A CPSC tracking label is the set of permanent marks that every children’s product and its packaging must carry, to the extent practicable, under section 103 of the Consumer Product Safety Improvement Act of 2008 (CPSIA). The marks must make four things ascertainable: the manufacturer, importer or private labeler; the location and date of production; batch, run or other cohort information; and any other information that helps pin down the product’s specific source (CPSC, data checked 2026-10-13). The information may be coded, the marks need not sit on one label, and the tracking label is not cited on your Children’s Product Certificate.
This guide sets out CPSC’s criteria so you can check your own product; it does not decide whether any specific label complies.
Sources: CPSC Tracking Label Business Guidance, CPSC Tracking Label FAQs, CPSC’s 2009 Statement of Policy on section 103(a) (notice of availability, 74 FR 41868, August 19, 2009), 15 U.S.C. 2063, 2052 and 2068 (U.S. Code, 2024 edition, via govinfo), and Amazon’s product compliance documentation help page. Data checked 2026-10-13.
What the CPSIA Section 103 Tracking Label Requirement Is
Section 103 of the CPSIA, titled “Tracking Labels for Children’s Products,” amended the Consumer Product Safety Act. It is codified at section 14(a)(5) of that Act, 15 U.S.C. 2063(a)(5). The statute says the manufacturer of a children’s product “shall place permanent, distinguishing marks on the product and its packaging, to the extent practicable.”
“Tracking label” is shorthand. CPSC’s FAQ says the term is “used in place of the phrase ‘distinguishing permanent marks’” and that firms “should not interpret ’label’ to mean that all of the information has to be printed in one discrete location.” Marks you already carry for other rules, such as the FTC’s RN number on textiles, can count toward the requirement, though CPSC says the RN alone does not fully satisfy it.
Effective date. CPSC’s 2009 policy statement says section 103(a) “applies to children’s products made on or after August 14, 2009” and does not apply retroactively.
Who is responsible. CPSC’s FAQ puts compliance on “the domestic manufacturer for products manufactured domestically or the importer of record for products manufactured overseas.” For most FBA private label sellers who import, that is the importer of record. CPSC’s FAQ also says there is no exemption based on the size of the business.
Which Products Need a Tracking Label
The requirement covers children’s products and their packaging only. The statute (15 U.S.C. 2052(a)(2)) defines a children’s product as “a consumer product designed or intended primarily for children 12 years of age or younger,” weighing four factors:
- The manufacturer’s statement about intended use, including a label, if reasonable.
- Whether packaging, display, promotion or advertising represents it as appropriate for children 12 or younger.
- Whether consumers commonly recognize it as intended for a child 12 or younger.
- CPSC staff’s Age Determination Guidelines.
Factor 2 matters on Amazon: listing copy, images and age range are promotion. CPSC’s FAQ applies the requirement to children’s furniture explicitly; in a set, “there must be a tracking label affixed to each item of furniture included within the set if each piece of the set is sold separately.”
Durable infant or toddler products carry more. CPSC’s guidance page says they “need to meet additional product and package labeling requirements beyond the tracking label requirements.” The marking rule for those products is covered in our infant sleep product standards guide.
The Four Kinds of Information a Tracking Label Must Include
CPSC’s guidance page lists what must be ascertainable from the marks on the product and its packaging, to the extent practicable. The second column is what CPSC’s FAQ and 2009 policy statement say about each item.
| Required item (CPSC’s list) | What CPSC says is enough |
|---|---|
| Manufacturer/importer or private labeler name | A name is mandatory; the marks must let “the ultimate purchaser to determine the manufacturer/importer or private labeler” |
| Location and date of production | Country plus city and state or province; month and year; a date range if made over time; for kits, the date of assembly or packing |
| Detailed information on the manufacturing process (e.g., batch or run number) or other identifying characteristics | No new batch system is required, but you need a reasonable way to tell apart products from different factories, components or times |
| Any other information to facilitate ascertaining the specific source (e.g., address of the manufacturing plant) | The manufacturer or importer must be able to identify the specific source if CPSC inquires; this may be coded |
The location can be coded and folded into a larger batch identification system; the name cannot be replaced by a code (see below). CPSC’s guidance page says compliance “improves the effectiveness and response rates for product recalls.” Our Amazon product recalls guide covers what a recall looks like on the selling side.
Product and Packaging: Where the Marks Go
The default is both. CPSC’s FAQ says: “In most instances, both the packaging and the product must be marked.” Two shortcuts apply:
- Clear packaging. If all the required information is visible on the product through outer or clear packaging, the package and any hangtag need not repeat it.
- No retail packaging. If no retail packaging encloses the product, marking the product alone is sufficient.
Permanent means for the product’s useful life. CPSC’s FAQ defines a permanent mark as one that “can reasonably be expected to remain on the product during the useful life of the product.” A packaging mark only has to be durable enough to reach the consumer, so an adhesive label on disposable packaging “might be sufficient.”
Adhesive labels on the product are allowed only if the label keeps its integrity for the product’s expected lifespan. Textiles are stricter: CPSC says hangtags and adhesive labels “are not permanent for these products,” and textile labels must last the product’s life under its care instructions. For socks, CPSC says the sock itself does not need a tracking label, but the packaging must still carry the information.
CPSC has not set a size, location or format. Its FAQ says it has not drafted a sample label “because each type of consumer product may warrant a different type of tracking label.”
A tracking label is not your FBA barcode. The FNSKU label in our FBA labels guide identifies a unit in Amazon’s inventory; it does not carry production location, date or batch.
What “To the Extent Practicable” Covers
CPSC’s FAQ sets the bar: “The Commission expects a manufacturer to depart from the specific requirements only for considered and definable reasons.” It lists these cases where marking the product itself may not be practicable:
| Situation | Example CPSC gives |
|---|---|
| Product too small to mark | Size is “a primary consideration” in the legislative history |
| Package is meant as reusable storage | Board games with small pieces |
| Sold through bulk vending | Mark the bulk package or carton shipped to the retailer |
| Marking would weaken, damage or impair the product | — |
| Surface cannot be permanently marked | Elastics, small pieces of fabric, pipe stems |
| A mark would ruin aesthetics and no inconspicuous spot exists | A bag of marbles |
For sets, CPSC’s FAQ says a set of 20 wooden blocks may not need every block marked; marking one side of one block may be reasonable, and a reusable storage box or bag counts as part of the product. The 2009 policy statement says items that function only as pairs, such as shoes, need only one item marked, but items that can be sold separately need separate marks.
Practicability is not an off switch. CPSC reminds firms that even when the product cannot be marked, the packaging still must be, unless the product marks are fully visible through clear packaging. If you decide marking is not practicable, CPSC says to “make a written record of the reasons,” including copies of any research into peer manufacturers’ practices. Keep that record with your compliance file.
Can the Tracking Information Be a Code or a Website?
Yes, with a condition. CPSC’s guidance page says the information “may be in code form as long as the consumer knows who to contact in order to interpret the code.” The 2009 policy statement says section 103(a) “does not require codes, formats or numbering systems.”
On a code plus a website address, CPSC’s FAQ answers yes, “provided the name of a manufacturer, importer, or private labeler is also identified so a consumer without access to the internet can know whom to contact.” In practice: put your brand or company name in plain text, and let a lot code carry the date, location and batch.
Why the Tracking Label Does Not Go on the Certificate
CPSC’s guidance page says the tracking label requirement “is not considered a safety rule that requires certification” under section 14(a)(1). Its FAQ adds that tracking labels are not on the list of rules needing third-party lab assessment at 16 CFR 1112.15(b), and that CPSC “does not require a citation for tracking labels to be included in a Children’s Product Certificate.”
That does not remove the certificate. CPSC says children’s products “still require a Children’s Product Certificate (CPC) if there are other safety rules that apply.” The CPC’s own date and place of manufacture element should match what your lot code decodes to. Our Children’s Product Certificate guide covers the seven elements and lab testing.
Missing marks still have legal weight. 15 U.S.C. 2068(a)(6) makes it unlawful “to fail to comply with any requirement of section 2063 of this title (including the requirement for tracking labels).” CPSC’s 2009 policy statement said that, given good faith efforts, it “will not likely seek penalties if required information was inadvertently omitted.” That statement described the period when section 103(a) first took effect.
What Amazon Asks For
Amazon’s product compliance documentation page has a section titled “Our policy for tracking labels.” It says: “If Amazon requests a tracking label for your product, you must provide a tracking label that includes the following,” followed by the same four items as CPSC’s list.
Amazon then adds three notes:
- “The tracking label must be a permanent tracking label on the product and product packaging.”
- “Do not provide a tracking label printed on paper and stuck on the product.”
- “In order to be compliant, product images must include all relevant safety information and the tracking label.”
Amazon’s paper-sticker note is narrower than CPSC’s position, which allows an adhesive product label that lasts the product’s life; if Amazon is asking, meet Amazon’s wording. The page does not say whether the images note means the listing gallery or images sent in response. Where these requests appear in your account is covered in our Manage Your Compliance guide.
What CPSC’s Pages Do Not Answer
On 2026-10-13, CPSC’s guidance page, FAQ and 2009 policy statement did not address:
- Whether an online product detail page must display tracking label information.
- Whether resellers of used or secondhand children’s products must add tracking labels.
- A required date or batch number format; CPSC says it has set none.
- Dollar penalty amounts for tracking label violations.
Treat these as open on CPSC’s pages, not as permission either way.
Common Mistakes
- Leaving off the company name. A code and website are fine only with a name a consumer can contact.
- Marking only the polybag. Packaging marks alone are acceptable only for a considered, documented reason.
- Hangtags on clothing. CPSC says hangtags and adhesive labels are not permanent for textile items.
- Treating the FNSKU as a tracking label. It carries no production date, location or batch.
- Citing tracking labels on the CPC. CPSC says no citation is required.
- No written reason for skipping product marks. CPSC asks for one.
Tracking Label Checklist
- Confirm the product is a children’s product using the four statutory factors.
- Decide your lot code scheme: month and year, factory location, batch.
- Print your brand or company name in plain text on product and packaging.
- Choose a permanent method: sewn-in label for textiles, molded, printed or engraved marks for hard goods.
- If the product cannot be marked, write down why and mark the packaging.
- Keep a decoding record so you can identify the specific source if CPSC asks.
- Check that the CPC’s date and place of manufacture match the lot code.
- Keep clear photos of product and packaging marks for an Amazon request.
Frequently Asked Questions
What information must a CPSC tracking label include?
CPSC’s guidance page lists four items: the manufacturer, importer or private labeler name; the location and date of production; batch, run or other identifying characteristics; and any other information that helps ascertain the product’s specific source (data checked 2026-10-13).
Does a tracking label need third-party lab testing?
No. CPSC’s FAQ says the tracking label requirement is not a rule requiring assessment by a CPSC-accepted third-party lab, and is not on the list at 16 CFR 1112.15(b).
Can I use a QR code or website instead of printing the details?
CPSC’s FAQ says a code and website address are acceptable if the manufacturer, importer or private labeler name is also shown, so a consumer without internet access knows whom to contact.
Do small or handmade sellers need tracking labels?
Yes. CPSC’s FAQ says there is no exemption based on business size, though small makers need not create a new batch number system.
Conclusion
A tracking label is a set of permanent marks, not a fixed design. Put your name in plain text, encode date, location and batch however suits your production, mark both product and packaging unless you have a documented reason, and keep the decoding record. Then check the CPC and Amazon’s request wording against the same lot code.