What is a batch?

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:

  1. The manufacturer as we define it (legally, in other words, you)
  2. Location of manufacture
  3. Date of production
  4. Cohort information (a contractor -none if applicable)
  5. 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

Related Entries:
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

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  1. I noticed that for the “place of manufacture” you’ve put “Made in USA.” It was my understanding that it was unknown which level of specificity was intended for the “place of manufacture;” with some people interpreting it anywhere from Planet Earth to requiring the name of the factory. Can you give me some background on how you came to understand “place of manufacture” to only require specificity to the country level?

  2. Kathleen says:

    Can’t help with the rumor mill, GiGO. Whatever.

    Logically tho, it doesn’t make sense that the name of the factory should go in this field because that’s cohort (#4) or manufacturer information (#1), not location.

    As far as my “credentials” are concerned, I got this from Cheryl Falvey, General Counsel of the CPSC at a meeting of the Children’s Product Safety Council in Washington DC back in Dec.

  3. I’m sorry if you took my comment as having a snarky tone questioning your credentials, Kathleen. I assure you it wasn’t intended that way and was carefully worded so that it *didn’t* question your veracity. I just wanted to know where the information came from, that’s all.

    I had read through the public comments on tracking labels and some of the larger businesses (some of whose letters were written by their attorneys) seemed to be under the impression that CPSIA would require them to disclose location information on the tracking labels down to the level of which factory they used, which naturally they were upset about. So I was referring to something a little more informed than the “rumor mill”, and I only wanted to know if your information was more reliable than theirs. I’d say Cheryl Falvey is a pretty reliable source and I’d take her opinion over those of the commenters. So thank you for letting me know.

  4. Renee says:

    Even if Cheryl Falvey is a reliable source, the real problem here is that any state’s Attorney General can seemingly choose to interpret and prosecute the law on their own, and since we all know how vaguely the law is written it certainly does keep members of my own household up nights up worrying how they will choose to do so.

    The part that leaves me scratching my head about determining batch is that we have basically been told not to worry about lead testing fabric because it won’t ever contain more than trace amounts. So why, then, would batch apply to anything other than lots of findings like my snap parts? Which, by the way, do not come labeled with a lot number and could therefore be manufactured in different places at different times.

  5. kathleen says:

    Sarah, I think we’re miscommunicating on a couple of levels. I put credentials in quotes because while my source is reputable, this still amounts to hearsay and we have no official written clarification yet. Yes, there is a matter of concern about factories but you asked me about location. Location is nation of origin. This is not a matter of concern for the people I’ve talked to. That you say others have similarly misinterpreted this and have written commentary about it, I can’t help. Violins on TV.

    The location requirement is a waste and redundant because (at least in apparel) you are already required under FTC regs to print this information on a label, in sales materials and product descriptions at the “point of sale” (eg, shopping cart on a website). However, does everyone do this? No, they don’t. So now, nation of origin is required by TWO federal agencies rather than just one.

    That is not to say there is not a great deal of controversy about listing factories. And yes, I am aware that some people are running around saying you must print your contractor’s name and address on the label but that is crazy talk. Cheryl got an earful about this; people are livid that this is so poorly defined. But you didn’t ask me about no 1 or 4, you asked about location. #4 is a whole other controversy. Congress cannot require the disclosure of one’s proprieatary competitive advantage to the marketplace.

    Falvey said that a manufacturer could issue a code for each contractor and list that on the label rather than a name or other identifying remarks. The requirement is that with the information the customer supplies from the label, you know exactly where and how this lot was produced. You are not required to supply that info to the customer, that is none of their business but you must be able to track the lot in the event of a recall. Again, I have tried to tell people this but they do not listen. I don’t care anymore. I don’t make kid’s products. I am providing a public service, I actually lose money every time I bring this subject up so I’m not going to argue about it.

    That the matter is confusing and ripe for misinterpretation by many is not in dispute. I seriously doubt it will change. We don’t have a unified consciousness or mechanism for coming to terms amongst ourselves anymore than homebased crafters do.

  6. Kate says:

    Thank you Kathleen for providing this information. I find it very helpful.
    I have a small homebased business making baby carriers. I’ve got a question about the batch #. In order to avoid the testing fiasco, I am moving to only approved fabrics, no zippers etc.. From your above article, I now realize that having a batch # for my items is going to require a lot of paperwork on my end to make that batch # trackable to the components in my item. But if I’m only using cotton fabrics, that don’t require lead testing, does it really matter. Will I need to make a spreadsheet tracking where/when each fabric was purchased and somehow translate that info into a batch #?

  7. kathleen says:

    I now realize that having a batch # for my items is going to require a lot of paperwork on my end to make that batch # trackable to the components in my item. But if I’m only using cotton fabrics, that don’t require lead testing, does it really matter. Will I need to make a spreadsheet tracking where/when each fabric was purchased and somehow translate that info into a batch #?

    Unfortunately, you still must comply with the labeling requirement even tho you have a stay on testing till Feb 2010. Yes, you’ll have to create a spreadsheet to track all of this. See the entries I linked to (sketch sheets, bom etc).

  8. sfriedberg says:

    It may amuse, or depress, you to learn that these batch tracking requirements are almost as strict as the requirements for aerospace parts. In surplus channels, one can still occasionally come across little bags or paper envelopes containing (for example) one machine screw, one washer and one locknut, with 10 or 15 lines of documentation allowing (in principle) those parts to be traced back _through_ the factory that made them, the shift (and specific machine operators and foremen) that produced them, all the way back to the foundary that smelted the steel and the specific ladle-full of molten metal used in them. The idea was that if a part failed in the field, there would be an audit trail leading back to the sources of production, which could then be followed in the opposite direction to recall or repair any other parts affected by a bad batch of production or materials. Also implicit was the ability to identify specific corporations (or even individual workers) and charge them with criminal or civil charges for negligent or irresponsible behavior.

    This is one reason the (printed) documentation for a modern airliner weighs about as much than the airliner itself. For apparel, I think this is gross overzealousness and quite futile. Unlike the aerospace industry, the apparel industry is not organized to keep the necessary records on things like (to use Kathleen’s example): when did we break open a new box of buttons and was the lot/batch number on the buttons the same as the number on the box we just finished? That information isn’t even available on most items in the supply chain! Every dye lot in principle must be logged, and calls for a new batch. When was the last time you saw the mill or converter’s dye lot number printed on a bolt or on cone of thread? Most of our inputs are currently treated as commodities, and the whole point of commodities is that the items are interchangeable and not individually tracked!

    Unfortunately, this is now a legal requirement. As citizens we have only ourselves to blame for allowing this to be imposed on us. By failing to oppose the lobbying of special interests, we ended up with some very expensive (not least, expensive when found guilty of non-compliance!) requirements that yield little, if any, actual value.

    Please keep in mind that you are not just obligated to put batch numbers of labels! You are also required to keep records documenting exactly what went into each batch (including things like the source and lot/batch number of every bolt of fabric, every button, zipper or trim, every spool of thread!). And you must retain those records for some legally specified length of time.

    In my more dire moods, I suspect there will be a far more lucrative business in suing manufacturers for failing to keep the appropriate records than there will be in making the goods to be labeled in the first place.

  9. Talia says:

    I know this is an older post and discussion, but since I am dealing with this very issue, I thought I might try for an answer. We are working through a manufacturing agent overseas and I am unsure how to handle the batch number on our labels. We are doing a single run of the same product with the same components and only a variation of print/color. Could we use the same batch number for the entire lot or do we need to track down the the trims (which in our case are snaps) and create a new batch number based on that? To be honest, I have no idea how to approach this.

    And could you please give an idea of the format of a batch number?

    Thanks for any help you can give. I’ve been reading all I can to understand the requirements and that is the one question that is truly stumping me.

  10. Kathleen says:

    Hi Talia
    It sounds like you need a timely and more targeted response. We could probably iron that out pretty quickly if you were up for a phone consultation. Check my about page for more info if you’re interested.

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