Tracking labels: What does “permanent” mean?
According to CPSC’s tracking label guidance, “permanent” means reasonably expected to “remain on the product during the useful life of the product.” Labels on packaging meant to be thrown away only have to be as permanent as the throwaway packaging.
A label that can be removed by defacing the product is still considered “permanent” if it wouldn’t come off during ordinary use. Clothing labels are considered “reasonably expected” to remain on the clothing because they don’t fall off by themselves; the fact that people sometimes cut them out or accidentally rip the seams they’re sewn into is immaterial.
