CPSIA Tracking Label: What Children’s Product Importers Must Mark

A CPSIA tracking label is the set of permanent marks that every children’s product and its packaging must carry so that both the manufacturer and the buyer can tell who made it, where, when and in which batch. The requirement comes from section 103 of the Consumer Product Safety Improvement Act, codified at 15 U.S.C. 2063(a)(5), and has applied to children’s products made on or after August 14, 2009. A children’s product is one designed or intended primarily for children 12 years of age or younger.

For an importer the label is not a formality. The Consumer Product Safety Act defines a manufacturer as anyone who manufactures or imports a consumer product, so the US importer shares the obligation with the foreign factory, and 15 U.S.C. 2066(a)(2) lists a missing tracking label among the reasons a shipment must be refused admission. This guide covers what the marks must contain, where they go, how they differ from country of origin marking, who should print them in an import supply chain and which mistakes stop goods at the port, using the statute and CPSC’s statement of policy on section 103(a).

What the Tracking Label Must Contain Under 15 USC 2063(a)(5)

The statute is written as a test of what the marks must make possible, not as a list of fields. Under 15 U.S.C. 2063(a)(5)(A), the permanent, distinguishing marks must enable two audiences to find specific information.

• The manufacturer must be able to ascertain the location and date of production, cohort information (batch, run number or another identifying characteristic) and any other information it decides helps trace the specific source of the product.
• The ultimate purchaser must be able to ascertain the manufacturer or private labeler, the location and date of production, and the cohort information.

How CPSC reads each element

CPSC’s statement of policy on section 103(a), announced at 74 FR 41868 (August 19, 2009), fills in the detail. The name of the manufacturer or the private labeler, meaning the brand owner, must be ascertainable. For location, the name of the country plus the city and state, or administrative region, is sufficient, although the manufacturer must be able to identify the specific factory if CPSC asks. The date of production may be a date range when a product is made over time, and for items assembled or gathered into one package it is the date of assembly or packing. Cohort information does not require a factory to invent a lot system it does not use, but CPSC expects a reasonable way to distinguish products made in different factories, with different components or at different times.

The policy also confirms there is no required format. Codes are allowed if the consumer can still ascertain the underlying information, and marks need not sit in one place: CPSC looks at the totality of permanent marks on the product and packaging, including brand marks and labels required by other federal rules. A format that covers every element on a sewn label or molded mark is brand name, factory city and country, production month and year, and a purchase order or batch code.

Product, Packaging and Practicability Rules

The default under the statute is both: the product and its packaging carry the marks, “to the extent practicable”. CPSC treats a mark on the product as permanent if it can reasonably be expected to remain for the product’s useful life. On disposable packaging, permanent only means durable enough to reach the consumer, so an adhesive label on a retail box can be enough, and if the product’s mark is visible through the packaging it does not need to be repeated on the package.

The statement of policy lists situations where marking the product itself may not be practicable and marking the packaging is acceptable. Each one is a judgment the importer should document, because CPSC expects a departure only for considered and definable reasons, compared with what peer manufacturers do.

• The product is too small to be marked.
• Games with boards and small pieces: the board and the box are marked, not each piece. Arts and crafts kits follow the same logic: the storage box and one integral part.
• Small items packed together, such as marbles, buttons or beads: the package is marked.
• Bulk vending items: the shipping carton sent to the retailer is marked.
• A mark would weaken or damage the product or impair its use.
• The surface cannot be marked permanently, such as elastics, beads, small fabric pieces in jewelry or hair ornaments, pipe stems or natural rocks.
• A mark would ruin the product’s appearance and no accessible but inconspicuous location exists.

Sets, pairs and multipacks

For items that only function as a set or pair, such as shoes, one item or an integral part of the set may carry the mark. Items that can be separated and sold individually need their own marks. This matters for multipacks broken down by a retailer or a marketplace seller: if a single unit can reach a consumer on its own, it needs marks that survive without the outer pack.

Tracking Labels vs Country of Origin Marking

Importers often assume the “Made in China” or “Made in Vietnam” mark covers the location requirement. It covers part of it. Country of origin marking is a CBP rule: under 19 CFR 134.11, every article of foreign origin, or its container, must be marked in a conspicuous place, as legibly, indelibly and permanently as its nature allows, with the English name of the country of origin. The marking must survive normal distribution and store handling (134.41(b)), and unmarked goods owe an additional 10% duty on their final appraised value unless they are exported or destroyed under CBP supervision before liquidation (134.2).

The tracking label asks for more. CPSC’s policy treats country plus city and state or administrative region as the location of production, and it adds manufacturer or private labeler, date and cohort. The two rules also differ on placement: 19 CFR 134.11 requires the article itself to be marked unless an exception allows marking only the container, while the tracking label is expected on the product as well as the packaging unless one of the practicability cases applies.

One label that satisfies several rules

CPSC explicitly allows marks required by other federal rules, including country of origin labeling and Textile, Wool and Fur Act labels, to count toward the distinguishing marks if they are permanent. For children’s apparel, a sewn-in care label carrying the brand, the RN number and the origin can be extended with factory city, production date and batch code instead of adding a second label. Questions about which country to declare for goods assembled in more than one country belong to country of origin determination, because the origin on the label, the entry and the tracking mark must agree.

Who Prints the Tracking Label in an Import Supply Chain

Legally, the obligation sits with the manufacturer, which under 15 U.S.C. 2052(a)(11) includes the importer, and CPSC’s policy says importers should work with their foreign sources because both must comply. Practically, the marks have to be applied at the factory, because that is where the production date, line and batch are known and where a molded, printed or sewn mark can be made permanent. The importer’s role is to specify the content, approve it, and hold the records that decode it.

A workable split for a toy or children’s product importer looks like this. The purchase order or product specification defines the format, including the brand or private labeler name, factory city and country, a date field and a batch or PO code. The factory applies the marks on the product and the retail packaging and reports the batch codes against each shipment. The importer keeps a register that links each batch code to the factory, production dates, components and the test report that covered that batch. When a private label retailer is the brand owner, the agreement should say whose name appears and who keeps the register, since the purchaser must be able to identify the manufacturer or the private labeler.

Where the tracking label meets the certificate

The batch code on the product is what ties a unit on a store shelf to the certificate and test report behind it. What the certificate itself must list is covered in our guide to the children’s product certificate, and the testing that feeds it, for toys, in the ASTM F963 guide. The point for labeling is consistency: the factory, the production period and the cohort shown in the tracking marks should match the certificate filed for that entry through CPSC eFiling support.

Common Failures That Trigger CPSC Action at the Port

The legal consequence of a missing tracking label is stated plainly in the statute. Under 15 U.S.C. 2066(a)(2), a consumer product offered for import must be refused admission if it is not accompanied by any label or certificate required under section 2063, “including tracking labels”. Failure to comply with the tracking label requirement is also a prohibited act under 15 U.S.C. 2068(a)(6), which exposes the importer to civil penalties. CBP can deliver samples to CPSC for examination; CPSC may allow the goods to be brought into compliance under supervision, and otherwise refused goods are destroyed unless CBP approves export, with storage, cartage, labor and destruction costs charged to the owner or consignee.

• Packaging marked, product not: a unit removed from its retail box carries no marks, although nothing in the product’s size or material made marking impracticable.
• Country only: the product shows “Made in China” and a brand, but no factory city, date or batch.
• Codes nobody can decode: a string of characters on the product that the importer cannot translate into factory, date and batch when CPSC or a consumer asks.
• Non-permanent marks: a sticker on a plastic toy or a hangtag on a garment used as the only product mark, which will not last the product’s useful life.
• Mismatched records: the batch code on the goods does not appear on the certificate, the test report or the commercial invoice for the shipment.
• Separable multipack units: individual items that can be sold alone with marks only on the outer pack.

A pre-shipment check

Before the goods leave the factory, pull a sample from each production lot and confirm, on the product and on the retail packaging, the brand or private labeler, factory city and country, production date or range and batch code. Photograph the marks and file the photos with the purchase order. A shipment refused for a missing tracking label cannot be fixed by paperwork after arrival, because the defect is physical. Importers can add the label photos to the entry file shared with their licensed customs broker before filing.

Duty on Common Children's Product Lines

Tracking labels sit on top of a duty bill that changed in 2026. Toys under heading 9503 have a Free MFN rate and are only on China’s suspended List 4B, so since July 24, 2026 they pay the 12.5% Section 301 forced labor duty from both China and Vietnam. Children’s apparel and accessories still carry MFN rates and, from China, the List 4A or List 3 duty as well. Run the 10-digit line through the China to US tariff calculator before setting a landed cost. AD/CVD and exclusions are not included.

Frequently Asked Questions