Tracking Label Requirement Still Vexes Suppliers and Distributors
Like it or not, CPSIA has thrust many new responsibilities upon companies in our industry who produce children's products. The more that distributors and suppliers integrate these new responsibilities into the culture and daily practices of their companies, the better job they will do in complying with the law and the less they will risk an expensive and embarrassing fiasco. And beyond pure compliance, conscientious and high quality business practices like these have a major impact on maintaining the confidence of major corporations in our industry, something that none of us can afford to take for granted.
Key Points and Suggested Best Practices to Consider
- Flag in your computer system the children's product orders you produce. If any non-compliant product or decorating materials slips into your supply chain or factory, being able to identify the children's products orders you produced will help you limit the scope of any potential recall.
- When you produce or decorate a children's product order, include a permanent tracking label on the product that complies with CPSIA. Store the tracking numbers in your computer with a link to the order you're producing.
- If you include a tracking label on blank but CPSIA-compliant product when it is manufactured be sure to record those tracking numbers in your computer system with a link to the particular order you're producing. One way is to develop a system for your warehouse team to scan the tracking labels when they pick product for each order. The better your documentation the easier time you will have if there is a recall. And when you use that blank stock for a children's order, print a date code in a discrete location on the product to help you later limit the scope of decoration-related recalls.
- If you purchase a children's product from another importer or manufacturer and it bears their tracking label, and then you decorate the product, you will need to print a second tracking label on the product that applies to your decoration.
- Consider keeping a sample of each completed children's product order to help you test and narrow the scope of any future recall.
- Develop a system to test and document the lots of ink and other materials you use for decorating. Consider keeping samples of each lot. If there's a problem later the documentation will help you narrow the scope of a recall.
- If you purchase a blank children's product and contract to have it decorated be sure your decorator has current third party tests to prove CPSIA compliance of all the inks and other materials used in the decoration. Then instruct the printer to print tracking information including your company name, production date, production location and batch information. The label must enable end buyers and/or recipient of the promotional product to track back to you. Store the tracking numbers and all testing documentation in your file for each children's product order you produce.