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Can we talk about the labeling requirements?
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Melissa McKeagney
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PostPosted: Wed Dec 17, 2008 9:54 am    Post subject: Can we talk about the labeling requirements? Reply with quote

I am going to test my trims and buttons for lead using XRF so that I can stay in business through August, and presume that I can use the certs. given to me by the fabric companies and thread company to at least be part of a "reasonable testing program" to that August deadline. I'm going to limit my styles to the few that have been tested, and see where that gets me.

My question is though about the labeling requirements. If you can't use hangtags on clothing as part of the requirement, then how are you supposed to get this accomplished? I have some reversible styles, and I'm assuming you can't use "iron on" either because it isn't permanent.

Has anyone figured this out yet? Thanks.

Melissa
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Pamela
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PostPosted: Wed Dec 17, 2008 11:04 am    Post subject: Reply with quote

I don't think the labeling requirement is "law" until the August deadline and this is for the batch labeling. So you probably don't have too much to worry about until then or until May when we find out the final outcome of all this.

Pam
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Vesta
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PostPosted: Wed Dec 17, 2008 1:54 pm    Post subject: Reply with quote

How do you label with your logo, size, care information currently? Just add a tag with the tracking info.
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Kathleen F.
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PostPosted: Wed Dec 17, 2008 1:56 pm    Post subject: Reply with quote

I think this is a topic we should start exploring, meant to write about it last week but was in a panic over site problems.

sources:
Section 103. Tracking Labels for Children's Products
FAQs For Section 103: Tracking Labels for Children’s Products

I'll include the section of law at close.

FWIW, the faq seems pretty straightforward. As of 8/14/2009, you need a permanent label (not a sticky or hang tag) on the product and its packaging (if applicable). I realize this is an expense and a hassle but we're luckier than other industries. What if we were making wooden blocks? How and where could you place this information? At least we're set up to handle labeling requirements.

Manufacturers must label so they can determine:
1. Location of manufacture.
2. Date of production
3. Cohort information (none if applicable)
4. Batch or lot number, however you track a production run.

Consumers should be able to determine:
1. The manufacturer as we define it (legal definition)
2. Location of manufacture
3. Date of production
4. Cohort information (none if applicable)
5. Batch or lot number, however you track a production run.

The sticking point with manufacturers is listing the contractor. A related stink was over having to list the contractor on the GCC but the CPSC backed down over that pretty quickly. You do have to have some kind of organized internal reference numbering or abbreviation system to track contractors but you don't have to list them by name on the GCC. I would imagine that it'll be fairly easy to have the same allowance made for the labeling requirement. In other words, while it's not official, I'm going to spend my time worrying about other things.

There's two key problems for small producers.
1. Ordering labels -we have minimums.
2. Creating a control system for batch or lot numbers.

I think #2 is easier. If you're using style numbers properly (review pgs 58-61 in the book), just amend it with another set of digits. The problem is one of replication tho because your upc code will be different as those include color codes and your batch could include several color ways. Duplicity is annoying but it's no big deal.

Batching
Oh wait. We don't know what a "batch" is. I mean, we know what we mean it to mean but we can't assume the CPSC shares our definition. Oh boy. This is something that will have to be clarified. [Note to self, write to CPSC for clarification.] For us, a batch means one production run, typically everything cut from a given marker. A production run usually includes several colorways all cut at the same time. Iow, it is possible that the fabrics considering dyes and all will not be exactly the same testing wise. For all we know, the CPSC thinks one batch means items are (for testing purposes) identical to each other. This could mean that to them, one of our batches is actually three (however many color ways). ~sigh~

Rather than amending style no with another set of digits, your other option is to create a separate database to track batches and assign unique numbers to each. You'd need fields for style no and all that rot that comprises the SKU.

Does it go without saying that all of this batching stuff flies in the face of lean manufacturing? If you're as lean as an operation like Fit Couture, all your batches are comprised of one unit. Definitely annoying.

Labeling
Since we have to track batches or lots and we run really small quantities, this just isn't possible to do the way we have been. I think there's two options. One is to order labels as we have been (putting this on the back of the care label) and add the batch # manually with an indelible ink pen. I don't think this is a practical solution for anyone but the tiniest of producers. It'll look tacky and we like things to look neat and professional don't we?

The other option is to print your own from a desktop laser printer. When I went to SPESA, I found a supplier for this kind of thing, Label It. He's not the only one of course but I did compare prices on consumables and different printing solutions that seemed pretty reasonable. You can get a dedicated printer for it (most commonly used for barcoding). He also sells software ($200) to set up the labels but I'd imagine anyone halfway handy with a word processing program could figure that out. The sheet feed consumables are perforated so you can tear them apart. I'm not wild on the consumables, it's that stiff interfacing looking stuff. I didn't see these products specifically listed on his site but I know he has them and I got a little catalog and price list when I was there. The price list is here (xls).

Okay, I'm done for now. I'll probably post this as a blog entry too.

Quote:
SEC. 103. TRACKING LABELS FOR CHILDREN’S PRODUCTS.
(a) IN GENERAL.—Section 14(a) (15 U.S.C. 2063(a)), as amended by section 102 of this Act, is further amended by adding at the end the following:
(5) Effective 1 year after the date of enactment of the Consumer Product Safety Improvement Act of 2008, the manufacturer of a children’s product shall place permanent, distinguishing marks on the product and its packaging, to the extent practicable, that will enable—
(A) the manufacturer to ascertain the location and date of production of the product, cohort information (including the batch, run number, or other identifying characteristic), and any other information determined by the manufacturer to facilitate ascertaining the specific source of the product by reference to those marks; and
(B) the ultimate purchaser to ascertain the manufacturer or private labeler, location and date of production of the product, and cohort information (including the batch, run number, or other identifying characteristic).’’.

(b) LABEL INFORMATION.—Section 14(c) (15 U.S.C. 2063(c)) is amended by redesignating paragraphs (2) and (3) as paragraphs (3) and (4) and by inserting after paragraph (1) the following:
(2) The cohort information (including the batch, run number, or other identifying characteristic) of the product.’’.

(c) ADVERTISING, LABELING, AND PACKAGING REPRESENTATION.—
Section 14 (15 U.S.C. 2063) is further amended by adding at the end the following:
(d) REQUIREMENT FOR ADVERTISEMENTS.—No advertisement for a consumer product or label or packaging of such product may contain a reference to a consumer product safety rule or a voluntary consumer product safety standard unless such product conforms with the applicable safety requirements of such rule or standard.’’.
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Melissa McKeagney
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PostPosted: Wed Dec 17, 2008 5:59 pm    Post subject: Reply with quote

Thanks Kathleen and Pam.

Vesta, I currently don't have care information on my cloth labels. I have been meaning to do this, but haven't gotten around to it, and it has been on my "to do" list. I always include this information on a written card that I send with each piece of clothing, and because my items don't need any special care, I haven't worried too much about it until now.

So, if a care label is sewn into the seam, and let's say I have the batch, lot, date, and other information back there, is that considered "permanent"? Yes, the indelible marker seems like a messy option. I'll check into the label it guy.

Melissa
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Vesta
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PostPosted: Wed Dec 17, 2008 6:10 pm    Post subject: Reply with quote

Yes, if it's sewn in, it's permanent. If you use the folded style (where you sew in the two raw edges), you can get a lot of info on the label and sew it into a side seam. Put it at the bottom of the garment, and it shouldn't be too noticeable. If someone really hates it, they can cut it out, but you did your duty.
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Miracle
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PostPosted: Wed Dec 17, 2008 6:14 pm    Post subject: Reply with quote

Quote:
Labeling
Since we have to track batches or lots and we run really small quantities, this just isn't possible to do the way we have been. I think there's two options. One is to order labels as we have been (putting this on the back of the care label) and add the batch # manually with an indelible ink pen. I don't think this is a practical solution for anyone but the tiniest of producers. It'll look tacky and we like things to look neat and professional don't we?


I was thinking, and I don't know if this is feasible, that someone could use a rubber stamp along with fabric ink to mark the batch information on the back of the label.

I guess this shows I haven't been to the library in like 10 years, but remember when they'd use that thing to stamp your due date slip? You can get this customized, with some things changeable.

And my first suggestion, was to talk a label provider into providing a specialty product line for this purpose (like Laven lables). Thermal labels are about the cheapest option for this.

Lastly, if this proves to be too cumbersome, there is always the option of having batch labels pre-printed, providing a manufacturer has a numbering scheme. They can use a tiny tiny label sewn in behind the others. I have seen labels like this used to track style #s, or production facilities, in other garments

The manufacturer, location of manufacture should be on the existing woven or care label, as the FTC mandates that. This law goes further with compliance, though, requiring companies to finally either have an RN# or use their legal business name.

Since I don't know what a cohort is, or feel like looking it up, I'll skip that.


Last edited by Miracle on Wed Dec 17, 2008 6:19 pm; edited 1 time in total
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Miracle
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PostPosted: Wed Dec 17, 2008 6:18 pm    Post subject: Reply with quote

Melissa McKeagney wrote:
Thanks Kathleen and Pam.

Vesta, I currently don't have care information on my cloth labels. I have been meaning to do this, but haven't gotten around to it, and it has been on my "to do" list.



Violates FTC rules for garment labeling.
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J C Sprowls



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PostPosted: Wed Dec 17, 2008 6:35 pm    Post subject: Reply with quote

Quote:
They can use a tiny tiny label sewn in behind the others. I have seen labels like this used to track style #s, or production facilities, in other garments

Yes. Batch and Lot can (and, probably should be) a separate label. The in-house printing option might work best for this. If the consumer decides to cut out the label because it's noisome, that's a separate matter.

I'm a little perplexed about the request for more than the RN number - I mean, this is the company accountable for bringing the product to market. IMO: the Batch ID should have an in-house paper trail to the production facility (i.e. cohort) and the Bill of Materials. Likewise, the BOM should have a trail to the intake testing results (i.e. component testing).

The gray area is carryover inventory. Let's say you have 3 dozen zippers leftover from last run; and, you go to the same supplier for 20 dozen more. Presuming the 20 dozen new zipper come from the same production lot, you - the manufacturer - now have to reconcile which zipper component was used on which unit w/in your batch.

You would also have the same problem if you ordered 1K zippers; and, the supplier needed to cross two lots to fulfill your order.

The uniform company I worked for used to do some military uniforms. And, as a result, we had a super-overhead-heavy inventory process. We also had "ways" of dealing with this carryover inventory "problem". But, because the military specs were such a pain, plus the military was notoriously late on payment, plus, plus, plus... we refused a lot of work. I need to rack my brain to see if I can remember the intricacies of the inventory system.

RE: CCO (Care, Content & Origin). You don't need this information on your brand label. But, you do need them in the garment to comply with FTC regulations. CCO labels typically contain the RN number, which is the legal business name of your - the manufacturer's - company.


Last edited by J C Sprowls on Wed Dec 17, 2008 6:39 pm; edited 2 times in total
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Kathleen F.
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PostPosted: Wed Dec 17, 2008 6:36 pm    Post subject: Reply with quote

Cohort means contractor. Entry is up on the blog.
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blizzard77
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PostPosted: Wed Dec 17, 2008 6:49 pm    Post subject: Reply with quote

Sigh. Currently I assign a pre-printed, numbered label...and then keep track of everything else in a database according to what that number is. So I know everything about the customer/order/product specs but the customer only has a number to refer to.

For some reason I was under the impression that soon we'd be required to have the info printed ON the garment --I'm obviously wrong on that so off to consider better tagging info.
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Miracle
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PostPosted: Wed Dec 17, 2008 6:51 pm    Post subject: Reply with quote

Quote:
I'm a little perplexed about the request for more than the RN number


Probably because people weren't playing by RN rules to begin with. I've come across my fair share of companies that were not.

For others, the RN rules go something like this: either of these must be on your label:

1- the legal company name (as on company documents and company registration)
2- the RN#

You can have both. You must have one.
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J C Sprowls



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PostPosted: Wed Dec 17, 2008 6:55 pm    Post subject: Reply with quote

Quote:
Probably because people weren't playing by RN rules to begin with.

Yes. I do know. I just got done reaming a CMT shop for sewing in size labels with their RN number on it because it competed with the RN number the customer supplied on the CCO label. Plus, the CMT shop opted to throw out the customer's size labels.

Guess who stood there supervising them to rip out and re-label all the garments?
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Vesta
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PostPosted: Wed Dec 17, 2008 7:12 pm    Post subject: Reply with quote

We can't get an RN#. We tried, but our products aren't required to have one, so they won't issue one. Just FYI, for others not making clothing.
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Miracle
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PostPosted: Wed Dec 17, 2008 7:17 pm    Post subject: Reply with quote

Vesta wrote:
We can't get an RN#. We tried, but our products aren't required to have one, so they won't issue one. Just FYI, for others not making clothing.



Did you apply online?

https://rn.ftc.gov/pls/TextileRN/wrnreq$rn.call_rn?p_mode=INS

RNs are supposed to apply to textile items, even including home goods, so that's strange that they wouldn't give you one.
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