• CPSIA Tracking Label Guide For Importers & Amazon Sellers

    Posted on 9 Comments

    Tracking labels are mandatory when importing all types of children’s products in the United States. In this guide, we answer common questions about CPSIA tracking labels relevant for importers and Amazon sellers buying children’s products manufactured overseas.

    We recommend that you use this guide as a complement to the official CPSIA tracking label FAQ on cpsc.gov.

    What is a CPSIA tracking label?

    The CPSIA tracking label is a permanently affixed information label, helping the CPSC and consumers (i.e. parents) to identify unsafe products, in case of a recall. The tracking label normally includes information about the importer company, production location and date, and batch number.

    In most cases, the tracking label must be printed on the product and its packaging.

    The label must also be permanent. Stickers can be considered sufficient for the packaging, but the product must have a lasting printed or engraved tracking label.

    CPSIA Tracking Label

    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. 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 the entire point of this requirement.

    Which products require a CPSIA tracking label?

    The tracking label is mandatory when importing all products which fit into the CPSIA definition of a children’s product:

    1. If the product is marketed as appropriate for use by children of 12 years old or younger

    2. If the product packaging presents the product as appropriate for use by children of 12 years old or younger

    3. If the product display (e.g. sold in a toy store or online store selling children’s products) presents the product as appropriate for use by children of 12 years old or younger

    4. If the product is generally recognized as a product primarily intended for use by children of 12 years or younger

    Generally speaking, all products that are designed for children or products considered as children’s products must be CPSIA compliant and therefore carry a tracking label.

    CPSIA tracking label sample

    Here are the CPSIA tracking label requirements defined on the official CPSC website:

    1. Domestic manufacturer or importer

    2. Production location (e.g. city, state or province) and date

    3. Batch number

    4. Relevant information about the product and materials

    Example

    • Imported Products LLC
    • Date: September 2020
    • Location: Ho Chi Minh City, Vietnam
    • Batch number: RSX-200929-VN
    • All new materials
    • PE plastic

    How to create a tracking label file

    Contract manufacturers in China, Vietnam, India, and other countries are generally not aware of the specific CPSIA labeling requirements. As such, importers must provide a ‘ready to print’ label file in .ai or .eps format with all the information.

    As mentioned, you’ll need to create and submit a new tracking label each time you place an order.

    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 the tracking label.

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

    Importers are responsible for ensuring that products manufactured in foreign countries (e.g. in China or Vietnam) are correctly labeled.

    Is the tracking label 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.

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

    Yes, 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 therefore mandatory to ensure that your children’s products are fully CPSIA compliant, meaning that a tracking label is required.

    What can happen if I don’t have a tracking label?

    Here are a few scenarios that could happen:

    1. Your products could be withheld by the US customs

    2. Your product listing could be rejected or removed by Amazon

    3. Consumers could report your company and product directly to the CPSC, which can then trigger an investigation and forced recall*

    4. Retailers will likely reject your product

    *Forced recalls require that you instruct all your existing customers to return your product, and offer refunds and/or replacements. As such, forced recalls can result in immediate financial disaster for your company.

    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. But, keep in mind 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 tracking label itself is not purchased. The only cost you need to consider is the time it’ll take you or designer to create the label. Printing the label on the product and packaging hardly comes at a noteworthy cost. A few extra 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.

    What are some other labeling requirements I should be aware of?

    All consumer products sold in the United States must also carry a country of origin label (e.g. Made in Vietnam). You can also learn more about product labeling requirements in the United States in this article.


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  • 9 Responses to “CPSIA Tracking Label Guide For Importers & Amazon Sellers

    1. Marco at 7:45 pm

      Very interesting post.
      When using a brand registered underneath an LLC. What name do we use as Manufacturer or Private LAbeler name? LLC name or Brand name?
      Thanks

      1. Fredrik Gronkvist at 11:20 am

        Hi Marco,

        We do not offer consultations in the comment section. I suggest you contact the CPSC small business ombudsman.

    2. joe at 6:04 pm

      hello please how do i register for compliance markings including the tracking label for my product in amazon i help thanks

      1. Fredrik Gronkvist at 2:01 pm

        Hi Joe,

        Did Amazon contact you?

    3. John at 6:22 pm

      Do we need to have a tracking number on the Physical item itself – this is in addition to the labels on the packaging ?
      items like Lego are so small and what do they do on the Pieces of Lego ? any idea in this situation ? :)

      1. Fredrik Gronkvist at 11:04 am

        This is explained in the CPSIA FAQ on the CPSC website actually. No, you would probably not need it on every single part in that case but that does not mean you don’t need a tracking label.

    4. Noelia at 10:21 pm

      How to put the information on a plastic toy?

      1. Fredrik Gronkvist at 12:27 pm

        I guess it could be printed?

    5. wendy at 10:00 pm

      hi, I like to use fidget spinner , but amazon recently went out of stoke.

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