Tagging Requirements for Consumer Product Safety Improvement Act and Home-Produced Goods
The US Product Safety Commission is responsible for the Consumer Product Safety Improvement Act which was amended in 2008 and came into force in 2009. A new section, S.103 covers product labeling of consumer products, making it mandatory for products to carry a tracking tag no matter whether they are imported or made in America and no matter who makes them. Hand-crafted products do not escape the new legislation so, we’ll take a look at the new law and how it affects you.
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Overview of s.103
s.103 mandates that all products, irrespective of origination, must carry a tracking tag to sufficiently identify where they were made and carry basic information to include:
- source of the product;
- manufacture date; and
- information on the manufacturing process, such as batch identification or in the case of a hand-crafted business, the worker id.
There is a key phrase which has been appended to all these requirements and serves to ameliorate the impact of the new law – manufacturers are only required to add tracking labels, “…to the extent practicable.” For instance, if you are making miniature figurines an inch or two high, you may not be able to add a tracking label and all the information required, especially if they are not shipped with individual packaging and are part of a batch of product, for instance candy or home-made chocolate.
Tracking labels cannot refer to safety information or standards, unless your product actually complies with that safety standard.
The new law came into force on August 14, 2009 though the safety standard provisions came into effect from October 13, 2008.
How the Law Impacts Home-based Businesses
Congress received a lot of representations from small and home-based businesses on how the new law would impact them and their businesses. It is apparent that s.103 brings many small and home-based businesses under the aegis of labeling legislation for the first time, so what do you need to consider to get yourself into line with the new law?
Look at Your Existing Tracking System
Part of the attraction behind buying hand-crafted goods is that they are individual, if not unique. Adding tracking labels detracts from this (even though they can be removed). You may already be doing enough to satisfy s103 of the new law, so your first step is review your existing tracking system.
The law requires that your tracking tag should identify you as the manufacturer sufficiently so a consumer is able to find and contact you with any requests for more detailed product information or any information proscribed by the new law.
Product Specific Information
Ask yourself, if a customer came back to you with a piece you sold them a couple of years ago, would you be able to advise that customer on the materials you used to make that piece? The new law imposes an obligation to be able to advise customers on safety issues and characteristics of the materials used in construction. An effective way of doing this is to maintain good records and receipts which allows you to be able to identify when you used certain materials in your business.
Marking Your Packaging
If your products are sold through retailers, can someone see from the packaging information which would be sufficient to identify them as products subject to a safety recall notice? If the packaging does not include this information, does your product carry it where it is visible through the packaging material?
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