Pennsylvania Toy Registration - FAQ
Registration Questions
Q.Are there any safety concerns with the new Micro Polystyrene Foam
Beads being used in a number of different products.
A.The very small polystyrene foam beads have become very popular as
filling material in all types of products. Toys and pillows presents the
biggest concern because of the possability of a chocking hazard with small
children. Therefore, IABFLO is recommending that these beads be inner-bagged.
Q.What states issue Uniform Registry Numbers?
A. There are 32 states that have labeling and/or registration laws in
effect at this time. Also, there are 25 states that require special labeling of
secondhand articles. The major registration states are: California, Connecticut, Massachusetts, North Carolina, Ohio, Pennsylivania, Texas, Urah, and Virginia. All of the other states will
accept a registration number from these states.
Q.I have a uniform registration number from one state, it is printed on
my law label, why am I in violation in your state for not being registered?
A.The first state that you register in will issue you a registration
number. You then print that number on your law labels and you can sell your
products in that state only. If you want to sell product in other states that
require registration, you must register in each state separately. They will
accept the registration number from the first state and will not issue you a
new registration number.
Q.Do I need a new registration number for each product or can I sell
different products under the same number?
A.You do not need a seperate registration number for each product as
long as they are made by the same manufacturer. The number represents the
manufacturer, not the product.
Q.I am an importer, does each manufacturer that I deal with need a
different registration number.
A.YES, each manufacturer needs their own registration number. The
registration number identifies the manufacturer of thier line of products.
Q.Why do some states require both the manufacturer and importer to be
registered?
A.Several states require that you report and pay a fee on the number of
products that were shipped into their state. Some states require that you
estimate what you will sell in their state and send the fee up front. Others
base the fee on what you have sold in that state over the past 6 months to a
year. The per item fee varies from state to state. For example, Pennsylvania is two & half cents, Ohio is four cents and North Carolina's fee is based on the number of
mattresses sold.
If the manufacturer does not ship their products directly into a state and uses
an importer to distribute product into a state, both the manufacturer and
importer must be registered in some states. The company that brings the
products into a state may be responsible for paying the per item fee.
Q.How long is my license good for?
A.In most states your license is good for one year. In the state of California the license is good for two
years. Your license renewal is normally due one year for the date that you
first registered in the state. Example: if you registered in July you would
need to renew the following year in July. Nowever, their are a few states that
go by the calender year. They only renew licenses at the end of the year
regardless of when you were issued the license. Example: if you registered in
October, your license would be due again at the end of December. That first
year your license would only be good for three months.
Q.Why do some states require you to register and other states do not?
A.The laws are intended to protect consumers from unknowingly purchasing
products that are unsafe, unsanitary, not labeled or labeled incorrectly. The
laws also protect reputable manufacturers from competing against unscrupulous
businesses that have no reguard for consumer safety. Unfortunately, some states
lack the resources to provide a meaningful enforcement program and their laws
have been allowed to become inactive and eventually removed from the state
enforcement code.
Q.Why are some states requirements different from other states?
A.Each state has jurisdiction over how it enforces their laws. In most
cases, the state legislature has reacted to a specific problem that has been
encountered in that state.
Law Label Questions
Q.Where does my law label have to be attached to my product?
A.The label shall be securely attached to an outside seam and must be
clearly visible to the consumer at time of purchase.
Q.What size does my label have to be?
A.The minimum size for a bedding and furniture law label is 2 inches by
3 inches. It may be larger as the need demands.
The size of a toy law label is left to the discretion of the manufacturer.
Q.What type of material can the law label be printed on?
A.For a bedding and furniture law label, it shall be white with black
print and printed on Tyvek, Vellum cloth, cloth or of comparable quality
material which will not flake when abraded.
The form, design, color and size of a toy law label is left to the discretion
of the manufacturer, provided that the information required on the label is
clearly legible.
(Please check examples of a bedding and toy label listed under Uniform Bedding
and Toy Law Labels on this site)
Q.Is it required to have a company name and address on the law label?
A.There are a few states that do not require a name & address, but
most do. You can use the following options: MADE BY, MADE FOR, IMPORTED or
DISTRIBUTED BY and SOLD BY.
The name & address is optional on a toy law label.
Q.What can be listed at the bottom of the law label under "Other
Information"?
A.This section can be used to list the following: Date of Delivery,
Finish Size, Weight of Filling Material, All Federal Requiewments including
Federal RN number, and Country of Origin.
Q.Can I print a UPC bar code on the law label?
A.YES, but it must be done at the bottom of the law label, seperated by
a thick black line so it it made to look like two labels.
Q.Can I use the same law label both in the U.S. and Canada?
A.NO, a U.S. law label can not be used in Canada and a Canadian law
label can not be used in the U.S. Items sold in Canada must meet Canadian
federal labeling requirements, as well as any provincial requirements.
The uniform law label used in the U.S. must be in English only while
the Canadian label must be in English and French.
Filling Material Terminology
Q. Why can't I use the same name on the law label that the manufacturer
uses for the material?
A.Only generic terms may be used on the law label. Industry uses
tradenames to recognize their particular line of filling materials. Tradenames
can not be used to discribe filling materials on a law label. When generic
terms are used, industry derives a measure of fairness and the consumer is able
to shop wisly by being able to compare like materials.
Q.If I manufacturer furniture or bedding what filling materials do I
need to list on my law label?
A.For furniture & bedding all hidden filling material must be listed
on the law label. If the product contains more than one type of filling
material, the percentage by weight of each must also be listed in the order of
it's predominance.
For mattresses and furniture cushions that contain a spring unit, they must be
listed on the law label as "SPRING UNIT" or "INNERSPRING
UNIT" but no percentage is required.
Note: THE FOLLOWING DOES NOT
NEED TO BE LISTED ON FURNITURE & BEDDING LAW LABELS: Burlap, Tape, Webbing,
Paper Separating Sheets, Glazed Wadding, or Embroidery.
Stuffed Toy Law Labels
Q.What filling materials do I need to list on a stuffed toy law label?
A.All hidden filling materials must be listed on the law label but NO
percentages are required. If there is any type of wire or plastic stiffeners in
the toy they also must be listed. Any material such as sand, plastic pellets,
rice, etc, etc used to add weight to the toy must also be listed.
Q.What size does a toy law label need to be?
A.The size, shape, design and color is left up the manufacturer. The
print size is also left up to the manufacturer, but it must be of sufficent
type size so the consumer can readily read the print.
Q.What other information must be listed on a toy law label?
A.The following must be stated on a toy label:
ALL NEW
MATERIAL
Then list the Hidden Filling Materials
Next list your registration number, Example: Reg. No. PA 12345 (CN)
If the product is made in another country you need to list country of origin:
MADE IN........
You may have other information on the label such as: company name &
address, age limit, or washing instructions.
Note: THE FOLLOWING DOES NOT
NEED TO BE LISTED ON A STUFFED TOY LAW LABEL: Rattles, Squakers, Noies Makers,
Music Boxes or Chips, Mechamical or Electronic devices.
The U.S. Pennsylvania Stuffed Toy Law
As specified in Title 34, Chapter 47.317,
Tolerances of the Commonwealth of Pennsylvania Regulation for Stuffed Toys, the
stuffing materials in toys are considered to be inconformity if:
1.
Material of sufficient size to visibly reveal a pattern,
weave or other mechanical unification of threads to indicate prior use of a
previous manufacturing process.
2.
Dirt and/or other foreign matter in excess of one percent
(1%) by weight.
3.
More than one percent (1%) oil or grease.
4.
More than 0.002% lead as (Pb) - (20 parts per million).
5.
More than 0.0002% arsenic - (2 parts per million).
6.
More than 5.0% ammonia.
7.
More than 1.0% urea.
8.
Plastic or metal ornaments such as eyes, nose, etc., not of
a safe design or not attached to the stuffed toys in such manner as to prevent
removal.
9.
Stones or other hard materials having jagged or sharp edges.
10.
Material bearing electrostatic charge with adherence
characteristics which when exposed could lodge in the windpipe, ears or
nostrils.
11.
Filing material which surface burns at a rate of less than
three (3) seconds for twelve (12) square inches.
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