Date code information needs to be reported to the California Air Resources Board (CARB) every year by your company if you do not use CARB’s standard date coding. California Section 94512 (b) product dating specifically requires all consumer products to be sold into the state to display the day, month and year the product was manufactured or a code indicating the date. CARB has been increasing its activity on investigating and levying fines for non-compliance of this section.
The date or date-code information shall be located on the container or inside the cover/cap so that it is readily observable or obtainable (by simply removing the cap/cover) without irreversibly disassembling any part of the container or packaging. Information may be displayed on the bottom of a container as long as it is clearly legible without removing any product packaging.
CARB’s standard code has to be represented separately from other codes on the product container so that it is easily recognizable, i.e.: YY DDD = Year Year Day Day Day. A manufacturer who uses this standard CARB code to indicate the date of manufacture does not have to report this code.
Failure to register a date code is subject to a fine. Every year the fines seem to go up. Your date code explanation needs to be submitted to CARB Enforcement on an annual basis, on or before January 31st of each year. Send to [email protected]
~Doug Raymond, Raymond Regulatory Resources