Seriously, though, couldn’t they have done this a few months ago??
Click to access sect103policy.pdf
Good news: They have defined “location of manufacture” to mean city and state.
Good news: They have noted that they recognize that “date of production” is a little undefinable, since MOST products are manufactured over the course of several days. “date” can be a range. For me, I’m assuming that then means “date” can mean Month and Year.
Also, regarding Cohort information:
Although Section 103(a) does not require manufacturers that do not use lot, batch or run numbers to create such a system, the Commission believes that compliance with this Section generally will require that manufacturers have in place a reasonable means to ascertain detailed production information, including the means to distinguish products made from different factories, made with different components, at different times or have other material differences that make the product non-identical from previous products. The business and recordkeeping practices of peer manufacturers should be considered.
Small volume manufacturers and crafters may be unlikely to use lot, batch or run numbers, and, again, the Commission does not interpret Section 103(a) to require them to create such a system. Nevertheless, reasonable practices should be in place by such manufacturers to keep records of components used in their products.
So, you know, you don’t HAVE to, but you have to. Which is fine. I’m not totally on board with the whole Fashion Incubator coding system thing yet, but I think I have a system worked out (in my head anyway) that will accomplish this goal of tracking every time something changes. Should not be hard, actually.
But it will be time consuming, yet another piece of paperwork cluttering up my time and sucking the joy out of what I do.
But, I am SUPER GLAD to read these clarified expectations from the CPSC. Let me state again that I think they’re doing a good job with the mess they were handed.
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