CPSIA Tracking Label Requirements for Better Recall Identification

The Consumer Protection Safety Improvement Act (CPSIA) was implemented to bolster consumer protection strength against unsafe products by authorizing increased enforcement power to the Consumer Product Safety Council (CPSC); updating safety standards; applying stricter thresholds on hazardous substances such as phthalates, cadmium and lead; and imposing mandatory tracking label requirements on children’s products.

The purpose of the tracking label requirement is to improve communication between consumers and manufacturers or importers concerning product recalls.

A History of Recall Effectiveness

The CPSC began conducting research into the effectiveness of product recalls back in the late 70’s, and in 1980, they formed the Recall Effectiveness Task Force. They looked for data to show how often consumers “took advantage of recall remedies” after a product recall was announced.

Mirroring more recent concerns over high lead and phthalate content, the prevailing scare 40 years ago was asbestos. The RETF surveyed consumer reaction to various hair dryer recalls on the basis of asbestos content and found that, even though 85% of those surveyed were generally aware of the problem, only 44% followed up to find out if their particular hair dryer had been identified as a recalled product.

Beyond that, an even smaller fraction of the consumers surveyed followed up on these recalls, and the asbestos hair dryers remained largely in circulation.

Dangerous products like these are too often made to be cheap and disposable and, as the RETF has concluded, factors like cost, product lifespan and distribution age seem to greatly influence a consumer’s decision to either follow up on or simply ignore recall alerts.

Since then, the CPSC has sought to make consumer access to available recall information much easier, and permanently affixed tracking labels are a result of these efforts.

When Are Tracking Labels Required?

Section 103 of the CPSIA specifies that all products intended for children 12 years or younger require permanent tracking labels.

Clear, effective tracking labels can go a long way in building further trust between your company and your consumers, particularly if there is grey area concerning the actual age group your product will be used by.

An expert Quality Assurance service can help you make informed design decisions which considers the practicality of incorporating an effective tracking label into your product.

What Do Tracking Labels Require?

Manufacturer or Private Labeler Name

The name of a manufacturer, importer, or private labeler is identified so a consumer without access to the internet can know whom to contact directly to obtain the required information.

Production Location

The country and city where the product is manufactured will be sufficient for the tracking label. All or part of this information may be represented in code form and may be included as part of a larger batch identification system for the purpose of satisfying the tracking label requirement.

Country of Origin

Although your product might contain components manufactured in multiple countries, the label should reflect the product’s final processing stage.

Manufacturing Date

This can be challenging because of the variant times it takes to make different products, sometimes months, depending on process and batch size. Many companies use “exit factory dates” even though they were technically finished well before that date. It is up to your company to narrow down as much as possible the particular date on the label.

Cohort Information

More variables are connected to this information, so your company’s “cohort”, or group from which the item originated, can be determined through a batch or run number, a purchase order number or other identifying characteristic. In certain cases such as garments, style or design is the best way to identify the product specifically.

Permanent Affixation

A label, both visible and legible, should be printed or etched onto the product to be considered permanent. Adhesive paper labels would not be considered permanent.


The CPSC is not specific about exemptions, however they insist on labeling “to the extent practicable”, either on the product itself or on the packaging. Items like children’s jewelry cannot be practically labeled on each item, so it is strongly recommended that any accompanying packaging is clearly labeled. Certain textiles, like those made from natural fibers, might also be exempt from labeling.

What is a Product Registration Card Required For?

An additional Product Registration Card is required for “durable infant and toddler products”, like cribs, strollers and bassinets. These are detachable, postage-paid registration cards requesting consumer contact information in case of a recall on that particular product.

Registration cards began appearing on child car safety seats in 1993 as per Federal Motor Vehicle Safety Standard 213 and has shown to be an effective boost to consumer product registration and repair rates.

Again, as the CPSC has discovered, a short span of usage can greatly affect a consumer’s participation in recall remedies. Products like infant car seats may only be used by a family for a few months before it is either passed on or sold privately, and the previous owner’s initial interest in the safety of that product has been replaced by whatever currently affects their child.

The registration card provides an additional layer of manufacturer-to-consumer communication protection because it allows the original registrants to pass along to the new owner any potential recalls down the road, and dangerous products have less of chance of remaining in circulation.

Developing Your Tracking Label Needs

QIMA's comprehensive QA assistance can help you make crucial labeling decisions from the very start which will ensure a better flow of information between the consumer and your company.

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