CPSIA Tracking Label Guide For Importers & Amazon Sellers

Tracking labels are mandatory when importing or manufacturing children’s products in the United States: Tracking labels include information about the importer or manufacturer, batch, and contact details – which is essential for traceability of children’s products to a specific seller and production run.

In this guide, we explain what US importers, manufacturers, and Amazon sellers must know about creating tracking labels.

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

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What is a CPSIA tracking label?

A tracking label is a permanently affixed product and packaging label which 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, tracking labels must be permanently affixed. This is to ensure that the product can be correctly identified months or even years after being sold.

What is the purpose of tracking labels?

CPSIA tracking labels include information necessary to trace defective and harmful products to a specific seller and production run. There are several reasons why this is important:

1. Brands can inform consumers of defects that concern specific production runs – rather than an entire product line. This can limit the financial impact of a recall.

2. Consumers can report defective and harmful products to the CPSC, which can then trace the products to a specific seller and batch

As such, tracking labels benefit both brands and consumers. Without such labels, brands could be forced to recall an entire production line – possibly wiping out years of revenue – as harmful items cannot be tied to a certain production run.

Must both the product and the packaging carry tracking labels?

In most cases, both the product and the packaging must be labeled. There are exceptions in case the product does not have the packaging, or if the tracking label is clearly visible through the packaging.

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 12 years old or younger

2. If the product packaging presents the product as appropriate for use by children 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 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 listed on the 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

5. Manufacturer contact information (US address and phone number)

Example

• Importer: Arcadia Bay Imports LLC
Manufacturing location: Bac Giang, Vietnam
• Date of manufacturing: September 2021
• Baby Romper (2022)
• Batch: ABC0921-VN-BG1
• Address: 44 Cedar Avenue, Arcadia Bay, Oregon, USA
• Phone: (123) 456-7890

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.

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.

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

The purpose of batch numbers is to ensure that unsafe products can be tied to a specific production run, rather than a product line that may have been sold for years.

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.

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

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 when selling children’s products in their 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. 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 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.

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 – meaning that they compare your product labels to the CPSC requirements.