Stay out of jail by navigating product safety in China!
Product Safety in China: Is My Product Safe?
When people ask “is my product safe?” most of the time they are asking the question because they want to make sure the product won’t hurt anybody and to be sure they are not at risk of a lawsuit. We could call this “design safety”.
Meaning, for example, the product has no pinch points, sharp edges or dangerous materials. If your product is in the concept or design stages, it is very important that not only can your design engineers come up with something that appeals to the market place, but is also needs to be physically safe. Imagine spending thousands of dollars on a design only to learn that it is not fit for function or unsafe.
Regardless if you design in-house or outsource the engineering, make sure your design and engineering team are fluent in DFM and that they have a solid understanding of the regulations in your marketplace. And that brings us to regulatory compliance.
As mentioned above, not only should we be thinking about physical safety, but we also need to make sure that our product can be imported into our market with no complications. For example, the safety regulations for a toy, electronics, or piece of furniture can be radically different in Jordan, Jamaica and Japan. You risk wasting a lot of money if your product is not engineered from day 1 to meet those standards.
Who can you trust?
Since standards are constantly updated and vary from country to country, you are at great risk to simply take your suppliers word for it. They want your order, so of course they will say “sure it is safe.” But if the product is not safe from a physical safety or regulatory compliance point of view, and God forbid, somebody gets hurt….who are the lawyers and government officials in your marketplace going to come after? An overseas supplier in China? No way, they will come after the importer of record. And that means you.
So as buyers, it is our responsibility to confirm the product is safe. Assuming you had it engineered right, the next step is to take the prototype or sample and get it to a reputable testing lab. The big international labs stay up to date on the latest rules and regulations for all the major markets. As they have offices in China, you need not send your widget back home to be tested. Plus even the testing costs are less in China, generally speaking.
Most new importers don’t realize they can take their widget to a lab and say “I want to import this to X country, how much will you charge me to test that this product and packaging fully conforms with all standards?”. The sales guy at the lab will pull out a giant book full of protocols and prices and in a few minutes you may learn that it really doesn’t cost that much to confirm your product is safe.
Can I sleep well at night?
Well before you start patting yourself on the back for working so hard to make sure your product is safe. Don’t forget that at the lab, you simply confirmed that one unit was safe. Now you need to make sure that when full production is running, every unit that comes off the line is safe.
But it is not realistic to send 100% of production to the lab for testing, so as buyers we need to come up with a realistic factory audit, production inspection and product testing plan. The factory audit may take place once or twice a year to confirm that the shop is being managed with a Quality 1st mentality.
In other words, they are running their factory in a well-documented and “safe” manner. Production inspection should be taking place with every order before the goods ship out of China. You or an independent inspector will go to the site of production and verify what is coming off the line is safe. In this case, safe means that it matches the specs set by the master sample which was tested by the lab to be safe.
Unfortunately, you still can’t call it a day just yet. Because, unless the order is tiny, the inspection will not be 100%. It will be based on a statistically reliable sample size, using an AQL chart. While the inspector can easily check the physically properties of production pieces, it is hard for them to check the chemical properties. So some parts should be picked at random and send to the lab.
How many pieces to send to the lab each production run is a hard question to answer and there is no universal formula and if you ask that question to your government, your lawyer, a testing lab and the inspection partner you may get four different answers. But if something goes wrong in the market place and a person is hurt, you will certainly be called upon to show your audit, inspection AND testing records. So being able to show you have a plan in place is a big step in the right direction. Getting caught without a well-documented plan or recorded results will exposure you significantly if the case ever went to court.