ComplyMyImport guide
Tracking label requirements for children's products
Tracking labels help identify the manufacturer or private labeler, production location and date, and cohort information for a children's product. They support traceability when investigating a safety issue or recall.
Build traceability into production
The product and packaging generally need distinguishing permanent marks to the extent practicable. The required information should enable the manufacturer and ultimate purchaser to determine relevant production details.
Operational records may include:
- Manufacturer or private-labeler identity
- Factory or manufacturing location
- Manufacture date or date range
- Batch, run, lot, or other cohort identifier
- Product model, SKU, and artwork version
- Explanation of any practicability limitation
Review both product and packaging
Do not review a flat artwork file in isolation. Confirm where markings appear on the finished product and retail packaging, their legibility and permanence, and whether the codes resolve to maintained records.
Label extraction can confirm visible text, but it cannot reliably determine physical permanence, final placement, prominence, or legal acceptance. Those questions require evidence and human review.
Keep product identity consistent
Tracking codes, SKU, model, factory, and production period should agree across the label, test report, CPC, supplier documents, and shipment records. Investigate inconsistencies before approval.
Separate labels from CPC citations
CPSC guidance notes that the tracking-label requirement itself is not certified on the CPC. It remains an important children's product obligation and should be reviewed within the product record rather than incorrectly added as a certificate citation.
Control artwork changes
Version label and packaging files, record approvals, and prevent obsolete artwork from returning to production. Connect each production lot to the approved version.
ComplyMyImport supports source-linked artwork review and exact product-identity checks while reserving final decisions for authorized reviewers.
This guide is general educational information, not legal advice.
Official source
- CPSC tracking label guidance: cpsc.gov/Business--Manufacturing/Business-Education/tracking-label