A few days ago I got the following question from a reader:
We import Consumer Electronics and would like to check that products have not changed components from the original CE and that they still pass CE requirements.
That’s a great question. Getting a certificate based on a pre-production sample is one thing, and ensuring the final product is compliant is another story.
Here was my response:
There are basically 4 options for you. I have listed them from the most to the least risky.
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Check nothing in production, and trust pre-production certificates. This is pretty risky, as I wrote before.
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Add a checkpoint a final random inspection: “open the product, look at the components and their labelling, and check if they are the same as on the CDF”. (Note: when we do it at the same time as an inspection, there is no extra cost).
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In addition to point 2, run a few lab tests (on random batches) on the most critical/sensitive components. If you are selective, this might not be very expensive.
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In addition to point 2, run lab tests on all components and for each batch. That will probably be expensive. But this way you can sleep better at night and not worry about your country’s Customs office investigating your company.
Do you agree that these are the best 4 options?
Disclaimer
We are not lawyers. What we wrote above is based only on our understanding of the regulatory requirements. QualityInspection.org does not present this information as a basis for you to make decisions, and we do not accept any liability if you do so.
Renaud,
There may be another thing possible between your point 1 and 2: require a signed/chopped product compliance certificate by the supplier. This document certifies that the product provided by supplier for this specific order are compliant to a list of standards defined.
It is not much more than the pre-order certificates, but at least the supplier cannot claim it did not know the requirement for each specific order.
Good idea. Thanks!
There are lots of things like this that are both free and useful.
I have heard about one importing company that came up with an incentive for the Chinese manufacturer to spend more effort on consistent quality and respecting regulations and standards: they paid a bonus to the manufacturer if the batch meets the agreed design specifications and standards. The importing company would take a random sample and verify.
Quality and compliance has a price, and it is the importers that should be willing to pay a bit more for less headaches later.
I am sure many people thought about it, but I had never heard of a company that actually put it in practice. I am a big proponent of always distinguishing quality and pricing in negotiations with suppliers.
I would be afraid of 2 perverse effects:
– If the goods are below the client’s requirements, does the supplier understand that he did something wrong?
– If the importer inspects the products with a testing/inspection agency of his choice, how can the supplier believe that the importer hasn’t given instructions to be very tough?