Fredrik Gronkvist is a co-founder of Chinaimportal, a company that helps small businesses import from China through supplier identification & verification services.
A part of Fredrik’s offer is to help importers understand what regulations and standards they need to comply with. in this Q&A he is sharing his experience about the European Union’s requirements.
Q: Importers who buy products from China want to be “in compliance”. What does this involve?
A ‘Compliant product’ adheres to all applicable, mandatory, and safety standards, regulations, substance restrictions, and labelling requirements. This is a very broad topic, but from a buyer perspective, ensuring compliance involves the following:
1. Confirm applicable product safety standards and substance regulations. These factors must be considered:
- Which standards/directives/regulations apply? In almost every case, there are far more than one regulation to consider — especially for companies trading in multiple markets.
- Is testing mandatory?
- What documentation is required? Often, a test report is just an attachment. It is not the only required document (that is a common misunderstanding).
- Are any labelling requirements part of the regulations? (e.g. CE mark, Country of Origin Labelling, Warning Symbols, or WEEE.)
2. Verify the manufacturer’s existing track record (i.e. their papertrail) in ensuring compliance with the applicable, or related, regulations. As you may know, a supplier’s ability to ensure compliance with American and European safety standards shall never be taken for granted.
3. Communicate all applicable regulations to the manufacturer, and implement a compliance testing/verification strategy.
4. Develop all graphical labelling files (i.e. country of origin label), user manuals, and relevant compliance documents (i.e., Circuit Drawings and Risk Analysis).
5. Submit pre-production and/or batch samples for third party compliance testing.
From the supplier’s side, the following steps are involved:
1. The engineers must understand the specific technical standards to which a product must be compliant. For example, LVD and EMC refer to specific IEC standards, to which a product must comply.
2. The supplier must purchase materials and components from organised subbcontractors. An electronic component is not RoHS compliant by accident, for example.
Q: Have there been changes over the past few years? Are European authorities getting stricter?
Yes. The EU has, as explained by Compliance and Risks in this article, moved from the “information phase” to stricter enforcement. While I don’t sit on official statistics, we do see more and more reports of goods — everything from samples to container shipments — being refused entry by the Customs authorities in the EU. Many issues (often very serious) are discovered only at a later stage, after the products have entered the market.
Attitudes are also changing. Just a few years ago, most procurement managers, even those working for big retailers, had a very vague idea about what product compliance involves and what sort of documents they should request from their suppliers (in the case of a retailer, the suppliers are often importers rather than overseas companies).
Today, these same procurement managers are far better educated on compliance-related matters. The stakes are too high to ignore that topic. However, Chinese suppliers have a lot of catchup to do. Importers are stuck between, on the one hand, strict regulations and the constant threat of recalls and fines, and on the other hand suppliers in Asia who barely understand the basics or EU and US product compliance.
Q: Where can a European importer find the information he needs on this topic?
There are plenty of sources online, including official European Union online databases. However, apart from that there are various company blogs covering compliance topics:
Some information is also provided online by the large product testing companies, including Intertek, SGS, Bureau Veritas and TUV.
Additionally, there are also paid services, for example ProductIP.com.
Q: Are there lessons to learn from some recent cases of batches that got seized or recalled?
Yes. Balance scooters. 15,000 units recalled in the United Kingdom during the first week of December. That recall was made out of a total inspected volume of 17,000 units, which leaves us at a total non-compliance rate of 88.2%. As I wrote above, there is no such thing as ‘accidental compliance’.
About one week later, Amazon.com pulled almost all models of balance scooters. They requested all Balance scooter sellers to produce documents proving compliance with various UL standards. Hence, Amazon has essentially made UL compliance mandatory for all importers of electronics. All of this happened after numerous reports, from around the world, of exploding batteries and chargers lit on fire.
These importers ignored product safety by assuming that the suppliers in China had them covered. They don’t. Chinese suppliers are not, and cannot be expected to be, experts on EU and US product safety standards and compliance requirements. If these companies had been pragmatic, instead of making assumptions, they would not have faced this situation to begin with. But I guess that can be said about many things in business and life.
If you want reach Fredrik, you can send him an email at info (at) chinaimportal.com.