This isn’t about the batching we’ve been talking about, this is an entry I needed to put up a long time ago for people making children’s products who need to comply with CPSIA. Several people contacted me saying they needed to order labels so I had to get back to it.
If you don’t know what I’m talking about, you need to read CPSIA and tracking label requirements. As of August 14, 2009, all children’s products are required to have a new label. For review, the purpose of the label is so consumers can determine:
- The manufacturer as we define it (legally, in other words, you)
- Location of manufacture
- Date of production
- Cohort information (a contractor -none if applicable)
- Batch or lot number (a number you assign)
The big sticking point is what is a batch? Normally, a cut order is a batch but this does not qualify under CPSIA. Under CPSIA, a batch is one lot that uses identical items which themselves have identical lot numbers. For example, if you’re using the same thread, the same fabric and the same buttons or zippers the individual items of which come from their own complete batch as listed on the box they came in, then that is a batch. Each batch needs a unique identifying number.
However, if in the course of making the products, you have to break into a separate box of buttons that has a separate batch or lot number itself, even if the product is otherwise identical, this is a separate batch and you need a separate new label for it with its own batch number that you assign.
If you make individual items of products you buy at retail, perhaps using the exact same fabric in each but you vary the trims or closures, then each product is a separate batch. It is conceivable every item you produce is its own batch and each needs its own number and label. Yes, I realize this is unwieldy, costly overkill and in many cases nigh impossible (production date for one, how can you order a label in advance if you’re not sure what date you will finish the lot?) but don’t shoot the messenger.
You will need to do “batch control”. You need to create a separate BOM for each batch. You can keep this electronically in a database or spreadsheet. It is my understanding you need to keep these records for three years.
Here’s a sample of what your label should have:
- Mfg by: RN 110706 OR Mfg by <your name>, RN 119786
- Made in USA
- August 14, 2009* (date the lot is completed)
- Cohort info (a contractor number if applicable)
- Batch number
What is a cutter’s must?
What is a sketch sheet
What is a Bill of Materials (BOM)
What is a cutting ticket
What is a tech pack?
How to move up to another level
CPSIA and tracking label requirements
CPSIA: Printable labels for August requirements
CPSIA: Tracking labels update