By Fabien Gaussorgues
This is not obvious for new buyers, but laboratory testing is something you need to consider when importing products from China. It should be integrated in your project from the beginning.
Here are the basics you need to know in order to avoid heavy mistakes.
What is the difference between a “certification” and a “test report”?
Many buyers and suppliers mix them up or are confused. Many times I was sent an SGS basic RoHS test report, presented as a high-level certification from suppliers. But I can buy a product in a store, send it to SGS, and get the same report.
In fact, a test that was not done on the exact product you are buying has close to zero value. A lab test is performed with the purpose of validating the compliance of a few samples to a certain standard.
In contrast, a certification is the validation of a process and/or product, and it often comes with a higher official value. For example, a UL certification (or a “UL listing”) includes regular audits of the factory in addition to the product tests, to ensure those tests are valid over time and the manufacturer follows defined processes. A simple test based on the same UL standard has lower value when it comes to regulatory compliance.
If your supplier gives you a certificate, always make sure it was done on the same type of product as you are buying. When we inspect electrical products, we tend to check if the marks/branding of the components are the same as shown in the certificate (that part of the certificate is called the ‘CDF‘).
When does it make sense to conduct laboratory tests?
As you purchase a new product, lab tests make sense (and, in principle, must be done) in two stages.
First, after all the development work is over and before mass production starts, you need to ensure the product design complies to regulatory standards — an example is electromagnetic test (FCC, EMC). Another example: for non-electrical toys, a number of safety-related tests apply (ASTM F963, EN 71…).
If a test fails at that stage, additional development work are probably needed.
The second stage is when mass production is under way. You need to confirm production complies with regulatory standards such RoHS, ‘food grade’, or California Prop. 65.
Many experienced buyers run tests on each and every order, at these two stages, in order to ensure no change took place. If you don’t, you are taking risks. Chances are that you are considered as the ‘manufacturer’ (and you carry all related risks) in your country if you are the company that brings some products to market.
Some more advice for importers on this topic
Here are a few general rules:
- Never use a laboratory proposed by your supplier. They could bribe the lab for positive results. And some Chinese labs’ sales staff promise to local factories “don’t worry, we guarantee you get a passed report that you can show to your customer”.
- Test production samples that are randomly selected by a third party. They should never be ‘chosen’ by your supplier. The risk that they send a different product (either from another batch, or made separately with different components and/or a different workmanship) is too high.
- Select a lab with an ISO 17025 certification issued by a reputable organization, or use a famous international lab.
- If practical, select a lab that is close to your supplier. It will save time in your overall process and will reduce logistical risks. There are labs virtually everywhere along the coast in China if you work in a common product category.
- Smaller, local labs are often cheaper than international labs. Some local labs are suitable for very standard tests, but are generally not recommended for very specific tests (for instance, checking the chemical composition of a compound).
- A laboratory’s fees can start from less than 100 USD for a simple test, and can exceed 100,000 USD (with certification lead times of 6 months) for advanced safety regulations. Careful planning and budgeting is a critical part of the process.
- In highly regulated industries, you have to budget for much higher requirements, testing fees, and lead times.