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If lab testing is not always mandatory, why do importers still submit their products for compliance testing?
First, a product must always be compliant. A third party lab test is the only way to verify that the product actually is compliant. While non-compliant products may get through the customs, they may be subject to a check later on.
If it turns out that your products are non-compliant, they will be subject to a forced recall. In other words, total disaster for any startup or small business.
For some products, such as toys and electronics, you must pay on a per design or SKU basis. Hence, two different SKUs, even with the same materials and components, must be tested.
However, when importing apparel, one test report per material might do. Hence, the final cost also depends on the type of product. Below follows a few cost examples:
100% Cotton Fabric, 2 colors
100% Cotton Fabric, 4 colors
Lithium power bank, 1 model
Stuffed animal, 1 model
EN 71, ASTM
While an extra color or material may not double the cost of lab test, it can add on anywhere from 20% to 50%.
How can we keep the testing costs as low as possible?
As the costs are based on the number of regulations, SKUs, colors and materials, you can lower your laboratory testing costs by applying the following methods:
a. Limit the number of markets you enter at a given time (hence, you need to comply with fewer regulations).
b. Launch a lower number of SKUs
c. Use the same colors and materials on as many SKUs as possible
Can’t we just use one of the suppliers test reports?
While a suppliers existing test reports are crucial for assessing if they can produce compliant products, you can in most cases not use old test reports as proof of compliance of the products you order at a later date.
Showing outdated test reports, or those that cannot be linked to your products, can result in the goods being seized by the customs authorities.
Do I need to get my products tested in my own country?
As such, many importers prefer to use laboratories based in Mainland China and Hong Kong, as it makes sample submission much faster.
You can therefore instruct your supplier to submit samples within the country.
Today, all major European and American compliance testing companies are present in the greater China region.
What should I look out for when selecting a compliance testing company in China?
You should only work with well known and established compliance testing companies, that are accredited in the United States and the European Union.
In fact, many countries only recognize test reports from accredited testing companies. You can find lists of accredited compliance testing companies on various government websites.
In addition, you can also use this checklist when selecting a testing company:
1. Do they offer compliance testing for the standards and regulations that your products must comply with?
2. Do they have experience with your product category?
3. Do they have a facility in Hong Kong S.A.R or Mainland China?
Should I book the test directly with the lab, or should the supplier manage this?
You should never let your supplier book the lab test for you. There are a few very good reasons for this:
a. They may select a non-accredited testing company. Thereby providing useless test reports. They may also forge test reports or bribe the testing company to produce a favorable result.
b. The supplier may not be aware of the regulations that apply in your market. Hence, they might order a test that is not corresponding to the regulations, safety standards or chemical restrictions in your target market.
c. You will end up paying for the test regardless. If you allow your supplier to book it for you, there is less transparency and you are exposed to the risks explained in a and b.
How do I submit product samples to the lab?
You can either deliver samples by mail to the lab testing company, or instruct your supplier to do so. Before you or the supplier submit samples to your testing company, you need to confirm the following information:
1. Contact person, phone number and address
2. Sample identification number / code
3. The number of samples required
That said, if you do let your supplier send the samples directly, be sure to get product photos or any other type of identification. There are stories of suppliers sending ‘made for compliance testing’ samples, only for the sake of passing lab testing – which don’t represent the batch as a whole.
Can a quality control agent handle testing while in the factory?
A common misconception is that quality inspections also involve product compliance checks. That is rarely the case, as compliance testing require expensive and bulky equipment, that is not exactly portable.
Further, it also requires expertise that is only possessed by chemical or electrical engineers.
That said, your quality inspection agent can collect samples from the batch, and later submit them to the testing company. That way you can be sure that the samples come from the ‘right box’.
How do I know what kind of tests I need to sell the product in my market?
Lab testing is done to prove compliance with one or more regulations or standards. Hence, you need to confirm which regulations and standards (i.e., REACH or CPSIA) apply to your product, in your market.
Most compliance testing companies can provide some basic guidance, but hire a consultant and contact the authorities in your target markets before you import products from Asia.
That being said, lab testing is not the only thing to take into consideration when it comes to product compliance. You may need to issue additional documentation, and most products are also covered by labeling requirements.
How many product samples should we send?
The testing company needs a certain number of samples per material, color, SKU and test. At a minimum, you will need to submit 3 to 4 sample units to get the product tested.
Confirm the number of samples required, with your testing company, and instruct your supplier accordingly.
Will we get our samples back after the test?
No, the samples are in many cases destroyed as a result of the compliance test. Hence, you cannot expect to get them returned.
There are exceptions though. Prototypes that undergo general checkups or a certification process (i.e., electrical systems that are EMC tested) must not necessarily be destroyed.
How long does it take to get the result?
It normally takes around 1 to 2 weeks, before the lab test is completed and the report can be issued. These days, test reports are mostly delivered digitally, rather than by post.
What can I do if the test fails?
In case the product fails to pass compliance testing, you need to work out the situation with the supplier. In some cases, the non-compliance can be resolved by replacing a certain component or material.
However, in some cases, it is impossible to ‘make’ a product compliant, especially when it comes to issues relating to chemicals and heavy metals.
In such cases, the supplier must remake the entire batch of products, as the entire batch is likely affected.
Do I need other documents than the test report?
Product compliance often involves much more than just lab testing. As mentioned, for some products, lab testing is mandatory – but for most it is not.
As such, it is up to the importer to decide whether or not to get the product tested.
Even in the cases when lab testing is not mandatory, additional product documentation may be so. In addition, most products are also subject to labeling requirements (i.e., Made in China label and CE mark).
In the European Union, many products are subject to CE marking, which requires the buyer to draft a technical file – including design drawings, bill of materials, risk assessment, user instructions and much more.
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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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