Product compliance can often feel overwhelming. Certificates, laboratory testing and supplier background check. It makes your head spin.
Perhaps this topic is so overwhelming, that we simply refuse to believe that it applies to us and our products.
We want to believe that the supplier somehow got it figured out, or that the product is already approved by the customs in the US or Europe.
So real that all importers, regardless of product category, can’t afford to make a single mistake when it comes to product compliance.
That’s why I decided to debunk the 5 most common myths about product safety, when importing products from China.
1. The product I plan to import is definitely compliant, because the supplier is already selling the same product in my country.
It makes sense. If a supplier is already exporting goods to the United States, Europe or Australia, their product should be just fine. Right?
That’s what one of my customers thought when they approached one of IKEA’s LED light bulb manufacturers in Ningbo.
Clearly, IKEA cares about compliance, so their products should be set.
We were tasked with verifying if the supplier had the compliance documents, such as test reports and bill of materials.
It turned out that they had nothing. Zip. Not even a test report, proving that their products met any form of safety standard.
What can we make of this?
It’s really simple. Chinese suppliers don’t ‘have products’. They make products according to buyer specifications.
IKEA gives them a design drawing, PCB schematic and bill of materials. The LED factory puts the pieces together. Simple as that.
They don’t need to know that the LED bulb light is wired in a way that makes it FCC or LVD compliant. Or that the components are RoHS compliant.
They just put the pieces together.
It’s up to you, as an importer, to ensure that the design is compliant.
2. I ordered a sample, and it’s already CE and FCC marked. That’s all I need, right?
Many suppliers label their products with compliance marks, such as CE and FCC. They kind of know that compliance marks are important in the EU and US.
And that’s about it.
But a printed CE mark is not magically going to make a toy or electric product become safe.
The authorities in your country know this.
This is why they don’t accept compliance marks at face value. They require that you provide test reports, declaration of conformity and a technical file – to verify that the product is actually compliant by design.
A printed compliance mark means nothing at all, if the product is not technically compliant.
3. The supplier said I shouldn’t worry about compliance, because no other customers asked for test reports.
This is another classic. Many suppliers claim that safety standards don’t exist, because ‘none of their other customers ever asked for it’.
But you shouldn’t listen to your supplier. They are not compliance experts.
Further, their incentive is to get you to place an order. The last thing they want you to do is to ask them to prove that they can make a compliant product.
Most of them can’t.
In the end, it’s up to you if you take advice from your supplier or not. But remember that you are going to be held liable when that power bank explodes in the pocket of a 7 year old.
You will not be able to shift any responsibility to that supplier. They know that too.
I may not be the bringer of joy when writing articles like this one, but I do speak the truth on these matters.
4. The supplier sent me a test report. Is that everything I need?
Test reports are indeed relevant. But only as a way to assess if a supplier is capable of manufacturing a compliant product.
Say that I want to import toys.
I will only consider suppliers with EN71 and ASTM test reports, for previous production runs.
That said, I cannot take an ‘old test report’ and use that to prove that my product is compliant.
Hence, I cannot just ask for a test report. I need to get my specific product lab tested, using samples from the very same batch of products.
5. I contacted the authorities in my country. They said that the manufacturer, not the importer, is responsible for product safety.
This is technically correct. However, when you import any custom designed or private label (i.e., branded) product from a foreign country, the importer is legally defined as the manufacturer.
So, yes, the manufacturer is responsible. And you are the manufacturer.
The actual manufacturer, in China or Vietnam, is not responsible. The authorities in the US, EU or Australia don’t bother going after suppliers in foreign countries.
They go after you.
Reading this might scare you.
Product compliance is actually a lot easier than think. But before we can go into the practical aspects of product compliance, I had to debunk the myths.
Ensuring compliance requires that you take charge of the process. This means that you must find out which standards apply to your product.
And, that you create all certificates and labels. You can issue them on your own. All you need is a computer.
But don’t make assumptions, and don’t take your suppliers advice when it comes to product safety and regulations.
Do you need help to ensure compliance with all mandatory safety standards?
We know how hard it can be to get a grip on product safety standards, labeling, documents and lab testing. To help startups get a grip on the process, and avoid crippling fines and forced product recalls – we created the Starter Package:
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