CPSIA section 103

Statement of Policy: Interpretation and Enforcement Of Section 103(a) of the Consumer Product Safety

Improvement Act

（

CPSIA section 103

）

B. Section 103(a), Generally

1. Purpose

The purpose of Section 103(a) is to establish a means for identifying the source of

children’s products

.

3. The Effective Date

Section 103(a) applies to children’s products made on or after August 14, 2009.

C. Format and Content of the “Tracking Label”

1. What is a “tracking label”?

While the title of Section 103 references “tracking labels,” the focus of the statutory text

is “distinguishing

marks.”

2. What marks are required and what does it mean for information to be ascertainable?

Section

103(a)

mandates

distinguishing

marks

such

that

(1)

the

location

of

production

(2)the

date

of

production and (3) cohort information for that product is ascertainable.

3. What is a “permanent” mark?

The Commission considers a “permanent” mark on a product to be a mark that can

reasonably be expected to

remain on the product during the useful life of the product

4.

When can only the packaging be marked and not the product?

(1)

If a product is too small to be marked.

(2)

If a toy is meant to be stored in a box or other packaging, such as games with boards and small game pieces.

(3)

If a product is sold through a bulk vending machine.

(4)

If a physical mark would weaken or damage the product or impair its utility.

(5)

If a product surface would be impossible to mark permanently such as those made of elastics, beads, small

pieces of fabric (such as jewelry, hair ornaments, etc.), or craft items like pipe stems, or natural rocks.

(6)

If the aesthetics of the product would be ruined by a mark and a mark cannot be placed in an accessible but

inconspicuous location.

Manley Tracking label formal:

4.1.1. Tracking label found on the product itself

TOY QUEST OR MANLEY

(For Manufacturer)

MADE IN CHINA

(For Country of Origin)

14509R

14509 are month and year. 14509 the meaning of 145 is the date in a year, 09 is

the year 2009.“R” means that

Manley Toys Vendor code and city.

Dollar Tree TRACKING LABEL:

On Packaging On Product

Greenbrier International, Inc.

Chesapeake, V

A 23320

123456-56789-001-0910A

(SKU#-Vendor#-Factory#-Production Date- Batch code (if

applicable))

If a product is too small to be marked; products that have an appropriate labeling surface area with dimensions less than

2.54 cm x 2.54 cm (1 in. x 1 in.) or 5.08 cm x 1.905 cm (2 in. x 0.75 in.) are considered as too small.

Target client's Tracking label

Target068031234F11344441-Q2/09 or

Target Target