Children's products sold in the US must carry tracking labels: permanent, distinguishing marks on the product and its packaging, to the extent practicable. CPSC guidance says they must make certain information ascertainable: the manufacturer, importer or private labeler; the location and date of production; detailed information on the manufacturing process, such as a batch or run number; and any other information that helps identify the specific source, such as the plant address.

Decide what goes on the garment and the packaging

The requirement applies to both the product and its packaging, to the extent practicable. For a T-shirt, that usually means information on a sewn-in label or a printed label, plus the polybag or retail packaging. CPSC treats a permanent mark as one that can reasonably be expected to remain for the product's useful life. A paper hangtag alone would not meet that on the garment itself.

Make the batch information meaningful

A batch or run number is only useful if it actually identifies a production run. Agree with the factory how batch numbers are assigned, for example by cutting order or production date. Make sure the number on the label can be matched to its production records. Keep those records available, because the purpose is to trace a product if there is ever a problem.

Combine it with the other labels

Children's tees also need the labels any garment needs. That includes fibre content, origin and manufacturer or dealer identity under 16 CFR Part 303, and care instructions under 16 CFR Part 423. Many brands put tracking information on the same label or a second label beside it. Plan the whole label set at development so you print it once.

Responsibility

CPSC states that the domestic manufacturer, or the importer of record for products made overseas, is responsible for compliance with the tracking label requirement. If you are the importer, this is your obligation even though the factory prints the label. Check the current requirements and any other rules for children's products in your category before production.

Finally, keep a copy of each label version with the batch numbers it was used for. If a retailer or authority ever asks which products came from a given run, you can answer from your own records rather than relying on the factory's.