Link for Tracking Label Guidance

[#1]

http://www.cpsc.gov/library/foia/ballot/ballot09/tracklabelpolicy.pdf

I just got this and haven't read it yet...

[Former_Member]

Wow... the word that comes to mind upon hearing this...

hallelujah! They have some sense in them after all! Yay!!!!

Now to hope they have similar senses in regards to the testing requirements, as that is still going to prevent me from making beads for kids since it will completely destroy the product (falling under the pthalate testing).

[NotMyTreeStore]

Thank you for posting the link. It all seems practicable to me :-).

[ballyhoocreates]

I am so impressed they considered crafters in the rules and I'm sure it was a direct result of everybody's hard work lobbying for fair rules.

Great job to all who endured the red tape!

[Former_Member]

This is, indeed, great news. How we are supposed to keep up with all of these 'statements' put out by the commissioners is beyond me, though. Thank goodness for the Etsy forums.

Has anyone seen any information on childrens items made from vintage or recycled materials? My daughter makes little girls Pocket Purses out of recycled blue jean pockets that she embellishes. And I have seen childrens clothing here on Etsy made from old linens, like vintage table cloths, pillow cases, etc. How do we comply with the record keeping parts of this law?

I also have a stash of fabrics that goes back at least 25 years, in addition to fabrics I have inherited from my grandmothers. Does this mean I can't use any of these to make childrens' items because I can't document their origin?

[Former_Member]

My blog on labeling requirements....http://buggalove.blogspot.com/2009/07/cpsia-labeling-guidance-issued.html

[Former_Member]

Whew...I new they would wake up sooner or later! Yahoo!

[Former_Member]

marking

[Former_Member]

What cohort information is to be marked or ascertainable? Do small volume
manufacturers or crafters need to create a system that includes batch, run or other
numbers?


Although Section 103(a) does not require manufacturers that do not use lot, batch or run
numbers to create such a system, the Commission believes that compliance with this
Section generally will require that manufacturers have in place a reasonable means to
ascertain detailed production information, including the means to distinguish products
made from different factories, made with different components, at different times or have
other material differences that make the product non-identical from previous products.
The business and recordkeeping practices of peer manufacturers should be considered.
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.

[TheWrapScrapPony]

3craftyladies says:
This is, indeed, great news. How we are supposed to keep up with all of these 'statements' put out by the commissioners is beyond me, though. Thank goodness for the Etsy forums.

---------------

You can sign up on the CPSC website to get emails everytime they update with new info on the CPSIA. I have and it's been very insightful to read the actual documents rather than just getting the important tidbits posted in the forums. Although I do appreciate those who do bring those important tidbits to light :)

As far as your question about recycled materials. Hmmm, that is an excellent question to which I have no idea on how to answer! I'd like to know though.

[allisajacobs]

Thanks for posting this!

[FayeMaloneDesigns]

If your vintage materials are on the exempr list there should be no problem that I can see. Just keep a swatch of the fabrics on an index card with the date of manufacturer, what it was, and when it was sold and to whom. If you add buttons, etc. attach the button card, a sample of the button, whatever. Attach a photograph of the garment. I put lots of little pics of garments on one sheet of printer paper, and print them off, cut them apart and staple one to the index card. Keep a card file. If you have documentation of testing from suppiers, cross reference that on the card, and keep the documentation in another file in alphbetical order by vendor/supplier. Just be sure you are adding the proper fabric, care an origin labels that you should have been already doing. Add your "designer" label with your company name, city, state.

[Former_Member]

Thank you, myblessedbaby and FayeMaloneDesigns. We are still trying to determine if it is feasible for us to continue making any children's items. We have allowed most of our items to expire in anticipation of the implementation of this law. We just make what we enjoy making, just trying to sell a few items to earn a little money to support our 'habit'. Although all of our items are perfectly safe, this CPSIA thing is quite disheartening.

Today's release is great news. We wish all of you who are going to continue with your dreams the very best of luck.

[SkyviewClay]

sweet!!!!

[BebeChicBoutique]

I need someone else to help me interpret the date part of labeling from this source

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

8. What date of production is to be marked or ascertainable?
The Commission recognizes that products may not always be started and completed in a
single day. The Commission anticipates that the date of production could be a date range
if the product is made over a period of time.

So, can the date be something like spring09 or sp09? Or do you think it should be more specific like 4/09?

[TheWrapScrapPony]

I think they wanted a specific date, but not sure if month/year would suffice or if they want month/day/year. hmmm good question.

[FayeMaloneDesigns]

I don't think they care how you determine date. It is so that you and a consumer can recognize a product if there is a recall or problem and track it back.

If you are using a bolt of fabtic and you make all your items using the same fabric, buttons, zippers and threads etc, what difference does it make if you make one item in jan, feb and not again until may? If there is a problem with a componant in the jan item, would there not be the same problem with the items made in the other months?

But if you a pouring plastic and making 5000 toy widgets at one time and another 5000 widgets tomorrow, an exact date, batch and run number could be very important, if there is a problem.

I think that common sense should be your guide. I don't think there will be a date police, or hidden security cameras in our studios recording our completion of a on off and recording the exact date and time we cut the last thread.

[Former_Member]

I hoped it would not be so difficult! I live in The Netherlands Europe and think it is all a bit too ..... what should I say?
People who buy my stuff know it is hand made from pure wool. As every piece is very unique, is a date neccecairy? I purchase wool from different shops, but store them in the same box...... Oh My, I think I will have to rebuild my crafting space... hihi

[happywhosits]

marking