Tracking Labels: Do I have to use batch numbers?
CPSC’s tracking label guidance indicates that if you don’t already use batches, you do not have to invent batch numbers. CPSC has stated that the intent of the batch numbers is so that the manufacturer can look up what materials were used in the batch. The object of batch numbers is so that if one of your products is brought to you, you could look at it and find out what materials were used and where they came from. If you already keep records of your materials and sources and you can tell where each material came from, and you do not already use batch numbers, you do not need to start using a system of batch numbers.
Just exactly what kind of batch record keeping will be required of small volume crafters is unknown. The CPSC guidance document just says that your system should be comparable to similar crafters’, but nobody knows what similar crafters are going to find adequate to meet the law’s requirements.
