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Tracking Label Business Guidance

Amended by section 103 the Consumer Product Safety Improvement Act of 2008, section 15(a)(5)(A) of the Consumer Product Safety Act, 15 U.S.C. § 2063(a)(5)(A), requires all children’s products to bear distinguishing marks (generally referred to as “tracking labels”) that:

  • Are visible and legible
  • Are permanently affixed to the product and its packaging, to the extent practicable
  • Provide certain identifying information

The tracking label requirement mandates that the following items of information be ascertainable from the permanent, distinguishing marks on the children’s product and its packaging (to the extent practicable):

  • Manufacturer/importer or private labeler name
  • Location and date of production
  • Detailed information on the manufacturing process (e.g., batch or run number) or other identifying characteristics
  • Any other information to facilitate ascertaining the specific source of the product (e.g., address of the manufacturing plant)

The information may be in code form as long as the consumer knows who to contact in order to interpret the code and ascertain the required information.

Compliance with the tracking label requirement improves the effectiveness and response rates for product recalls. It also helps CPSC staff and companies in the chain of commerce. When a component has been identified as the source of a hazard or violation, the tracking label may assist with identifying other products that may contain the same component.

Please note: Durable infant or toddler products need to meet additional product and package labeling requirements beyond the tracking label requirements discussed on this guidance page.

Certification

The tracking label requirement is not considered a safety rule that requires certification under section 14(a)(1) of the Consumer Product Safety Act, 15 U.S.C. § 2063(a)(1). Children’s products still require a Children’s Product Certificate (CPC) if there are other safety rules that apply; however, the CPC does not need to include a reference to tracking labels.

For more information on CPCs, visit our CPC business guidance page.

Additional Information

Contact

For more information, please contact the Small Business Ombudsman (SBO) team:

Report an unsafe product