CPSIA Tracking Label Guide For Importers & Amazon Sellers

Children’s products sold in the United States must have a tracking label that makes it possible to trace a product to a certain company and production run. In this guide, we explain what you must know about creating CPSIA tracking labels, including the required information, placement, and much more.

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What is a CPSIA tracking label?

A tracking label is a permanently affixed product and packaging label that includes information about the product, batch, importer, or manufacturer. It enables brands, consumers, and the CPSC to identify and recall defective and potentially harmful products.

Further, additional tracking label requirements apply to products defined as durable infant or toddler products.

It is also important to ensure that the information in the tracking label matches the information in the following documents:

• Children’s Product Certificate (CPC)
• Test report issued by a CPSC-accepted testing company

What should be included in a CPSIA tracking label?

There are two types of CPSIA tracking labels. The first is applicable to children’s products in general, while the second contains additional labeling requirements for products defined as durable infant or toddler products.

Basic requirements

• Company name (Manufacturer, importer, or private labeler)
• Production location
• Production date
• Batch or run number or other identifying manufacturing process characteristics
• Any other information to facilitate ascertaining the specific source of the product (e.g., address of the manufacturing plant)

Durable Infant or Toddler Products

• Company name (manufacturer or private labeler)
• Production location (city, state)
• Production date
• Batch or production run number
• Manufacturer contact information (U.S. address and telephone number, toll-free if available)
• Model name
• Model number

Which products require CPSIA tracking labels?

Tracking labels are required for all children’s products, which generally cover products intended for children aged 12 years or younger. More specific guidelines can be found on the CPSC website.

Product examples

• Toys
• Baby feeding bottles
• Pacifiers
• Play yards
• Children’s clothing
• Children’s furniture
• Children’s bikes
• Children’s helmets

However, you cannot arbitrarily decide if a product is deemed to be a children’s product or not. Products that are generally recognised as children’s products or marketed as suitable for children are, in many cases, defined as such.

Where should the tracking label be placed?

The tracking label should be affixed on the product and its packaging. As such, the tracking label can be observed on the packaging when a consumer is buying the product. Further, affixing the tracking label to the product itself means that the consumer can trace the item to a company and production runs long after the packaging has been disposed of.

However, there are cases where the product cannot be labeled. Here are some examples:

• The product is too small
• The product does not have a surface that allows for label printing

In such cases, the packaging must still be labeled.

How to create a tracking label file

You need to provide a ‘ready to print’ tracking label file in .ai or .eps format with all the required information. You can use any graphics editor, such as Adobe Photoshop, Adobe Illustrator, or GIMP, to create the tracking label file.

I also recommend that you provide the following information to your supplier:

• Print placement on the product
• Print placement on the packaging
• Print color
• Print dimensions

You can find qualified design freelancers on Upwork.com in case you or your team don’t have the expertise, software, or time to create tracking labels yourself.

CPSIA Tracking Label Sample

FAQ

Which products are exempt from tracking labels?

Non-children’s products do not require a tracking label, as these are not subject to CPSIA requirements.

Is tracking labeling mandatory when importing children’s products to the United States?

Yes, the CPSIA tracking label is mandatory when selling any children’s product, as defined by the CPSIA, in the United States. Children’s products that are not correctly labeled can be seized by the customs authorities or subject to a recall at a later date.

Do I need a CPSIA tracking label when selling on Amazon?

Amazon.com requires that all products sold on its platform are fully compliant with all relevant product regulations in each respective country.

If you sell on Amazon.com in the United States, then it’s mandatory to ensure that your children’s products are fully CPSIA compliant, meaning that a tracking label is required.

Do I need a new tracking label for each order?

The tracking label must include the production date and a batch number. As such, each new production run (e.g., the order you place from your supplier) must have a unique CPSIA tracking label.

Using the same tracking label means that the product cannot be tied to a specific production run, which is a key reason why tracking labels are needed.

What is a batch number?

A batch number is a code used to tie a product to a certain production run (e.g., date) and manufacturing location. Batch numbers are unique to each production run, and generally include the following in some form.

• Product model/SKU
• Production facility
• Location
• Manufacturing date

Why is a batch number required?

The purpose of batch numbers is to ensure that unsafe products can be tied to a specific production run. This benefits sellers too, as recalls can be limited to a certain production run.

Without a batch number, you could be forced to recall years of sold goods.

Is the importer or manufacturer responsible for the CPSIA tracking label?

Importers are responsible for ensuring that products manufactured in foreign countries are correctly labeled. Meanwhile, domestic manufacturers in the US are responsible for ensuring that their products are correctly labeled.

Keep in mind that the vast majority of manufacturers outside the United States are not aware of tracking labeling requirements. You can therefore not rely on your overseas suppliers to ensure that your products are correctly labeled.

What can happen if a product is not correctly labeled?

Products with incorrect or missing tracking label files can be subject to product recalls. Incorrectly labeled products can also be subject to action from the customs authorities.

Amazon also tends to require label photocopies or label files when selling children’s products in its US marketplace.

Do I need to get approval before I can affix the label?

No, you don’t need approval from the CPSC or other government agencies. However, please note that lab testing is mandatory when selling any product covered by the CPSIA.

However, the lab test report is not specifically mentioned or otherwise referenced on the tracking label.

How much does the tracking label cost?

The only cost you need to consider is the time it’ll take you or a designer to create the label. Printing the label on the product and packaging costs a few cents per unit, at most.

How do I know if my supplier can print the tracking label?

Essentially, all manufacturers can print the tracking label on the product and its packaging as long as they are provided a ready-made label file in the correct file format, and information about the print position, dimensions, and color.

How do I check that my products are correctly labeled?

Tracking labels can easily be checked during the pre-shipment quality inspection, which takes place in the factory. Checking the label upon arrival is risky, as you cannot easily return incorrectly labeled products to overseas manufacturers.

You can also book a third-party label review. Note that some testing companies can also provide label reviews as part of the testing process.

Can I get help from a lab testing company to create the tracking label?

Lab testing companies generally don’t offer label creation services. However, some do offer label checks, which means that they compare your product labels to the CPSIA requirements.

In addition to tracking labels, are there other labeling requirements for children’s products?

Yes, there are small parts and choking hazard warning labels to take into consideration. Further, certain children’s product safety rules and standards incorporated by reference can also contain labeling requirements and symbols.