| Following a series of tighter consumer protection | | | | enforcement deadlines." |
| laws, makers are emphasizing product safety while | | | | But for small and midsize factories that have less |
| contending with the high cost of compliance. | | | | capital to invest in equipment and prohibitive testing |
| Faced with stricter safety regulations in key export | | | | fees, conformance can be a daunting task. |
| destinations, companies in China are allocating more | | | | Testers can also be partners |
| resources to product testing and emphasizing | | | | The professional testing industry is booming amid the |
| high-quality materials despite the pressure these are | | | | rising safety trend. With the increased need for |
| putting on manufacturing outlay. | | | | product evaluation, the past few years have seen an |
| For most suppliers, adopting complicated and | | | | influx and expansion of third-party laboratories in |
| far-reaching directives is not the main challenge, but | | | | China, including SGS, TUV, BV, Morlab and Pony Test. |
| the high expense of compliance is. | | | | These organizations also provide free training on the |
| Many of the new safety standards require makers to | | | | latest regulations, and inform companies on which |
| conduct more tests on a greater number of chemical | | | | merchandise needs testing and how. |
| substances. As a result, certification fees for some | | | | Regulatory agencies in the US and the EU have |
| products have risen by as much as 50 percent, and | | | | likewise been active in helping suppliers get up to |
| even doubled in a few cases. CPSIA evaluation for | | | | speed. |
| toys, for example, can cost up to $1,000 per model | | | | Workshops on the new EU Toy Safety Directive |
| depending on the complexity of the design. | | | | have been organized, with the support of the |
| The average toy company now spends $60,000 to | | | | EU-China Trade Project and the Directorate-General |
| $100,000 on examination fees every year. One of | | | | for Enterprise and Industry of the European |
| the biggest toy makers in China pays more than $2.9 | | | | Commission. |
| million annually on testing, much higher than the yearly | | | | In October 2009, the third CPSC-AQSIQ Summit was |
| revenue of small suppliers. | | | | held in Wuxi, Jiangsu province. With a theme of |
| Lamp specialist Heshan Mingkeda Industries Co. Ltd | | | | "promoting best practices by Chinese manufacturers |
| spends about $3,000 for SAA certification alone, | | | | and US importers to maximize product safety", the |
| which takes one or two months to acquire, according | | | | summit was attended by CPSC chair Inez |
| to the company's sales manager Mini Yip. | | | | Tenenbaum. |
| In many instances, fulfilling safety requirements | | | | In her keynote address, Tenenbaum reported that in |
| involves replacing infringing materials with compliant | | | | fiscal year 2009, toy recalls went down to 40 from |
| substitutes. | | | | more than 80 in the preceding period. The |
| Suppliers of food-grade products, for instance, have | | | | information exchange between the CPSC and AQSIC |
| already stopped using BPA, an organic compound | | | | about recalls of China-made goods was emphasized, |
| found in many plastics. In a range of consumer | | | | as well as the need for frequent training sessions. |
| goods, further modifications include the shift from | | | | The AQSIQ has been educating China toy makers |
| PVC to POE, and from PC to phthalate-free PES, | | | | about safety requirements in the US and on |
| glass and nontoxic silicone. | | | | strengthening quality controls. The CPSC has arranged |
| Battery makers are striving to develop or source | | | | to set up an office at the US embassy in Beijing to |
| safer anode and cathode materials. Some have begun | | | | help promote compliance with US standards among |
| to replace conventional lithium cobalt oxide | | | | local suppliers. |
| formulation with lithium iron phosphate, an alternative | | | | Local governments and trade organizations are also |
| with lower environmental impact. Other efforts are | | | | vigorously pushing companies to bolster the image of |
| aimed at improving protection against overcharging, | | | | "made in China" products. |
| discharging and heating. | | | | At the Canton Fair last fall, the Ministry of Commerce |
| But in most instances, "safe" alternatives are costlier | | | | distributed export quality and safety manual to |
| than the originals. 3P PVC for instance, is 30 percent | | | | exhibitors. |
| more expensive than regular PVC but is 30 percent | | | | Organizations such as the China Council for the |
| cheaper than 6P. | | | | Promotion of International Trade have been |
| Similarly, A5-grade melamine goes for $2,200 per ton, | | | | sponsoring seminars for business owners and local |
| three times as much as the same volume of the | | | | government officials on product safety in Southern |
| A1-grade variant at about $735. | | | | China. |
| In some cases, imported materials, which invariably | | | | Regulations getting tougher |
| cost more, are favored over domestic equivalents. | | | | The safety bar that China suppliers must hurdle is |
| Imported PP, for instance, is 20 to 30 percent higher | | | | getting higher by the year as new international and |
| than domestic versions, at $1,800 to $2,100 per ton. | | | | domestic standards are put into place. |
| Overseas-sourced organic fabrics, likewise, are 20 to | | | | In December 2009, the European Chemicals Agency |
| 30 percent more expensive than local variants. | | | | announced the addition of 15 chemicals to its |
| Despite the high outlay, some companies prefer to | | | | candidate list of substances of very high concern |
| source abroad for consistent quality. Foshan Geuwa | | | | (SVHC) under REACH. Among the inclusions were |
| Electric Appliance Co. Ltd sources 80 percent of | | | | diisobutyl phthalate, a commonly used plasticizer, and |
| materials and components for its blenders and juicers | | | | lead chromate, a coloring agent. |
| overseas, while the rest are purchased locally. | | | | REACH has wide-ranging impact in the EU as it |
| Besides higher raw material expenses, makers have | | | | requires disclosure of information on hazardous |
| to contend with increases in indirect costs, particularly | | | | substances contained in every product. The directive |
| those related with monitoring the supply chain to | | | | is on top of specific regulations such as RoHS for |
| ensure that all manufacturing inputs meet | | | | electronic goods, EN 71 for toys, and Regulation 1905 |
| specifications. | | | | 2004/EC for materials that come in contact with |
| According to Tim Corrigan, president and CEO of the | | | | food. |
| Quality Assurance Institute, "The root cause of the | | | | For toy makers, the CPSIA/HR4040 in the US and |
| problem (of product quality) is control of the raw | | | | the EU's New Toy Safety Directive or 2009/48/EC |
| material, application contaminations and subfactories. | | | | amend existing rules substantially and impose greater |
| To fix this requires an overhaul at many factories. | | | | restrictions on suspicious chemicals. The latter |
| The solution calls for significant transparency, diligence | | | | regulation limits 19 metallic elements. It also bans 55 |
| and dedication." | | | | fragrant substances and warns against a further 11 |
| Generally, material vendors are able to offer | | | | types. |
| third-party certification. But for those that cannot do | | | | Other baby and children's products and toys must |
| so, companies need to send their own QC staff to | | | | pass the standards for EN 71, CE, WEEE and EMC in |
| supervise the production at the material suppliers' | | | | the EU, ASTM-F963, CPSIA, FDA and UL in the US, |
| factories. | | | | AS/NZS/ISO 8124 in Australia and New Zealand, and |
| More exporters are now limiting their sourcing to | | | | ST2002 in Japan. |
| suppliers that can provide certified inputs. Still, | | | | Following the US and EU's lead, Japan, Australia and |
| collection and documentation of every component | | | | even Malaysia are modifying their existing toy safety |
| utilized requires time, effort and money. | | | | regulations, particularly on flammability and the use of |
| In addition to testing and materials quality, | | | | phthalates and lead. |
| manufacturers are also enhancing their in-house QC | | | | Lithium battery exporters have to comply with |
| facilities. | | | | UL1642 for cells and UL2054 or FCC for battery |
| Lai On Products (Industrial) Ltd, a Hong Kong-owned | | | | packs in addition to EMC and RoHS. Designs shipped |
| maker of crayons, modeling clay and paint has set up | | | | by air are also obligated to undergo UN38.3 testing. In |
| a microbiological laboratory at its factory in Shenzhen, | | | | markets where FCC, UL and RoHS approval are not |
| Guangdong province. Certified by the China National | | | | necessary, passing the UN38.3 is sufficient. |
| Accreditation Service for Conformity Assessment, | | | | For products that come in contact with food, |
| the lab is comparable to a chemical-testing facility. | | | | companies have to comply with assorted standards |
| The supplier also sends its products to third-party | | | | such as UL, CB, CE, GS, ETL, CCC, FDA and LFGB. |
| agencies to ensure compliance with ASTM D-4236 | | | | Most EU countries recognize Germany's LFGB |
| and F963, Toxicological Risk Assessment, EN 71, | | | | because of its stricter requirements. |
| CPSIA, California Proposition 65 and REACH | | | | Aside from international regulations, suppliers have to |
| requirements. | | | | follow domestic guidelines for a number of goods. |
| Some baby stroller factories are now equipped with | | | | Garment trimming makers, for example, need to |
| wheel performance, dynamic durability and | | | | comply with three sets of requirements for cords |
| drop-testing facilities. At the same time, many | | | | and drawstrings to be used in children's clothing. |
| stuffed toys and children's garments makers are | | | | Issued by the General Administration of Quality |
| purchasing more needle detectors. | | | | Supervision, Inspection and Quarantine, and |
| Any measure to comply with safety regulations | | | | Standardization Administration, the GB/T 22702-2008, |
| undoubtedly adds to the cost of production. Suppliers | | | | 22704-2008 and 22705-2008 are based on US' ASTM |
| estimate material and certification expenses have | | | | F 1816-97(2004), the UK's BS 7907:1997 and EN |
| risen about 10 percent in recent months. Many | | | | 14682:2007, respectively. |
| companies try to absorb the additional expenditure, | | | | In addition, some existing national standards for |
| but this is not always feasible. | | | | trimmings have been revised and now have |
| While investment in facilities can be recovered in the | | | | provisions that monitor and prescribe allowable levels |
| long term, the same cannot be said about testing | | | | for harmful substances that are even lower than |
| fees. When order quantities are low, as in the current | | | | European regulations. The GB/T 17592, for example, |
| environment, makers are often unable to recover | | | | keeps azo content at 20mg/kg whereas it is 30mg |
| money spent on certification of specific models. | | | | kg in the EU's EN 14362. |
| Shorter product life cycles due to fast-changing | | | | Likewise, the China government issued a new |
| customer preferences also give manufacturers a | | | | standard for melamine-formaldehyde products used |
| narrower time frame to recoup compliance outlay. | | | | as food containers and packaging materials. This |
| Some suppliers try to negotiate bigger orders or ask | | | | comes after several foreign markets banned low-end |
| buyers to shoulder the cost for certification. But | | | | models due to potential chemical leaching. |
| clients are averse to both options in view of the | | | | The regulation seeks to ensure safety by prohibiting |
| current economic conditions. | | | | the use of urea formaldehyde resin as the main |
| Typically, tier 1 manufacturers are able to comply | | | | material. A1 and A3-grade melamine dinnerware |
| with regulations more seamlessly due mainly to their | | | | pieces, which contain 70 to 90 percent of this |
| stable financial resources. | | | | substance, tend to melt at high temperatures and |
| "Enterprises that cater to major OEM customers | | | | may cause a health hazard. |
| likewise have the easiest time adjusting to the new | | | | To ensure compliance with the safety code, the |
| rules as they have better access to information," said | | | | government has required suppliers to obtain a |
| Cody Wang, chemical testing deputy general | | | | production license from the General Administration of |
| manager at Intertek. "They are usually able to make | | | | Quality Supervision, Inspection & Quarantine. |
| the necessary changes months in advance of | | | | |