Can we talk about the labeling requirements?

[Vesta]

Yep, I did. They were very clear, and sent me a list of items for which they wouldn't give RNs. I can't remember all of them now, but seems like a lot of accessories were on the list.

[Melissa McKeagney]

Thanks for the info Miracle, I am guilty as charged. I will get these ordered tomorrow, and try to figure out how to deal with the new labeling requirements at the same time.

Stupid question alert: what is an RN#?

Melissa

[J C Sprowls]

[Vesta]

J, I never thought of that. I'll try it and see how they react.

[annika]

If baby slings aren't considered within the realm of the act that governs RN numbers, what is the advantage of having and using one? Seriously curious.

[J C Sprowls]

Traceability. And, now that the CPSIA requires that *all* companies identify themself, getting an RN number just moved from "a darn good idea" to "meets/solves the identification requirement".

[Esther]

The term "voluntary" in the eyes of the government is no different than a "law". An example is the drawstring guideline. Technically a voluntary guideline but interpreted as a law (Nordstrom just got slapped with fines for failing to notify the CPSC about problem drawstrings in a timely manner, even though it is strictly voluntary). Anyway, the RN thing is just another example.

[Kathleen F.]

I've always said to lie or do what you had to, to get an RN #. I don't know why they don't like passing them out.

Unofficial response to my question of "what is a batch?" is don't ask and shut up. It wasn't said rudely. Just not to bring up the minutia of it, why give the consumer product safety commission more to deal with if we can track things internally with one batch or lot number for three colorways in a cut?

[Esther]

Well, we can disregard the batch problem now, but it will come up at some point when some bureaucrat gets bored or the next CPSC head honcho wants to appear to have accomplished something. How else did OSHA come up with 4,000 mostly ineffectual regulations?

[J C Sprowls]

[Shannon Foster]

This may be a dumb question. I rave a RN# from when I trademarked my name with the USPTO. Is that "the" registration number I need to begin including with my labels?

[J C Sprowls]

USPTO does not issue RN Numbers. Those come from the FTC. Follow the link, above and search the database by the RN number you have. If it returns a record registered to your company, then, this is the number you need to display on you CCO labels.

[Shannon Foster]

Thanks JC. I do have a serial # from the USPTO and then they issued a RN# after the process was complete but you are right, it is not coming up in the database.

[Tina HD]

I am just befuddled at how I am supposed to possibly batch my items.

For example--last week I made 13 diapers. Not one of them was the same--I may have had 3 with the same materials, but 1 was small, 1 medium, 1 large. Did I have 13 batches? Was that a "production run"? It took 4 days to do it, some were done on Tues, some Wed, some Thusday. What's my production date?

Next month, if I make another batch and some of those are in the same fabric/size combos as these I made, will they need to be labeled differently?

I simply cannot see how these labeling laws can work for someone as small-time as me. I'm glad I have till Aug to figure it out.

Tina

[Kathleen F.]

Tina, these questions aren't so unusual, large companies have the same issues. Typically, the date of completion of the entire batch is the date of manufacture. All the law is requiring you to do is to create better management systems for your work process.

This is the question they want answered:
If a product of yours is recalled, do you have the means to find every other unit that would be subject to the recall? Can you identify every affected unit through your internal processes? If not, you'll have to create a method to do it. More paperwork!