Sourcing from Vietnam and status:
What is Product Compliance?
Sourcing from Vietnam – The Four Elements
1. Safety Standards / Substance
Restrictions
ISO, EN or REACH
2. Document Requirements
Product Certificates, DoC, Technical File
3. Testing / Verification Requirements
Often mandatory, but not always
4. Labeling Requirements
CE Mark, FCC, “Made in China”, Textile Labels
Which products are regulated?
Very strict
– Toys & Children’s Products
– Electronics, Machinery, Energy, Medical Devices, Vehicles
– Food Contact Materials, Kitchen Utensils
– Chemicals, Cosmetics, Pharmaceuticals
Not as strict (but regulated)
– Furniture
– Apparel, Textiles, Watches and Jewelry (for adults)
A brief overview of product regulations in the United States
- Toys: CPSIA (Consumer Product Safety Improvement Act): Technical, Substances, Documentation, Labeling
- Substances: CA Prop 65: Labeling, Substances
- Electronics: FCC: Technical, Labeling, Documentation
- Food Contact Materials: 16 CFR: Substances, Labeling
- Consumer Goods: CPSC: Substances
- All Products Labeling Requirements: Country of Origin, Apparel Labeling
Case Studies
Children’s Products (USA): CPSIA
Step 1: Assess applicable ASTM (American Society for Testing and Materials) standards
Step 2: Submit samples for testing (and implement a testing strategy)
Step 3: Create all the mandatory documents (i.e., Children’s Product Certificate)
Step 4: Create labeling files (and submit to your manufacturer) (i.e., tracking label)
Summary: CPSIA outlines very specific requirements. This makes the process straightforward.
Ensuring compliance when sourcing from Vietnam/Asia
How do you know if a supplier can manufacture compliant products?
- A supplier’s capability to ensure compliance must not be taken for granted
- Capability = Expertise + Access to compliant materials and components
- Only suppliers with a history of exporting to the EU and the US tend to have the “capability to ensure compliance”
- Verify the supplier’s “compliance track record” = test reports and other documents
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