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CPSC children'sUnited StatesChildren's products

Do children's products need tracking labels?

Updated

Short answer

Yes, on the product and its packaging, to the extent practicable.

Section 14(a)(5) of the Consumer Product Safety Act, added by CPSIA section 103, requires permanent, distinguishing marks on every children's product and its packaging, to the extent practicable. The marks must let the buyer find the manufacturer or private labeler, the location and date of production, and cohort information such as a batch or run number. There is no set format, but the label must be permanent and legible.

What changes the answer

  • Practicability. The duty applies to the product and its packaging to the extent practicable. If the product is too small or its surface cannot hold a permanent mark, the packaging carries the information. Record why the product itself could not be marked.
  • Two audiences. The statute requires marks that let the manufacturer find the location and date of production and cohort information, and that let the ultimate purchaser find the manufacturer or private labeler, location and date of production and cohort information. Internal codes are fine for the first purpose; the purchaser still needs readable data.
  • Private labels. The purchaser-facing marks may name the private labeler instead of the manufacturer. The marks must still allow the source to be traced.
  • General use products. Tracking labels are a children's product requirement. Adult products do not need them under CPSIA, though some other rules, such as the bicycle helmet certification label, require similar data.
  • Durable infant products. Cribs, strollers and similar products have an additional permanent marking requirement and a registration card under 16 CFR 1130.

What to do

  1. Decide what goes on the label: brand or company name, city and country of production, month and year, and a batch, PO or lot code.
  2. Choose a permanent method: sewn-in label, molded mark, laser etch or durable printed label. Stickers that peel off are not permanent.
  3. Put the same information on the retail packaging and outer carton.
  4. Make sure the tracking data matches the CPC. The certificate must identify the date and place of manufacture and the lot, and since July 8, 2026 its data is eFiled with the entry.
Examples of children's product HTS lines
  • 9503.00.00.73

    9503: Tricycles, scooters, pedal cars and similar wheeled toys; dolls' carriages; dolls, other toys; reduced-scale ("scale") models and similar recreational models, working or not; puzzles of all kinds; parts and accessories thereof

    "Children's products" as defined in 15 U.S.C. § 2052 / Labeled or determined by importer as intended for use by persons / 3 to 12 years of age

    Toys for ages 3 to 12.

    General rate
    Free
  • 4202.92.31.20

    4202: Trunks, suitcases, vanity cases, attache cases, briefcases, school satchels, spectacle cases, binocular cases, camera cases, musical instrument cases, gun cases, holsters and similar containers; traveling bags, insulated food or beverage bags, toiletry bags, knapsacks and backpacks, handbags, shopping bags, wallets, purses, map cases, cigarette cases, tobacco pouches, tool bags, sports bags, bottle cases, jewelry boxes, powder cases, cutlery cases and similar containers, of leather or of composition leather, of sheeting of plastics, of textile materials, of vulcanized fiber or of paperboard, or wholly or mainly covered with such materials or with paper

    Travel, sports and similar bags / With outer surface of textile materials / Of man-made fibers / Backpacks (670)

    Backpacks with outer surface of man-made fiber textile.

    General rate
    17.6%
    Free or reduced under 17 programs

Next steps

Frequently asked questions

Can the tracking label be a QR code only?
The statute asks for marks that let the ultimate purchaser find the required information. A QR code alone depends on a phone and a working link, so put the basic data in readable form and use the code as an extra.
Does each crayon in a box need a tracking label?
Not if marking each piece is not practicable. Label the box. The requirement applies to the extent practicable on the product and on the packaging.
Do tracking labels replace the CPC?
No. Tracking labels, third-party testing and the CPC are separate requirements for every children's product.

Sources

  1. 15 U.S.C. 2063, Product certification and labeling (CPSA section 14), Office of the Law Revision Counsel, U.S. House
  2. Clothing FAQ, U.S. Consumer Product Safety Commission
  3. Children's Products business guidance, U.S. Consumer Product Safety Commission
  4. Certificates of Compliance final rule (eFiling), published January 8, 2025, Federal Register

This is general information drawn from the official sources linked above. It is not legal advice. Rules change and often turn on the facts of your product, so confirm your test plan with an accredited lab and your obligations with qualified counsel before you import or sell.