Section 103 of the CPSIA, which requires manufacturers of goods intended for children to place tracking labels on products, becomes effective on Aug. 14, 2009.
NAM’s request was denied. “Among other purposes, the tracking information is to help the Commission and manufacturer distinguish with great specificity the products that are subject to a recall from those that are not and to help the consumer do the same by being able to look at our recall notices and match the tracking information in them to what is on their product,” wrote Commissioner Thomas H. Moore in the May 13 statement rejecting NAM’s request.
“Changes in product processes, including changes in labeling requirements for packaging and products, usually take at least a year in many sectors in order to assure smooth execution,” said Rosario Palmieri, NAM vice president for infrastructure, legal and regulatory policy, in response to the denial. “This process must begin in the design phase of the product, well before production takes place. The new tracking label provision will necessitate legal reviews, compliance clearance and training of supply chain partners. Many companies are already ordering, planning and costing production of goods that will be made in the fall of this year or later, meaning they must guess how the new labeling requirement will be implemented. If they guess wrong, they will have to scramble to rework labeling and packaging at significant cost.”