What did the CPSC say?
• The CPSC said it will be flexible in enforcing Section 103(a). Good faith efforts to comply will generally be given deference and in any case will typically not result in a CPSC fine. A manufacturer’s individual circumstances, as well as general industry practices, will be considered in determining whether a tracking label can be placed on a product/packaging at all, and whether that label is sufficient to meet the requirements of the CPSIA. For example, the Statement of Policy indicates that crafters and other small manufacturers likely do not have to develop a new, comprehensive record–keeping system in order to differently identify each “batch” of new products, if such is not currently done by similar businesses. • Labels can be a mere “distinguishing mark” and the specific information need only be “ascertainable.” Thus, alphanumeric codes and even Web site URLs may be sufficient to comply with Section 103(a) if those marks allow both the manufacturer and consumers to ultimately d
