I received a message from a potential client who is starting to import garments into the US. I broke it up in different parts, and I inserted my responses below. It might be helpful to other importers wondering how to comply with their country’s regulations.

I have run into manufacturers who ask me if I have a quality manual for testing and are negotiating who is responsible for the testing of the swimwear (manufacturer or my company).

There are 2 ways to deal with this:

-1- The safe way

You get the list of appropriate tests, you select a laboratory (you pay their fees and you receive all test results directly), and you ensure the samples sent to the lab come from production.

For extra safety, an engineer from an inspection firm can go and pick up a few products randomly during production, and at the same time perform a quality check on some samples. The advantage of doing this during production is that quality issues can be noticed and corrected early, without incurring significant shipment delays.

-2- The not-so-safe way

You trust the supplier, and they send you either a certificate that your products comply with all US regulations or some test results from a laboratory of their choosing. None of these documents is fool proof.

The problem with a certificate is that it does not protect you, so the supplier can sign whatever you want without incurring significant risks. There is virtually no way of sending a shipment back to China for refund, or to sue your supplier for compensation (except if you had them signed a contract drafted by a specialized lawyer and enforceable in China).

The problem with a lab test result from the supplier is that you don’t know if the products making up your shipment would give the same results, were they to be tested.

They are looking for guidance from me about test standards.  Do you know where I could find a “standard manual” and what manufacturers normally test for?

The best is to ask a large testing laboratory. They know what types of tests should be performed for about any category of product shipped between any two countries.

To be very clear… The results of these tests will show if the samples received by the lab comply with all the regulations of the importing country. These tests are highly advised. Not every importer bothers to do them, but they are taking risks.

In addition, is this testing to pass certain US custom restrictions?  Can you advise or give me some guidance?

You are importing garments, not very sensitive products. I don’t know of any custom restriction in the US, other than import duties or maybe import licenses (aka quotas). Your custom broker or your forwarder can give you more information about trade restriction issues.

What is clear, though, is that your country does not tolerate certain chemical substances and does not want any product that might harm consumers (for example, long strings that might strangle a kid). The testing lab will give us some indications as what is forbidden.