As the client’s purchasing agent on the ground in China, it’s not just factories that PassageMaker coordinates. For example, during the product development phase, we often help clients confirm which certificates are required to sell a given product in a given market. Safety certificates are especially important for importers of electronics, toys, medical equipment and such.
Recently, a client who has a new and unique design for a Wi-Fi enabled household wall socket asked his account manager at PassageMaker “what safety certificates and markings do I need listed on my product to be in compliance in China with product regulations?”
If you find yourself asking similar questions for your product, you may find our response below of interest.
Excerpts from the email to the client as follows:
There are three main tasks at hand.
A) Confirm the product you have in mind is safe and is compliant with the standards set by the government in the market where you wish to sell this product.
B) Confirm what markings and labelling is required to be present on the product or product packaging.
C) Confirm if there are any certs that need to be shown to the authorities in China when exporting out of the country. Many new buyers forget about item #3 and end up having their product stuck at customs in China!
Here is the suggested plan of action!
First off, confirm in which countries you wish to sell your product.
Depending on which markets you have in mind, we may be able to find some of the information we need on a government website. But most of the time the information is not clear and it is constantly being updated. It’s rare for a government official in just about any country to take the time and point us in the right direction. In our experience, the best option is to consult with an accredited laboratory. These are the labs that can not only confirm what product attributes need to be in place (like fire retardant material for children’s sleepwear or the standard for pinch points on a toy) but they can also test the actual products to confirm if it meets these standards. For your product we can ask a few labs and get quotes from UL, Intertek and some others to ensure the best pricing.
If the product is in production phase we can coordinate your engineering firm and the labs to ensure the design will meet specs. No sense spending a lot on engineering only to learn that the finished product won’t be fit for sale in your given market.
If the product design is complete, give us a sample of the product from the supplier you said you were working with. Note that this sample needs to exactly the same as what you plan to produce in full production. If the materials and designs changes, you may be required repeat the conformance testing.
BTW, it’s not uncommon for the sales guy at the factory to say their product conforms to your market’s standards. They may even print a UL or CE mark on the item. I have seen supplier print UL on a product that was never tested, just to get a sale from a naive buyer. Certs can also be forged.
Keep in mind that if there is a problem in your home market, you are the importer of record, so the lawyers are coming after you, not the factory way over in China. For that reason, we highly recommend you do independent testing, even if the supplier claims the product is compliant.
Here is the key information we will get from the labs:
1) What tests need to be done for what purpose
2) What is the cost for the test from various labs
3) How long it will take to do this test
4) What testing plan should we put in place for periodic testing during on-going production?
5) Is the supplier’s existing test certification or test number on file? Because your product is totally new and a custom design that you came up with, I suspect we need to do the full compliance confirmations from scratch.
While we haven’t seen your product yet, based on your initial notes, at a minimum, for Europe they will need to do CE, for USA they will need to do UL (but if your Wi-Fi socket has the electronics circuit board inside then FCC may also be needed). Canada needs CSA and for AUS/NZ they will need C Tick test.
We will also have our in-house customs brokers take a sample down to the port and visit with the customs officials to confirm if there are any potential roadblocks in terms of certs and markings for the product to leave China.