The CPSIA compliance has been met with criticism and confusion from small businesses, charities, and others who have complained about expensive testing requirements and vague and sometimes mixed guidance from the CPSC. Recently this was indicated in the blogosphere and twitter about the lack of guidelines from the CPSC about the CPSIA tracking label provision, Section 103(a) of the CPSIA.
The commission finally provided guidelines on the 21st of July. The CPSC commissioner talked to AP 5 days ago and these are the key points.
- The tracking label provision, Section 103(a) of the CPSIA, goes into effect on August 14 and affects only products manufactured on or after that date.
- The guidelines allow manufacturers to be flexible in how they comply with the provision.
- The only requirement is that the tracking information required by statute be ascertainable from the distinguishing marks made on the children’s product and its packaging. "How an individual manufacturer chooses to achieve this end is left to the reasonable judgment of each individual manufacturer." Said Tenenbaum.
- Manufactures can print the “tracking label,” which must be permanent and appear on the product and packaging, anywhere on the product and in any form, as long as it contains the specific source of the product, including the country, city and state where the product was manufacturered, the date of production, and cohort information such as the batch or run number. The information can be printed in full on the product, or a code can be used to allow consumers to find the information online.
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