The Gerber diapers seem to be excluded from FTC labeling but since you are repurposing them into something that is not a diaper you may have to label them under the FTC. As for not having the CPSIA tracking label I know from dealing with Gerber when I had a B&M boutique that many of their items are made upto a year before it arrive at US customs so what you see in the retail stores or at wholesale warehouses right now may of been made in late 2008 early 2009 before the CPSIA tracking labels were in effect.
Since the item your making does not seem to be on the FTC exemption list then you do have to label your final product with all the necessary care and content information. If the item was made on or after 8-14-09 and is being marketed as a child's or child care product then you do also have to follow the CPSIA tracking label regulations regardless or the exemption status of the raw materials or components you are using.
Here is a list of FTC labeling exempt items from
http://www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm#covered"The following items also are excluded, unless you choose to make a statement about the fiber content. If you make any representation about fiber, all of the requirements for fiber content disclosure, described on pages 7-19, apply.
Belts
Suspenders
Arm bands
Neckties that are permanently knotted
Garters
Diaper liners
Labels (individually and in rolls)
Looper clips intended for handicraft purposes
Book cloth
Artists’ canvases
Tapestry cloth
Shoe laces
All textile products manufactured by operators of company stores and sold exclusively to their own employees
Coated fabrics and those parts of textile products made of coated fabrics
A coated fabric is any fabric which is coated, filled, impregnated, or laminated with a continuous-film-forming polymeric composition, and the weight added to the base fabric is at least 35 percent of the weight of the fabric before coating.12
Secondhand household textile items that are obviously used or marked as secondhand
Non-woven disposable products intended for one-time use only
Curtains, casements, draperies, and table place mats that are made primarily of slats, rods, or strips that are composed of wood, metal, plastic, or leather
Textile products purchased by U.S. military services according to specifications
However, textile products sold and distributed through post exchanges, sales commissaries, or ship stores are covered. In addition, if the military sells textile products for nongovernmental purposes, the fiber information must be furnished to the buyer for labeling the products before distribution.
Hand-woven rugs made by Navajo Indians with the attached “Certificate of Genuineness” supplied by the Indian Arts and Crafts Board of the U.S. Department of Interior"
There is no exemption list for the CPSIA tracking labels if the product is seen under the governments criteria as a child's product.
Tracking labels
http://www.cpsc.gov/about/cpsia/sect103policy.pdfCPSIA's FAQ page
http://www.cpsc.gov/about/cpsia/sect103.html#103q8
