FLPA (Fair Labeling Product Act) Question

To those knowledgeable in this, one of the Christmas ornaments I sell is typically hand-wrapped and then boxed in plain packaging. However, this year it has sold well enough for me to have it boxed from the manufacturer.

I would like to adhere to FLPA as much as possible.

I know the item must be clearly labeled, qty described, country of origin noted, and the part I have a specific question about is the company address.

Currently, I do everything out of the home. For obvious reasons I would like to not use this address. Can I use a PO box? Do I need to register this somehow to be able to use this on the packaging? Any tips or a point in the right direction would be grrrrrreeeat.

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If the PO Box belongs to the business (the post office has the PO Box under the businesses name), then yes.

We use a PO Box. Costco uses a PO Box on their items. We are sure, if you look around your house, that you will find your own examples of PO Box usage.

But we would Google (research - lookup) your items requirements to make sure you meet all of the labeling requirements for your item.

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Gracias, off to the post office I go.

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My opinion, others may differ. If you read the FLPA carefully, as long as the customer can find you with ease, it is not an issue.

Our packaging includes, our company name, registered with the state. It includes our brands (we have several) websites. We also have our 800 number on our trade dress and products when appropriate.

The FLPA indicates, that if it easy to find and contact the company of the product, this is enough.

From a practical point of view, we manufacture markers that are ATSM D-4236 safe for humans and animals. We have had customers contact us where a child has used them on their skin. While not approved for that, it is safe for humans and animals.

Again, our 800 number, our town and state, and website is on the product. Not our street address, or other detailed information. Since the law, allows us to do this as long as we can be found with ease.

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Agree

Even to the point that it is just Company Name / Town / State is acceptable.

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Thank you for the support, not for me but for others that are researching this issue.

As long as you (the Corporation, LLC, DBA, you personally) can be found what you wrote, that I quoted above is enough.

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To look more professional, you do have the option of just putting city / state where you operate out of + a working phone #. That’s what we do. Got a FreedomVoice account, $10 a month.

Just another option for you.

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You may. Also for consideration instead “Manufacturer:” Consider language such as “Packaged for:” or Distributed By:"

(1)The commodity shall bear a label specifying the identity of the commodity and the name and place of business of the manufacturer, packer, or distributor;

Also, from the FTC’s Rules, Regulations, Statements of General Policy or Interpretation and Exemptions Under the Fair Packaging and Labeling Act Federal Register / Vol. 80, No. 221 / Tuesday, November 17, 2015 / Rules and Regulations

Long Excerpt

Based on its consideration of the
record, the Commission amends the
Rules as explained below.
A. Modernize the Place-of-Business
Listing Requirement
Currently, the Rules require a label to
conspicuously state the name and place
of business of the manufacturer, packer,
or distributor and further specify that
the place of business statement contain
the street address, city, state, and ZIP
code. The street address, however, may
be omitted if it is listed in a current city
or telephone directory.24 The
Commission proposed revising this
exception to permit a business to omit
the street address if it is listed in any
readily accessible, well-known, widely
published, and publicly available
resource, including but not limited to a
printed directory, electronic database, or
Web site. The inclusion of ‘‘any readily
accessible, widely published, and
publicly available resource’’ in the
exception provides flexibility and is
intended to encompass new
technologies that meet these
requirements.
All the comments addressing this
proposal supported it.25 One individual
suggested that the Commission delete
the requirement that certain business
entities use their ‘‘actual corporate
name’’ (as opposed to their fictitious or
doing-business-as name). However, he
acknowledged that the requirement did
not burden business and he did not
demonstrate any benefit associated with
his suggested amendment.26
Accordingly, the Commission adopts its
proposed amendment without change.

Short version: The street address, however, may be omitted if it is listed in a current city or telephone directory

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Perfect, I think I will go with the non-address approach in that case. Thank you for all the help guys.

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