Tracking Labels for Children’s Products

The tracking-label requirement applies to children’s products, with permanent distinguishing marks on the product and packaging to the extent practicable. CPSC identifies the domestic manufacturer or importer of record as responsible for ensuring compliance. The size of a business does not create a general exemption. Review the product’s audience and physical construction before deciding where the information can practicably be placed.

The marks allow the manufacturer, importer or private labeler, manufacturing location and date, and detailed production information such as a batch or run number to be ascertained. The purpose is to identify the specific source of an article. A retail SKU naming only the design may not distinguish factories or manufacturing runs, so it should not automatically be treated as sufficient traceability information.

A mark should remain legible and attached through the relevant product life; packaging marks must remain usable through distribution to the consumer. CPSC explains that an adhesive mark may be acceptable in some circumstances but not as a permanent tracking label on textile-type articles. Assess the substrate, attachment and expected handling rather than treat every sticker or hangtag as equivalent.

Production information can be represented through a controlled code when the required information remains ascertainable. Maintain the mapping between that code, factory, production date, lot and responsible business. Preserve changes to coding conventions and ensure that customer-service or investigation personnel can resolve an actual mark. An internal code that no one can interpret after a supplier change does not provide useful traceability.

Tracking labels are not themselves a children’s-product safety rule requiring testing by a CPSC-accepted laboratory, and CPSC does not require a tracking-label citation on the CPC. Other test, certification and product-labeling duties remain applicable. Durable infant or toddler products can have additional registration and marking requirements; a tracking code should not be assumed to replace their product-specific obligations.

When checking a shipment, compare the product mark, package mark and production records for the same lot. Investigate discrepancies before using the code to define affected goods. This information supports defect investigations and recalls but is not evidence that the product passed a mechanical or chemical test. The compliance file should distinguish traceability, safety evidence and certification rather than combine them into a single unsupported approval claim.