Tracking Label Requirement Still Vexes Suppliers and Distributors
So how do you get it right with tracking labels? Let's start by looking at the most straightforward case. This first example applies primarily to suppliers but also to distributors who import directly: You contract with one of your overseas factories to produce a fully decorated, CPSIA-compliant children's product, including a detailed tracking label with all of the required information. As the order is being produced, your on-site inspector at the factory sends representative samples from the production run to a CPSC-certified laboratory to test for CPSIA compliance. Then, once you verify compliance, you ship the products to your customer.
So why is this example the most straightforward case? The example product is a children's product from day one so there's no ambiguity there. The product is produced and decorated by the same manufacturer and then tested as a finished product. There's only one company responsible - the importer who contracted for the product - and you have a third party test that applies specifically to the order. Very clear, very clean.
Next let's consider a more typical case. You're a supplier who imports hundreds of products and stocks them in your warehouse. You carry an undecorated string backpack that you've had tested annually as compliant with CPSIA children's product standards. Each time you produce a new batch you include a tracking label inside each bag that ties back to its production run. You stock thousands of these bags and decorate them in your U.S. factory as you receive orders from distributors. These bags are in dozens of distributor co-op programs, including a large federal program with a child-oriented cartoon imprint that promotes healthy eating habits for first graders. Since you already have a tracking label in the blank bag do you need a second tracking label each time you decorate an order for that federal program? No. Your company imported the bag so the tracking label you attached overseas when the bag was manufactured still applies. When working with pre-applied tracking labels like this you should consider adding a date code in a discrete location on the bags each time you decorate a new order. It's also a good idea to flag in your computer system the orders that are specifically for children. Both practices could save you money if the product is later involved in a recall. It could help you narrow down the problem and identify the specific products to be recalled.