CPSIA Tracking Label Policy Clarified

    U.S. Consumer Product Safety Commission (CPSC) recently published its new interpretation and enforcement policy statement regarding Section 103(a), Tracking Labels, of the Consumer Product Safety Improvement Act (CPSIA), stating that its purpose is "not to impose siginificant additional burdens on manufacturers.

    The provisions apply to children’s products and their packaging, which, as defined in the CPSIA, applies to “a consumer product designed or intended primarily for children 12 years of age or younger.”

    Providing an explanation of the purpose of the requirements, the policy statement cites a House Committee decision that the tracking label provisions would aid in identifying the location, date of production, and other information (such as batch or run number) that could help readily isolate products when a safety concern is identified. The CPSC has identified that the purpose of the Section is “not to impose significant additional burdens on manufacturers who already make available the required information for their products, but to bring those who do not up to a higher standard.”  Nor does the statutory provision require a uniform one-size-fits-all system.

    The CPSC has clarified that the August 14, 2009, effective date for the Section 103(a) provision does not apply retroactively to such products made before that date.  Further, the Commission will not seek penalties from manufacturers and/or importers who have given good faith efforts to educate themselves on the requirements and to act appropriately, even if information was inadvertently omitted. 

    The document continues with nine (9) questions and answers to help clarify issues pertaining to the format and content of the “Tracking Label.” For more information view the CPSC's interpretation and enforcement policy statement.