CPSIA and tracking label requirements

With all the drama over testing, one thing we haven’t discussed is labeling. There’s a new labeling standard required for all product manufactured on or after August 14, 2009. The sources I’ve used for this entry are:

I’ll include the specific section of law at close.

The FAQ seems pretty straightforward. As of 8/14/2009, you need a permanent label (not a sticky or hang tag) on the product and its packaging (if applicable). I realize this is an expense and a hassle but we’re luckier than other industries. What if we were making wooden blocks? How and where could you place this information? At least we’re set up to handle labeling requirements.

Manufacturers must label so they can determine:

  1. Location of manufacture.
  2. Date of production
  3. Cohort information (none if applicable)
  4. Batch or lot number, however you track a production run.

Consumers should be able to determine:

  1. The manufacturer as we define it (legal definition)
  2. Location of manufacture
  3. Date of production
  4. Cohort information (none if applicable)
  5. Batch or lot number, however you track a production run.

The sticking point with manufacturers (meaning the legal definition) is listing the contractor. A related protest from manufacturers was being required to list the contractor on the General Conformity Certificate (GCC) but the Consumer Protection Safety Commission backed down on that pretty quickly. You do have to have some kind of organized internal reference numbering or abbreviation system to track contractors but you don’t have to list them by name on the GCC. I imagine but cannot confirm that it won’t be a big battle to get the same allowance made for the labeling requirement. In other words, while it’s not official, I’m going to spend my time worrying about other things.

There’s two key problems for small producers.
1. Ordering labels -we have minimums.
2. Creating a control system for batch or lot numbers.

I think #2 is the easiest to tackle. If you’re using style numbers properly (review pgs 58-61 in the book), just add another set of digits separated with a hyphen. The problem is one of replication though because your UPC code will be different as those include color codes and your batch could include several color ways and may not be a batch according to the CPSC definition (below). Replication is annoying but it’s no big deal. If you’re using a software program like Style File to manage your production, this capability is already built in. Additionally you can track by cut or fabric lots.

Rather than amending the style number with another set of digits, your other option is to create a separate database to track batches and assign unique numbers to each. You’d need fields for style number and all that rot that comprises the SKU. One boon to everyone who works with you, is we’ll get you out of the habit of naming your styles once and for all. Yeah! Like I said, one positive thing about the law is that it will force the smallest of producers to adopt better management practices that are used in the garment industry.

There is one problem with #4 Batch numbers because we really don’t know what a “batch” is. I mean, we know what we mean it to mean but we can’t assume the CPSC shares our definition. This is something that will have to be clarified so I’ll remember to ask about this. For us, a batch means one production run, typically everything cut from a given marker of one style. A production run usually includes several colorways all cut at the same time. In other words, it is typical that the fabrics in the cut will not be exactly the same testing-wise. For all we know, the CPSC thinks one batch means items are identical to each other, as though we were making a bunch of Legos or something. Each color of Lego would be a batch but we don’t work like this. This could mean that to them, one of our batches is actually three according to their definition.

Does it go without saying that all of this batching stuff flies in the face of lean manufacturing? If you’re as lean as an operation like Fit Couture, all your batches are comprised of one unit. This poses a real problem for people making the lean transition.

Since we have to track batches or lots and we run really small quantities, this just isn’t possible to do the way we have been. Who can afford to order separate labels for each batch? Even if we could, there would be a lot of waste considering the order minimums of labels. I think there’s two options. One is to order labels as we have been (putting the required text on the back of the care label) and add the batch # manually with an indelible ink pen. I don’t think this is a practical solution for anyone but the tiniest of producers. It’ll look tacky and we like things to look neat and professional don’t we?

Perhaps another other option is to print your own from a desktop laser printer. When I went to SPESA, I found a supplier for this kind of thing, Label It. He’s not the only one of course but I did compare prices on consumables and different printing solutions that seemed pretty reasonable. You can get a dedicated printer for it (most commonly used for bar coding) with a special kind of laundry ink that won’t wash out. He also sells software ($200) to set up the labels but I’d imagine anyone halfway handy with a word processing program could figure that out. The sheet fed consumables are perforated so you can tear them apart. I’m not wild on the consumables, it’s that stiff interfacing looking stuff. I didn’t see these products specifically listed on his site but I know he has them and I got a little catalog and price list when I was there. The price list is here (xls).

One last obvious requirement is you can’t advertise that your product meets CPSC standards unless it really does. Odd that they have to mention that.

Here’s the section of the law pertaining to this section:

(a) IN GENERAL.—Section 14(a) (15 U.S.C. 2063(a)), as amended by section 102 of this Act, is further amended by adding at the end the following:
(5) Effective 1 year after the date of enactment of the Consumer Product Safety Improvement Act of 2008, the manufacturer of a children’s product shall place permanent, distinguishing marks on the product and its packaging, to the extent practicable, that will enable—
(A) the manufacturer to ascertain the location and date of production of the product, cohort information (including the batch, run number, or other identifying characteristic), and any other information determined by the manufacturer to facilitate ascertaining the specific source of the product by reference to those marks; and
(B) the ultimate purchaser to ascertain the manufacturer or private labeler, location and date of production of the product, and cohort information (including the batch, run number, or other identifying characteristic).’’.

(b) LABEL INFORMATION.—Section 14(c) (15 U.S.C. 2063(c)) is amended by redesignating paragraphs (2) and (3) as paragraphs (3) and (4) and by inserting after paragraph (1) the following:
(2) The cohort information (including the batch, run number, or other identifying characteristic) of the product.’’.

Section 14 (15 U.S.C. 2063) is further amended by adding at the end the following:
(d) REQUIREMENT FOR ADVERTISEMENTS.—No advertisement for a consumer product or label or packaging of such product may contain a reference to a consumer product safety rule or a voluntary consumer product safety standard unless such product conforms with the applicable safety requirements of such rule or standard.

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