CPSIA Labeling For Small Crafters

Today is the first day of the requirement under CPSIA for affixing tracking labels to your products, and there are a lot of small crafters* out there asking the same question: "How the @#$% am I supposed to do this?????" If you make apparel you may already have figured out what to do, since there's a well-known standard for labeling apparel and CPSIA's requirements just mean a little tweaking to it. But if you make crafts?

I'm not going to cover how physically to mark your products in this post; that wouldn't be possible. There are as many kinds of products as there are crafters who make them. What I'd like to address in this post are general strategies for the hardest part (for crafters) of the CPSIA tracking label: the batch number. If you'd like to know what doesn't have to be labeled, go here.

There are three things that have to, have to, have to be on your label:

• Your name (or your DBA/business name if you have one)
• Your location (city, state, country-- I think we'd be safe skipping country if in the U.S.)
• Your choice of EITHER a production date OR a batch number that you can use to look up the production date

Production Date vs. Batch Number

The first thing you will have to decide is whether you will be using production dates or batch numbers.

If you sit down and make your product one at a time, a production date might be a better choice for you. You can use a date range if you want, or the date of final assembly. So if you start making a crayon bag on Monday 8/10 and finish it on Friday 8/14, you can put the date 8/14 or the date range 8/10-8/14 on the label. If you don't know when you'll be making stuff in time for the labels to be ordered, but you're pretty sure you'll be making it in August, you can use the date 8/2009.

If you make products in batches, for example you sit down one night and make a dozen red hairbows, you can still use a production date, which in this case would be the date that you sat down and made red hairbows.

Batch numbers are a good choice if you make goods from the same materials, especially if you make them over a spread-out period of time. To continue the hairbow example, let's say you get a new roll of red ribbon and you sit down and make it all into hairbows over the course of three days, 8/14 through 8/16. Even though you made them over 3 days, you can still consider them part of the same batch. If you make some red hairbows today and some next month, if they are made of the same materials you can still consider them part of the same batch.


Record Keeping

If you use batch numbers instead of production dates, you will need to be able to look up two things from the batch number. One is the date of production, and the other is the materials you used and their sources. The object of the record keeping game is that if CPSC brings you one of your dollies or hairbows or airplanes and says "tell me when you made this and where you got your materials," you can whip out your spreadsheet and/or notebook and look it all up.

If you can, you'll want to consider sourcing all your materials from the same places all the time. I know that's not possible for people who do upcycling and repurposing. But if you are using, let's say, new fabric, you might want to see about getting a single source where you can get all your fabric, or at least narrowing it down to a couple of sources. You may have to buy in volume to do that, but buying in volume is not as hard or expensive as it sounds. I'll have to explain how to do that later, since it's enough for a whole other post.

Whether you use production dates or batch numbers, start keeping a notebook with swatches or samples of your materials. If you use materials that can't be swatched, like wood, or materials that you will use all up, then use a photo instead of a swatch. Next to each swatch write down what it is, where you bought it, how much you bought (and maybe even what you paid if you'd like to keep track of that), what its fiber content is if it's a textile, etc. etc. As much information as you know about it, so that when CPSC comes knocking and says "And where did the stuffing come from?" you can flip through your notebook and say "I bought it at Michael's on 10/5/09." Also, give each material a sequence number (i.e. number them 1, 2, 3, etc.). This will be useful later. Every time you get a new bundle of a material, cut a new swatch (or snap a new pic) and make an entry in your notebook. When a material needs testing, put a copy of the test results in your notebook.

Now you get to choose whether to go high-tech or low-tech. If high-tech, whip out your handy dandy spreadsheet. If you don't already know how to use a spreadsheet, you will have to learn how to use it. Borrow a friend to teach you or take a class at the local community college. If you don't have Microsoft Excel, never fear. You can download a free office suite here and use the OpenOffice spreadsheet, Calc. The basic functions work like Excel, and that's all we really need for this purpose. If you'd prefer low-tech, get a ledger or a loose-leaf notebook (it can be a section in the swatch notebook). The disadvantage of low-tech is it isn't searchable, or rather its search function is your 11 year old daughter.

Whenever you make a batch, then, you'll open up your spreadsheet or ledger. In one column you'll write the batch number. Then you'll write a list of the material numbers that were used in that batch, and the date (or date range) of production, and keep a snapshot of the finished product for visual reference if it would help.


Example

You make hats using red fabric, taupe ribbon, buttons, and red thread. You bought the fabric from Quilt Warehouse on 8/1/09, the ribbon from Naomi's House Of Ribbon on 8/12/09, the buttons from Button City on 6/7/09, and the thread at Cheap Mart on 8/10/09. So your first entries in your swatch book will be:

1. Red 100% cotton calico, Quilt Warehouse, 20 yards x 45" wide, 8/1/09. (snippet of fabric)
2. Taupe 3/8" grosgrain ribbon, Naomi's House Of Ribbon, 100 yard spool, 8/12/09. (snippet of ribbon)
3. 1" white plastic buttons, Button City, 1000 qty, 6/7/09. (snapshot of button)
4. Red 100% polyester thread, Cheap Mart, 200 yard spool, 8/10/09. (sample of thread)

Also in the notebook will be a copy of the test results for the buttons. At the top of the test results you will write "#3" so that you can connect this test result with material #3. And on the packaging of these materials, write their sequence numbers. You might attach a tag with "#1" written on it to the corner of the fabric.

Now you sit down and make 12 red hats out of these materials. You assign them batch number A063 (you make up your own scheme for creating the numbers for each batch). In your ledger or spreadsheet, you write: "Batch A063, made 8/14/09. Materials: #1, 2, 3, 4."

Next month, you want to make blue hats so you go back to Quilt Warehouse and buy some blue material. So you enter into your swatch notebook:

5. Blue 100% cotton calico, Quilt Warehouse, 20 yards x 45" wide, 8/1/09. (snippet of fabric)
6. Blue 100% polyester thread, Cheap Mart, 200 yard spool, 8/10/09. (sample of thread)

and then you make 10 blue hats using the same taupe ribbon and white buttons, which you call batch number B063. (Again, you make up a numbering scheme that works for you.) In your ledger or spreadsheet, you write: "Batch B063, made 9/07/09. Materials #2, 3, 5, 6."

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I think that would be a decent, cheap record keeping system. Those who aren't all up on the computer jive that the young hepcats are using these days can do it on paper. Let me know what you think, because I just threw this together in an evening with people pestering me the whole time.


* I am NOT going to open up the whole crafter vs. artisan can of worms. Let's just have a convention that if I say "crafter" I mean YOU, even if you call yourself an artisan. It makes for easier reading.