Consumer Registration Card for Durable Baby Products – Understanding with One Reading

Understanding Durable Baby Products' Consumer Registration Card in One Read

The product registration card requirement for durable infant and child products will help improve the effectiveness and response rate of future recall campaigns. The US Consumer Product Safety Commission (CPSC) has issued precise requirements for the content that must be included on registration cards. The following chart provides an overview of the specific labels and registration requirements that durable infant and child products must meet.

What are durable infant products?

Durable infant and child products are products intended for use by children under 5 years of age or that can be combined with expected use for children, and include one or more of the following:

Tracking Label Requirements for Children’s Products:

Children’s products designed or primarily intended for use by children 12 years of age or younger must have permanent labeling (commonly called “tracking labels”) that provides certain identifying information.

  • The labels must be affixed to the product and its packaging.

  • The labels must provide certain identifying information.

Please note: Importers, manufacturers, and private labelers of durable infant or toddler products are subject to additional product and outer package labeling requirements beyond the basic tracking label requirements discussed on this guidance page.

All tracking labels must contain certain basic information, including:

  • The manufacturer or private labeler’s name

  • The product’s place and date of manufacture

  • Details about the manufacturing process, such as batch or run number, or other identifying characteristics; and

  • Any other information that helps to identify the specific source of the product.

All tracking label information must be clear and legible.

Compliance with tracking label requirements will help improve the effectiveness and response rate of future recalls. It can also assist CPSC staff and companies in the business chain. When a component is identified as the source of a hazard or violation, tracking labels can help identify other products that may contain the same component.

Product Registration Card Requirements for Durable Infant or Toddler Products:

  • Provide a postage-paid product registration card for each product.

  • Maintain a record of the consumer’s name, address, email address, and other contact information for each registered product.

  • Permanently label each durable infant or toddler product with the manufacturer’s name and contact information, model name and number, and the date of manufacture.

What is a durable infant product registration card?

The registration card is designed to allow manufacturers or retailers to contact consumers to provide recall or other safety information. All durable infant products must provide a product registration card.

The product registration card must be attached to the surface of the durable infant product so that the consumer will notice and handle the card after purchasing the product.

The product registration card already contains some information, such as the manufacturer’s name and contact information, model name and number (or other identifier), and manufacturing date. Consumers need to provide their own name, address, telephone number, and email address.

The product registration card must provide consumers with the option to register the product via the internet or email.

What are the current children’s product safety regulations for durable baby products under the Consumer Product Safety Improvement Act (CPSIA)?

All durable infant products must comply with regulations regarding lead content in surface coatings, lead and (in certain cases) phthalate content, testing and certification, registration cards, and tracking labels.

  • Surface coatings: Durable infant products may not use fats containing more than 90 ppm (0.009%) lead.

  • Lead content: The total lead content of any part of a durable infant product that is accessible may not exceed 100 ppm (0.01%).

  • Phthalate content: Any durable infant product that contains plastic parts designed, marketed, or intended for use in facilitating sleep or feeding may not contain more than 0.1% of any of the following eight phthalates: di-(2-ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP), or benzyl butyl phthalate (BBP), diisononyl phthalate (DINP), diisodecyl phthalate (DIDP), di-n-octyl phthalate (DNOP), di-n-hexyl phthalate (DHEXP), and dicyclohexyl phthalate (DCHP).

  • Testing and certification: Like all products primarily intended for children 12 years of age or younger, durable infant products must be tested to all applicable children’s product safety rules by a third-party laboratory recognized by the Consumer Product Safety Commission. Based on the test results, the domestic manufacturer (or importer) of the durable infant or children’s product must issue a Children’s Product Certificate that specifies each applicable safety rule and states that the product complies with those rules.

  • Product and packaging labeling requirements: Durable infant products must permanently mark specific tracking label information on both the product and its packaging. In addition, durable infant products must include their product identifier and product registration card as required by regulation.

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