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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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