CPSIA: Printable labels for August requirements

Yes, everyone has a testing reprieve through February 2010 but all children’s products makers are required to comply with the August labeling requirement even for batches of one item. You must have a sew in label listing specific information on your product by August 14, 2009.

I’m continuing to wade through material for a set of articles on how to comply with the CPSIA labeling requirements that should have been done by now. Part of the hold up is sourcing labels that people can print themselves for the tracking by batch component. Some vendors are really expensive, charging over $4 a sheet (25 sheet minimum). Eeek! I found one vendor who sells for considerably less but they have a one case minimum. One case has about 50,000 1″ x 2.2″ labels. The nice thing is these are perforated.

Unfortunately, it seems the only way I can make this work for the smallest of producers is if I buy the labels and sell it by the sheet. But I’d have to charge $1-$1.50 a sheet (@40 labels) with a ten sheet minimum otherwise it’s too much hassle (it’s still a hassle even with a ten sheet minimum). There’s four different kinds of labels. I’m thinking most people would want the softest labels for kid’s clothing and those labels are costlier. The inexpensive kind are those pellon type labels most often used for care and wash instructions. The latter could be used on utility items that won’t actually be touching the child (bibs, plush toys, slings etc). The problem for the smallest producers using the perforated labels is setting up the label fields and in any event, you can’t feed a partially used sheet into a printer without some waste. It may be that they will need to print even quantities of labels and use an indelible marking pen to hand write in the batch number (in the case of single units).

I’ve also been working on DIY labeling solutions with off the shelf components but wash testing results are not consistent; the label is useless if a consumer can’t read it after the item is washed. There’s a fixative compound one can buy to apply to the fabric for ink jet printers (that I haven’t tried) but that’s over $7 a bottle and requires total immersion and who knows how far it goes or even what chemicals are in it. Worse, if done on fabric, all outside edges must be finished or the label will fray off. That’s why I’m looking at a traditional garment industry supplier for these consumables. By the way, the garmento labels are designed for laser printers. I have samples coming which I could test on the ink jet I have at home but who knows what the status of that will be.

The last hassle of it all is having to flog it so I don’t get stuck with a bunch of blank labels I’ll never use. It’s not as though I’m set up to sell a myriad of components where it’s up front in people’s minds. Or should I just let it go and let people worry about their own solution?


  1. Dawn B says:

    Boy, there is so much to think about with manufacturing…I had conveniently forgotten all about this. Thanks for keeping us honest! My labels have the manufacturer and location on them (if USA is enough of a location – I wonder how specific that is supposed to be?). So I would only need to add date and batch number. Ideally I would put that on a small tag tucked under the main (soft printed satin) tag, so it could be the pellon type.Report

  2. Esther says:

    I have some of the pellon, perforated type labels and they do pretty well in my inkjet. The problem is that inks vary by manufacturer and some are water soluble. Manufacturers definitely need to wash test them before committing. I think the ideal solution is to print up a label where each batch/lot number can be hand written. How else can it be done when using lean manufacturing?Report

  3. kathleen says:

    I’m hoping we can figure out some kind of pellon to use, like you buy at the store and cut to fit. It’s kind of a hassle but it’s a low cost option for onesies-twosies. I really wish people would experiment with the process now rather than later. What I suspect will happen is that people will figure out later what a hassle it is and then want labels but I won’t have any. I’d rather not have to buy any and deal with it at all.Report

  4. Alice says:

    Once upon a time I bought this pearl-coated stuff that you can print on with a dot matrix printer or a laser jet. I just cut it down to letter-size so that it would fit in the printer. It was great for doing small batches of care labels. Not the softest stuff, but mine is slightly pink and pearlescent and prettier than the regular white pellon-like labels. It seems to hold up pretty well with washing. I got it from KG Industries in Queens, NY. . . . .Report

  5. Esther says:

    Just wanted to say you can run pellon through laser printers. It was used at one company I worked at. The pellon had a smooth surface and fed through fairly well. Pellon doesn’t go through ink jets because the fibers clog the heads.Report

  6. Natalie says:

    What about existing inventory? Does that have to be labeled like this as well or can I just start with my production today and be okay by August?Report

  7. Kathleen says:

    Re: existing inventory.
    Everything I’ve read or heard leads me to believe that labeling is required on all products sold as of August 14th. In any event, taking the most conservative approach is the most prudent. It’s safest to presume there is no retroactivity on inventory for any reason two reasons. One, it’s in the law. Two, the one time the CPSC extended retroactivity on inventory, they were sued and over ruled. Lastly, as so many have discovered to their detriment, as a practical reality it doesn’t “matter” what the law says, it only matters what buyers *think* the law says. Iow, retail compliance programs are much stricter. They’ll return your product if it doesn’t fit their guidelines.Report

  8. colleen says:

    Kathleen, the CPSIA should hire you to work out a reasonable solution to their requirements!

    Is it possible to divide the required label info. so that some is heat set and some is on the printed label?

    Is it feasible to have the manufacturer use an iron-on transfer with some or all info. directly onto the item? I have seen Old Navy and J.C. Penney do this on children’s clothing and Merona on Men’s t-shirts. The child’s shirt has country of origin and size heat set inside the back of the t-shirt. A separate printed, satin label indicating fiber content, RN# and care instruction is sewn into the wearer’s left side seam, 4″ up from the bottom.
    The Men’s t-shirt has size, fiber content, care instruction, country of origin and RN # all heat set at the back neck. There are no additional woven labels.
    There don’t appear to be batch numbers on either. I’m guessing that this is a new requirement for Children’s wear and compliance is expected for August ’09.Report

  9. Jennifer says:

    A lot of the big companies already do this. I have noticed at Target, Gap, RL they have a tag sewn in the side seam. It is the scratchy kind that most parents will probably cut out anyway. Also have seen some smaller brands doing it by applying a sticker to the back of a sewn in label. I am not saying this is right or wrong just sharing what I have seen. I think if people can put a process in place and do the best they, that is a good start.Report

  10. Diane S. says:

    I used to do work for someone that would stick fabric on to paper with a spray can (I’m not sure of the name of the stuff she used) run it through the printer (I’m pretty sure it was ink jet) and peel it off and cut it out. I turned it under a quarter and stitched it all around.

    By folding it twice you could get rid of two raw edges, one would be in the seam, so just one to deal with by….Report

  11. Wacky Hermit says:

    You can stick the fabric to butcher paper with an iron to run through an inkjet printer. Dharma Trading sells special butcher paper already cut into sheets, but I bet it’s available elsewhere too, and you can use regular butcher paper which is probably much cheaper but takes more time.

    Maybe this is where all the jobs they think they’re going to create are going to be: in ironing freezer paper for mom-and-pop’s production labels!Report

  12. Amanda says:

    When I recently converted to labeling by batch, I started using t-shirt transfer paper to print my labels-which is available at office supply houses. They are not pre-divided, so I made the labels as small as possible to economize on the paper (which is relatively economical if you buy it in bulk). Obviously, this will only work for fabrics that can stand up to heat transfer (my things are cotton).

    I just print off the necessary labels for each batch from my ink-jet printer, and my contractor applies them to the garments by heat transfer. Not an ideal solution, but it has worked so far…Report

  13. Kathleen says:

    I just print off the necessary labels for each batch from my ink-jet printer, and my contractor applies them to the garments by heat transfer.

    This was another thing I’d considered but then I wondered how to go about getting the tracking labels to print in as a mirror image. Do you do that through settings in Word or are you using another program? All I can find in Word is to make the text block into “text art” and then to flip it. Unfortunately, you can’t do this in an expedited way as you ideally would use data from a database, setting up labels in the same way you’d do it for doing a mailing. Or maybe the nature of the beast is that it’s a multi part process? Good grief, that’s a lot of work. Anyway, I’d like to hear more about how you’re doing this because I’m sure it’ll come up again.Report

  14. Dawn B says:

    Okay, here’s an idea, may be wacky…what about a stamp, the old type librarians would use where you can rotate the numbers to create a date or series of numbers. Could be stamped on the back of the tag using permanent stamp pad ink.Report

  15. Clara Rico says:

    If you want to print out a transfer, check your printer settings. Mine lets you select “T-shirt Transfer” and automatically flips it. When it shows the preview it shows is normal, but will print the mirror image.Report

  16. Yolanda says:

    Okay forgive me but this is all so overwhelming for me. I currently print my labels on fabric paper and I include made in USA and I also create labels containing the fabric content. Could someone please explain the batch number and let me know what else I would need to include on a label. ThanksReport

  17. Amanda says:

    Actually, I made the whole thing easy on myself by using the “dark t-shirt” transfer paper, which prints the “right” way on to a white ground. You then peel the backing off and iron it face-up onto the garment.

    I think it is somewhat less lovely than the transparent ground would be, but it solves two problems at once–in that many of my products are made from dark-colored fabrics, and so the other kind of transfer wouldn’t work, unless by some miracle your household printer had opaque inks…

    Anyway, with some attention to formatting detail, I think I was able to get it small enough and neat enough that it looks about as nice as your average white-background care label is likely to look anyway. Once I got it going, it’s actually a pretty easy system.

    Oh, and I checked my printer, and it does have a “print mirror image” setting, if you were to go that route…Report

  18. Kathleen says:

    Could someone please explain the batch number and let me know what else I would need to include on a label.

    The link in the opening paragraph of this entry goes to an entry that explains the basics of the labeling requirement and that section of the law but I’ll include the link again. As I mentioned in the second paragraph, I intend to follow up next week with specific information. It’d be great if people would monitor the site and pose questions in the event I don’t cover all topics fully.

    If you wanted to start working on it now, a batch number is what we would call a “cut number” or a “lot number” -with refinements, courtesy of cpsia. Traditionally our cuts may be comprised of several colorways and so, share the same cut number (the same marker). All of this is in my book, but people will need to begin to itemize their inputs in a controlled manner if they are not already using the sketch form or something akin to it. Anyway, it will not be possible to use the cut number to indicate batch; I advise people to use the cut number and hyphenate to indicate colorway.Report

  19. Sandra B says:

    Textile artists have been going crazy with inkjet printers for a while now. There are a few products you can use to enable inkjet inks to permanently bond with almost any substrate thin enough to go through a printer. I have seen lace printed this way, and heard of sheets of lead. This link is to an Australian site, but I’m sure the products are available everywhere. http://www.essentialtextileart.com/inkjetfabric_index.html
    Youtube has some information: http://www.youtube.com/watch?v=UEBozgQAxCE I have used the inkjet Printing sheets shown in the video, and they worked well.
    Apparently the important thing is to ensure the ink is pigment based, not dye based.

    Dye sublimation is another option. I’m not sure how it works with printers, because I’ve only used it directly with either paints or crayons. http://www.wide-format-printers.org has a huge amount of information. I downloaded a PDF, Direct Digital Printing on Fabrics, that discusses the different inks and sources. They talk about using actual fabric dyes rather than standard inkjet inks.

    Another option could be Spoonflower. They do print-on-demand, and are very popular with crafters who want original fabrics. http://www.spoonflower.com I can see that they could be useful for small numbers of labels, particuarly for one-offs, you could assemble them as a jpeg and print the lot to be cut apart later. Fussy, and not as fast as printing in-house, but another option.Report

  20. Mich says:

    I have been debating about this for months now and have pretty much resigned myself to having custom designed labels for each type of product that lists content and has production info, with a place for me to write batch numbers. This means about 9 different labels for my products alone.
    My biggest issue now is that once I add these labels to each product, doesn’t that change the composition of the product and require a new test that includes the label, since component testing is still not allowed?

    ie: if I make a diaper with 2 standard fabrics, standard snaps, elastic, thread, my business label… and then add the CPSIA required label, haven’t I changed the product again and doesn’t each one require a new test now?Report

  21. Dana says:

    “Okay, here’s an idea, may be wacky…what about a stamp, the old type librarians would use where you can rotate the numbers to create a date or series of numbers. Could be stamped on the back of the tag using permanent stamp pad ink.”

    I had one of these band stamps made and use them to label the muslin bags I use with style number/size. You can get them made with different fonts, sizes of fonts, letters, numbers, etc. Don’t know why it wouldn’t work for batch numbers, etc.Report

  22. Mich says:

    The stamp idea would work if you can reasonably expect the ink to remain legible through reasonable wear and laundering for the expected life of the product. Again, though, once you add those labels ( and now with the ink from the stamp), haven’t you altered the original product and need new tests?
    I mean, my current tests would be totally useless once I decide on a labelling system and start adding them to my products. If anyone has spent money on testing their products already, implementing a labelling system makes those tests nothing but wasted money, right?Report

  23. Peter says:

    I think you have to have the labels and ink/toner tested for lead and phthalates. And you have to do it on a unit basis, not from the label materials. You need 5 grams of label for each test, which needs to be done three times, so for the average garment you should ship off 1,750 pieces per color/model variation to the testing lab.

    (I’m only half joking here.)Report

  24. bente says:

    Mich and Peter;
    should I laugh or should I cry???
    Use the same stamp in an imaginary label in the garment you test for lead and phthalates.
    Write a poem or something on it!
    Then use the same stamp system and the same ink for the real info!
    Fully Joking or just don’t have a clue what to do?Report

  25. Kathleen B. says:

    My printer has “T-shirt transfer” as a printing option (where you choose photo paper, plain paper, etc.) which automatically does a mirror image when printing. It doesn’t flip it on my screen, though, so I didn’t know it would really flip the image until I went through all the trouble of doing the crazy Word Text thing to reverse it–so then it printed backwards because the printer reversed my reverse image.

    I tried some Bubble Jet Set 2000 on muslin, then ironed it to freezer paper and ran it through my ink jet printer. The instructions say to hand wash or machine wash in cold on a delicate cycle using mild detergent, but I stuck the skirts (my daughter’s) with labels in the washing machine on warm and used regular detergent. The labels didn’t bleed at all. They have been washed multiple times now and seem just fine. It still doesn’t solve the frayed edge issue, though. Oh, and the Bubble Jet Set 2000 seems to go really far. You can soak a lot of fabric in each batch.Report

  26. Marlene S. says:

    I found some printable labels at Rogeneration. They also go by Rogen Studio. You can get on their website and check out what they have. They were nice enough to send me some samples and I was able to try them out. They offer labels for both inkjet and laser and have different sizes available. Please note that I have an inkjet printer that uses Epson No. 68 high capacity black ink. ” Because of the ink’s instant drying, all pigment formulation, prints are smudge, fade and water resistant, whether you create single or double sided prints.”

    This was my experience:
    Remar – most inexpensive and you get what you pay for.

    Econo- Although I have an inkjet printer, I much preferred the laser labels. They were a little thicker and I am printing on both sides. I’m printing all my info on one side and adding the cpsc info on the back. (This may not work for all injet printers). They also have a pearl coated label that I liked best, but after printing on it, you could hardly read the info. and if my memory serves me, it was much more expensive.

    The labels come in sheets that are perforated and quite easy to use. There are 50,000 labels per case. Prices vary by size and quality.

    I made a sample, printed both sides, and washed and dried it and it came out fine.Report

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