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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
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