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In this week’s product guide, we share our expertise on children’s and baby clothing manufacturing in China. What may not come as a surprise, especially not for our regular readers, is that the emphasis in this guide lies on product compliance: including substance regulations, labelling requirements and physical properties. In addition, we also explain what you must know about product testing – and why importers in this field are wise to stay away from ready made ‘off shelf’ items.
Challenges When Importing Children’s & Baby Clothing
Children’s products, including clothing, are strictly regulated in all major markets, including the United States, Australia and the European Union. Noncompliance penalties are severe, and range between US$5, 000 to US$100, 000, per violation, in the United States. Penalties in Europe, for example the United Kingdom, are slightly lower, but can result in imprisonment of up to 6 months, and a fine of £5,000 per violation. That is, of course, in addition to the obvious fact that all non-compliant baby and children’s clothing are subject to an immediate forced recall.
Who is responsible to ensure compliance, when importing baby and children’s clothing? The importer is, without exceptions. This responsibility cannot be shifted to a foreign manufacturer. Ensuring compliance is therefore the core challenge when importing baby and children’s clothing, and even more so when the items are sourced in China.
First, most Chinese suppliers, in the industry, are not able to comply. As I will explain further in this article, regulations in this area apply to various elements: including substances, physical properties and labelling. In order to even be able to comply, a manufacturer must meet the following:
Has previous experience manufacturing items according to the ASTM (US) and ISO (EU) standards.
Has fabric and component subcontractors able to control substances (e.g. lead and phthalates).
Many, if not most, Chinese manufacturers are not primarily geared towards Western markets. As such, they have no real incentive to ensure compliance with applicable standards and regulations in these markets. This is also why finding the right, e.g., compliant, suppliers, is such a challenge.
Many suppliers on the market are not real manufacturers, but trading companies. Small businesses tend to favor such traders, as they tend to offer slightly lower Minimum Order Quantity Requirements (MOQ), as compared to manufacturers. However, the items traded are in general off the shelf goods made for the domestic Chinese market – which are not manufactured in compliance with US and European regulations.
Therefore, importers of children’s and baby clothing are left with one option: ordering exclusively from manufacturers that can show extensive, previous compliance, with the relevant regulations. This is indeed affected the MOQ requirement, often ranging between 500 to 1,000 pcs. That is quite a bit for a Startup, but then there are ways to reduce the MOQ.
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CPSIA (US), California Proposition 65 (US), EN 71 (EU) and REACH (EU) restricts usage of various substances, including lead, cadmium and formaldehyde (a chemical found in textiles). Many Chinese manufacturers struggle to comply with these regulations, as the content of chemicals are not directly in their control. Fabrics and other components, such as zippers and buttons, are purchased from subcontractors, and not made ‘in house’.
For a supplier to be compliant, they must already have established relationships with rather sophisticated fabric subcontractors that are capable to ensure said compliance. Many are, however, not able to do so.
You can never be sure that a batch is compliant, until you have a testing report in your hand proving that so is the case. Instead, it’s all about risk management. A supplier that can show extensive compliance (e.g. several recent test reports) is very likely to ensure compliance, while a supplier that is unable to provide any testing report, is quite unlikely to possess this capability.
Physical Property & Flammability Standards: Buttons, Seams and Zippers
In addition to substance restrictions, physical properties are also regulated, in the US, EU and Australia. CPSIA, for example, is not a uniform standard which regulates all elements of an item. Instead, it refers to various industry standards developed by ASTM, which in turn apply to specific products. In the European Union and Australia, importers are required to ensure compliance with ISO standards. Below follows a brief, but incomplete, overview of relevant ASTM and ISO standards:
ASTM F1816-97 (2009) Standard Safety Specification for Drawstrings on Children’s Upper Outerwear
ASTM D6545-10 Standard Test Method for Flammability of Textiles Used in Children’s Sleepwear
General Product Safety Directive 2001/95/EC (GPSD) (Read more)
EN 14878:2007 Textiles – Burning behavior of children’s nightwear – Specification
EN 14682:2007 Safety of children’s clothing — Cords and drawstrings on children’s clothing
Labelling Requirements: Washing labels, Country of Origin and Fiber Content
Each market has its own labelling requirements, some of which apply to all products, while other concerns only textiles, and children’s clothing in particular. Noncompliance all applicable labelling requirements is enough of a reason for customs authorities to quarantine a shipment, so you better take it seriously. Depending on your location, the following must be considered:
Country of Origin
That said, ensuring compliance with labelling requirements is very simple, compared to the complexities and risks surrounding substances, flammability and physical properties. However, never assume that the supplier is aware of how a product must be labelled in your market. Instead, importers must provide a ‘ready made’ design file (e.g., in the .eps format), including the following:
Compliance Testing is Often Mandatory
Unlike clothing made for adults, substance testing is often mandatory when importing children’s and baby clothing. Clearly, such testing does not come free of charge – and the importer is always expected to finance them. Not the manufacturer.
Testing companies, such as SGS and Asiainspection, charge based on the number of variations, not per item. An item made of the very same fabric, but in two different colors, are therefore counted as two tests. As a result, the substance testing costs are entirely based on the number of different fabrics and colors. Assuming you buy a number of items, all made of different fabrics and in various colors, the bill may add up to thousands of dollars – per order!
This is a major issue for small to medium sized companies.
The only solution to this, apart from setting up your own testing facility, is to streamline the number of materials and colors. In other words, use the same fabrics, and colors, on as many products as possible. In addition to cost reductions, this strategy also has several other benefits, as outlined in this article.
Children’s & Baby Clothing Manufacturer Checklist
Compliance is certainly the main qualification criteria, of which a children’s and baby clothing manufacturer shall be selected. It’s rather pointless to even consider pricing, material quality, and quantity requirements before you have confirmed that a manufacturer belongs to this, small, group. For this reason, I have divided the qualification requirements in two:
Primary qualification requirements
Is the supplier registered as a baby and children’s clothing manufacturer? (As specified in their registered business scope)
Can the supplier show relevant substance testing reports?
Can the supplier show relevant ISO or ASTM testing reports?
Can the supplier manufacture a label according to the buyer’s specifications?
Secondary qualification requirements
Materials and component quality
Social compliance protocols and Audit reports
Quality Management Systems
Compliance is, as I’ve repeated about a hundred times now, critical, but it is not necessarily a guarantee of a ‘high quality’ product. Visit the articles below for further reading about clothing sourcing and product development in China:
Co-founder of Asiaimportal (HK) Limited and based in Hong Kong. He has been quoted in and contributed to Bloomberg, SCMP, Alibaba Insights, Globalsources.com, China Chief Executive, Quartz Magazine and more.
Hey there, I’m Fredrik!
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