The U.S. Consumer Product Safety Commission requires children’s toys to have something called a tracking label. Essentially, this is a label or sticker that has certain information on it (company name, where/when manufactured, manufacturing batch number) that allows the government and consumers identify if their children’s product is subject to a recall. One is required to have a tracking label on both the children’s product AND the packaging of the same children’s product. We had lots of questions about how this requirement would apply to our toy dog house.
One of the items we are manufacturing (in our line of children’s toys) is a printed box that children can color and decorate. The box is printed with a design (so we need to build steel printing plates for that). And, the box will be shrink-wrapped (to protect it from factory > shipping > storage > customer purchase > child).
Question: The permanent tracking label requirement applies to both toy + toy packaging. Does this double requirement apply to one of our toys that is merely packaged in transparent shrinkwrap?
>> According to Small Business Ombudsman @ CPSC, we would not need to have a permanent tracking label on both because our packaging is shrink-wrap. This is because (and according to the CPSC website here), one is exempt from placing a permanent tracking label on packaging if the permanent tracking label is visible to the customer through “disposable packaging”. This was great news for us because it saves us the time & $ & hassle of putting tracking label stickers on our finished shrink-wrapped products!
Question: Can we merge the Date of Production requirement with the Batch Number requirement (of the U.S. permanent tracking label requirement)? For example, let’s say we have Batch # 123 & we manufactured the items on 10-1-2015, instead of having these two pieces of data in two separate places on our tracking label, >> could we instead just print it as Batch # 10-1-2015-123?
>> Answer: According to our friend at the SBO @ CPSC, yes! (Cool, this saves us space, and saves us from extra ugly random text).
Question: This particular product that we are manufacturing is a colorable box (Think McDonald’s Happy Meal Box). We need to build printing plates to make our products. It is not practical to engrave the date of production or the batch # into the steel printing plates. We need to be able to use the steel printing plates over many courses of manufacturing batches. Can we put an adhesive label onto these boxes instead?
>> Answer: There seems to be some ambiguity in the language of the label requirement on the CPSC website about adhesive labels. But, in this case scenario, as long as the sticker that we are placing on the box is a strong sticker that does not easily come off, then this adhesive permanent tracking label satisfies the label requirement.