box or bag, these would be areas to place a mark
Posted 07/21/2009."
From
http://www.cpsc.gov/about/cpsia/faq/103faq.html#103q9
