What is this about labeling?

[CelesteandCompany]

I keep reading stuff about labeling come August? What does that mean? Can someone please elaborate? Thank you!!!

[Former_Member]

The requirements for labeling are extensive. For the exact requirements you need to go to the CPSC site and read their faq on labeling.

In short - each item must be permanently labeled - not the packaging, but the item. This label must contain the maker's name, address, item name, lot number, style number, and that it meets all compliant regulations and was tested. If you change lots - meaning you use a different fabric, a different embellishment, a different color then those items are a new lot and they need a set of labels.

The clause that says "where practicable" is meaningless as it is so open to interpretation that any DA or the CPSC can dispute your way of interpreting it with no effort at all.

Labeling in this manner is just about impossible for home working crafts artists. Many things have no place to put a permanent label and the production of labels with such specifics for small quantities is not possible without great and repeated expense.

If the testing does not knock someone out of business, the labeling will.

Write your Congressman and Senators. This all happens in August and there will be no stay of enforcement.

[Former_Member]

Very good explanation!

[Former_Member]

Will this include jewelry and other accessories? Or just childrends items?

[AuntCindysAttic]

I've been thinking about the labeling...

For me, I hope, lot#s and item#s are fairly meaningless because I typically make unique quilts. I think I could have a fabric label with blank spaces to write in a lot# & item# (with permanent marker). It assumes that I actually use lot#s or item#s! I'm thinking for my lot# I'll just use the date in this format: 090529-1. Meaning - 2009, May, 29th, item 1 that I made that day. I've worked in industry (not toys) and have seen a similar format used.

Does anyone see anything inherently wrong with this? Maybe it's easier to label fabric items than other items.

I have no clue what to do with bows - there's no way I can get all of that info on a frikkin' bow!

[Former_Member]

I need to read the rule again, but I'm wondering if this can be attached to a garment via a removable tag?

[Former_Member]

marking

[SimmonsCreek]

babycheeks,
As far as I understand it, the tags have to be permanently attached.

[Former_Member]

Nope it must be permanently attached to each product, and included on any packaging as well if the label on the product is not readily visable to consumer.
The labeling is in section 103 of the 62 page CPSIA law, but here are 2 other links that give a decent summary http://cpsc.gov/businfo/frnotices/fr09/trackinglabels.pdf and http://cpsc.gov/library/foia/foia09/brief/emergstaytracklabels.pdf .

[Former_Member]

Well, in the case of a OOAK soft sculpture, a label would be completely inappropriate no matter where I put it...

[Former_Member]

Marking for August.

[Former_Member]

If you wait for August it will be TOO LATE.

[Former_Member]

Marking to be ready for August Labeling.

[FayeMaloneDesigns]

The thing to realize about the labeling is far more than just attaching a label. Let's face it, most of us cut labels off things anyway, the gov at this point can't make you keep a label on something that you have purchased and now own, especially garments etc. But some may actually keep those labels to refer to.And yes I have no idea how you are going to label a bow or hairclip.

The record keeping that goes with the batch# and the rest is for you the manufacturer to be able to keep complete records of every supply that you used in that item. Like I make a OOAK dress, I use 10 fabrics, 3 colors of thread, 2 trims, 1 style of button. When I assign that number, I have to keep track and be able to identify everyone of the products that went in to that garment. And if there is a problem anywhere down the food chain, I have to be able to identify the person who bought that dress with the purple button, that la mode recalled and contact them. That is my understanding of the nightmare of this law, over and above how to actually label the item.

[Former_Member]

Faye,

To my knowledge, you are understanding it correctly:

EVERY item made for a child MUST have a PERMANENT label so you can track it...not just track it, know which roll of thread you used, which lot of elastic, trim, and so forth! I am really praying this is ammended. I can see alot of us closing down - or making the tough choice to break the law and continue to sell.

[FayeMaloneDesigns]

And think about the what happens if they pass a value added tax, which is the lastest proposal to finance mandatory health insurance. If the economy isn't already in the dumper, think what adding a tax onto a tax onto a tax will do....

[Former_Member]

FayeMaloneDesigns,

That is exactly what I am trying to work on right now. Figuring out not only how to label each garment with all of this added info (I do currently have labels just not with batch and lot numbers. Luckily I do assign style numbers but that is as far as that goes.) but how to keep track of who bought what with what on it. It is a nightmare!

[Former_Member]

My hero, Mr. Woldenberg, has a blog post about labelling from the other day (he has a few, but this is the most recent). In it is a link to an op-ed he wrote that was published in the "Journal of Commerce."

http://www.learningresources.com/category/id/104652.do

[Former_Member]

marking

[Former_Member]

what a friggin mess.

please go sign the petition...and spread the word as best you can...

http://www.ipetitions.com/petition/rethinkthecpsia/

although i don't know if it will do any good

[FayeMaloneDesigns]

littlelotti...Are those your girls? They are adorable!!!

Rick needs a purple heart!! He is a true American! He deserves all the prayers and support we can give him.

[AuntCindysAttic]

GAH! Didn't even think of the materials tracking aspect of this. Medical manufacturers have to do this (pharmaceuticals, medical devices, etc...). This is frikkin' ridiculous! I get it for FDA items, but NOT toys!!!

[lowe40]

marking!

[AveryLane]

marking

[Former_Member]

Marking!