Chinese Rsl Restrictions by Aafa Vvv

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International Product Safety & Restricted

Substances Conference

Hangzhou

May 11, 2010

Product Stewardship in the Global Value Chain

Industry EnvironmentIndustry Environment

Product recalls Emerging legislation and regulation Corporate social responsibilities Sustainable consumption and production models Increased multi-stakeholder expectations Transparency & traceability

Product Stewardship ObjectivesProduct Stewardship Objectives

Social and eco-logical considerations are designed into products

Products are safe during their intended use Products are free of defects and conform to order

requirements Products perform their required functions safely,

reliably, and with minimum performance degradation over their expected life

Products comply with all applicable regulatory, statutory, legislative standards (i.e. ASTM, BSI, CPSIA, REACH, EU, etc)

Identify and develop suitable supply partners with the required manufacturing, quality, safety,social & environmental systems

Product Safety AssuranceProduct Safety Assurance

Four Stage ApproachSupplier Evaluation & Qualification strategic choicesProduct DevelopmentTesting / CertificationInspection

Compliance Standards & ReferenceCompliance Standards & Reference

QA Systems Testing / Certification Standards Labeling Standards Consumer Product Safety Commission Product

Recall Information Defect Classifications Product Performance Standards Restricted Substances Lists (RSL) Acceptable Quality Levels (AQLs)

Product Safety Best PracticeProduct Safety Best Practice

Conduct due diligence on potential partners Adopt a solid product safety compliance policy Implement a robust product-safety testing program Communicate and educate up/down the supply

chain Ensure products are adequately identified for

traceability and tracking Preserve and maintain documentation

information management Consider appropriate indemnification and

insurance coverage Shift from suppliers to partners

RSL/ Chemical ManagementRSL/ Chemical Management

Risk assessment, design review, factory assessment Establish and RSL/ chemical management policy Communicate, train and educate supply chain Materials management Monitor and control Verify and validate

Industry FutureIndustry Future

Extended producer responsibilities Standards harmonization Low impact materials, technologies and processes Sustainable production and consumption Product life cycle management Multi-stakeholder exchange / collaboration

Thank youThank you

International Product International Product Safety & Restricted Safety & Restricted

Substances ConferenceSubstances Conference

Hangzhou

May 11, 2010

www.intertek.com

Understanding Government Product Safety Standards and Regulations

Hangzhou

May 11, 2010

www.intertek.com

Prof. James Wang Intertek Consumer Goods

China Domestic Market Services May 6, 2009 in Dongguan 201056 May 11, 2009 in Hangzhou 2010511

Eco-Safety Technical Codes for Apparel & Footwear Products in China

2010 AAFA 2010 AAFA International Product Safety & Restricted Substances Conference China

www.intertek.com

Structure of Standardization System of China

GB 18401-2003 GB 18401-2003 National general safety technical code for textile products

GB 20400-2006 GB 20400-2006 Leather and fur limit of harmful matter

GB 21550-2008 GB 21550-2008 The restriction of hazardous materials in polyvinyl chloride artificial leather

GB 19601-2004 23GB 19601-2004 Limit and determination of 23 harmful aromatic amines in dye products

GB 208142006 10GB 20814-2006 Limit and determination of the quantity of 10 heavy-metal elements in dye products

FZ/T 81014-2008 FZ/T 81014-2008 Infants wear

National mandatory standard-Footwear-Limit of harmful substances

Product quality supervision system of China

14

Discussion topics

www.intertek.com 15

Classifying of Chinese

Standards

Classifying of Chinese

Standards

Grading of Chinese

Standards

Grading of Chinese

Standards

National Standard

National Standard

Structure of Standardization System of China

Industrial Standard

Industrial Standard

Local Standard

Local Standard

Enterprise Standard

Enterprise Standard

Mandatory Standard

Mandatory Standard

Voluntary Standard

Voluntary Standard

/ Such as GB, FZ, QB/ Such as GB, FZ, QB

/Such asGB/T, FZ/T, QB/T

/Such asGB/T, FZ/T, QB/T

Method Standard

Method Standard

Product Standard

Product Standard

Basic Standard

Basic Standard

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Application Scope: The textile products manufactured, sold or used in China.

Product Classification A Category A Products for babiesB Category B Products with direct skin contactC Category C Products without direct skin contact

GB 18401-2003 National General Safety Technical Code for Textile Products

cannot be used(20 mg/kg)

Banned azo colorants( carcinogenic aromatic amines)

None odor--4 To saliva334 To dry rubbing333-4 To perspiration333-4 To water

Colorfastness( grade)

4.0-9.04.0-7.54.0-7.5pH pH value3007520 Formaldehyde (mg/kg),

Category CCategory BCategory A Requirements

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GB 18401 Updating of GB 18401GB 18401-2003WTOGB 18401-2003 has been revised and the updated version has been circulated within WTO. The updated edition is expected to be effective around the end of this year.

GB 18401 Key Updates on GB 18401* 2436

Definition of Infant: to be changed from 24 months to 36 months* BpH4.0-7.54.0-8.5

pH value requirement for Category B: to be changed from 4.0-7.5 to 4.0-8.5*

Colorfastness to perspiration is not required on drapery fabrics such as curtain*

Toy, textile handcraft, luggage, backpack, footwear, umbrella, carpet, havelock,tabernacle etc. to be excluded in the application scope of this code.

* 244-The banned amine list is changed to total of 24 aromatic amines including4-aminoazobenzene

GB 18401-2003 National General Safety Technical Code for Textile Products

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Application Scope: Home leather and fur products.

Products are classified according to its final usesA Category A Products for babiesB Category B Products with direct contact to skin C Category C Products without direct contact to skin

* 234-Total 23 aromatic amines excluding 4-aminoazobenzene are banned in therestricted list

* Cr (VI) is not in the restricted list

GB 20400-2006 Leather and Fur Limit of Harmful Matter

300 mg/kg 600 mg/kg for sheared sheepskin

75 mg/kg20 mg/kg Free formaldehyde

30 mg/kg Carcinogenic aromatic amines (banned azo colorants)

C Category CB Category BA Category A Limit

Items

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PVCPVCApplication Scope: PVC artificial leathers made of mainly PVC resin and processed with relevant auxiliary agents via various technologies.

Technical requirements:

* PVC Ethylene chloride monomer in PVC: 5mg/kg

* Soluble heavy metals: lead (Pb) 90mg/kg, cadmium (Cd) 75mg/kg

* Other volatiles: 20mg/kg

GB 21550-2008 The Restriction of Hazardous Materials in Polyvinyl Chloride Artificial Leather

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Application Scope: Various commercial dyes, dyestuff preparations, dye intermediates and auxiliary agents for textile, dyeing and finishing processes.

Requirement:

*23 150mg/kgThe content of all 23 harmful aromatic amines should not exceed 150 mg/kg individually based on the weight of dry sample.

* 4-4-aminoazobenzene is not listed in the harmful aromatic amines list.

GB 19601-2004 23 Limit and Determination of 23 Harmful Aromatic Amines in Dye Products

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Application Scope: Commercial dyes in various states including liquid dyes, pigment printing paste

Requirement:10Limit of 10 heavy metal elements in dye products based on the weight of dry sample:

GB 20814-2006 10 Limit and Determination of The Quantity of 10 Heavy-Metal Elements in Dye Products

Zincum Antimony Lead Nickel

Manganese Element

Zn

Sb

Pb

Ni

Mn

15002500Fe Iron50250Cu Copper

100100Cr Chromium200500Co Cobalt

100020Cd Cadmium Limit (mg/kg) Limit (mg/kg) Element

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Application Scope: Infants wears mainly made from woven fabrics.

Below requirements are mandatory in the standard:* GB 18401-2003A

Products must meet the requirements of Category A in GB 18401-2003.*

Below additional requirements are mandatory as well

FZ/T 81014-2008 Infants Wear

25.0 Cu 0.2 As 0.2 Pb 1.0 Cr 0.02 Hg

Extractable heavy

metals

mg/kg

Technical requirements Items

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201035A new national mandatory standard about limit of harmful substances in footwear has been drafted and passed examination on 5th March 2010. Now, the document is being undergone formal approval procedure.

The standard was initially named as Sanitation Safety Technical Code for Footwear. The respective standardization committee has proposed to change the name as Footwear-Limit of Harmful Substances in the final draft.

Only formaldehyde, banned azo dyestuff and extractable heavy metals including lead (Pb), cadmium (Cd) and arsenic (As) are restricted in the standard as harmful substances.

National Mandatory Standard-Footwear-Limit of Harmful Substances

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Product Quality Supervision System of China

General Administration of Quality

Supervision, Inspection and Quarantine, AQSIQ

General Administration of Quality

Supervision, Inspection and Quarantine, AQSIQ

Local Entry-Exit Inspection and

Quarantine Bureaus

Local Entry-Exit Inspection and

Quarantine Bureaus

State Administration for Industry & Commerce,

SAIC

State Administration for Industry & Commerce,

SAIC

Local Bureaus of

Quality and Technical Supervision

Local Bureaus of

Quality and Technical Supervision

Local Administration

of Industry and Commerce

Local Administration

of Industry and Commerce

Supervision on Import & Export

Supervision on Import & Export

Supervision on Production

& Manufacture

Supervision on Production

& Manufacture

Supervision on

Market

Supervision on

Market

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U.S. Product Safety RegulationsU.S. Product Safety Regulations

CPSIA, Prop 65, & Other CPSIA, Prop 65, & Other RegsRegsNate HermanNate Herman

American Apparel & Footwear AssociationAmerican Apparel & Footwear Association

AAFA International Product Safety & Restricted AAFA International Product Safety & Restricted Substances ConferenceSubstances Conference

Apparel & Footwear Recalls

Recalls by Category

0

5

10

15

20

25

30

35

40

45

50

1974

1976

1978

1980

1982

1984

1986

1988

1990

1992

1994

1996

1998

2000

2002

2004

2006

2008

2010

(Yea

r to D

ate)

Year

R

e

c

a

l

l

s

Other

Flammable Fabrics

Lead

Small Parts/Choking

Draw strings

CPSIA StandardsCPSIA Standards Lead & lead paint standardsLead & lead paint standards Phthalate standardPhthalate standard Tracking labelsTracking labels Stay of testing and certificationStay of testing and certification

Still need to test for lead paint with Still need to test for lead paint with third party testing facility and issue third party testing facility and issue GCCGCC

Retailer standardsRetailer standards Tracking labels, general conformity Tracking labels, general conformity

certificatescertificates

NonNon--CPSIA StandardsCPSIA Standards FFA (childrenFFA (childrens sleepwear)s sleepwear) DrawstringsDrawstrings Small PartsSmall Parts

International RegulationsInternational Regulations State LegislationState Legislation

California PROPOSITION 65California PROPOSITION 65

TodayToday

ChildrenChildrens Products s Products Subject to more Subject to more

standards than adult standards than adult products/general use products/general use products.products.

Designed or intended Designed or intended primarilyprimarily for children 12 for children 12 years of age and under.years of age and under. How the product is representedHow the product is represented How the public recognizes the productHow the public recognizes the product Any manufacturer statementsAny manufacturer statements CPSC Age Determination GuidelinesCPSC Age Determination Guidelines

Just because a child may Just because a child may wear the product does wear the product does not mean that it is a not mean that it is a childrenchildrens product.s product.

Lead & Lead PaintLead & Lead Paint

ScrapeableScrapeable surface coatings are subject to surface coatings are subject to the lead standard, everything else, lead the lead standard, everything else, lead substratesubstrate

Lead standard:Lead standard: 300ppm, 90ppm for lead in paint300ppm, 90ppm for lead in paint Applies to every component of a childrenApplies to every component of a childrens s

product except for:product except for: Inaccessible components andInaccessible components and CPSC determined compliant components:CPSC determined compliant components:

TextilesTextiles WoodWood precious metals (gold, sterling silver)precious metals (gold, sterling silver) precious gemstones (ruby, sapphire, emerald), pearls, precious gemstones (ruby, sapphire, emerald), pearls,

etc. etc.

Phthalate StandardPhthalate Standard Footwear & Most Apparel & Footwear & Most Apparel &

Fashion Accessories Are ExemptFashion Accessories Are Exempt Phthalate Bans Applies to:Phthalate Bans Applies to:

ChildrenChildrens toys that can be placed in s toys that can be placed in a childa childs mouths mouth

Child care articlesChild care articles CPSIA Bans Six Types of CPSIA Bans Six Types of

PhthalatesPhthalates DEHPDEHP DBPDBP BBPBBP DINPDINP DIDPDIDP DnOPDnOP

Tracking LabelsTracking Labels

Purpose is to improve recallsPurpose is to improve recalls

Purpose is to recall only Purpose is to recall only violativeviolative productproduct

Product must have distinguishing mark to Product must have distinguishing mark to determine source of productdetermine source of product Batch #Batch # Run #Run # Other identifying characteristicsOther identifying characteristics

Third Party TestingThird Party Testing

Stay of Enforcement to February 10, 2011Stay of Enforcement to February 10, 2011

Required Now for Lead in PaintRequired Now for Lead in Paint

Component testing for chemical Component testing for chemical standardsstandards Traceability required throughout supply Traceability required throughout supply

chainchain

Reasonable Testing Reasonable Testing ProgramProgram

Five elementsFive elements Product Product

specificationspecification Certification testsCertification tests Production testing Production testing

planplan Remedial action planRemedial action plan RecordkeepingRecordkeeping

State StandardsState Standards California Proposition 65California Proposition 65

Exposure standard not a content standard like CPSIAExposure standard not a content standard like CPSIA

Covers 850 chemicals Covers 850 chemicals NOT JUST LEAD AND PHTHALATESNOT JUST LEAD AND PHTHALATES CadmiumCadmium

ChromiumChromium

FormaldehydeFormaldehyde

Warning label requirement for all productsWarning label requirement for all products This product contains This product contains chemicalschemicals known to the State of California to known to the State of California to

cause cancer, or birth defects or other reproductive harm.cause cancer, or birth defects or other reproductive harm.

Regulations by litigationRegulations by litigation Settlements average at $123,000. Settlements include standards Settlements average at $123,000. Settlements include standards and/or warning and/or warning

label requirementslabel requirements

Illinois Lead Warning Label LawIllinois Lead Warning Label Law Warning Label Requirement forWarning Label Requirement for

ChildrenChildrens painted toyss painted toys

Child care articles intended to be placed in the mouthChild care articles intended to be placed in the mouth

ChildrenChildrens jewelrys jewelry

Other States Other States Washington State, Maine, ColoradoWashington State, Maine, Colorado

Prop 65 NoticesProp 65 NoticesSelected Prop 60 Day Notices

0

10

20

30

40

50

60

70

80

2007 2008 2009 2010 (Year to Date)

Year

Lead or Lead Compounds Phthalates Other

February 10, 2011:February 10, 2011: Testing and certification stay Testing and certification stay

lifted for lead substratelifted for lead substrate

February 14, 2011:February 14, 2011: Database implementedDatabase implemented

August 14, 2011:August 14, 2011: Lead limit dropped again to Lead limit dropped again to

100ppm (retroactive) unless the 100ppm (retroactive) unless the CPSC determines not CPSC determines not technologically feasible technologically feasible

WhatWhats Coming s Coming Up?Up?

What is on the Product What is on the Product Safety Horizon?Safety Horizon?

New Leadership and New Leadership and resources at CPSCresources at CPSC

CPSEACPSEA Heavy metal regulations Heavy metal regulations

(cadmium is this (cadmium is this seasonseasons new lead)s new lead)

Other state regulationsOther state regulations

39

ProductSafetyCompliance

WhereWeAre?WhereWeAreGoing?

AndreLeroy5/6/10

WhereWeAre?

40

ImportantProductSafetyIssuesMattel:Recall9millionitemsrecalled:9Milk inChina:Melamineissue: ChineseSofas: thousandsofpeopleinUKdeveloped allergies tosomechemicals:

WhereWeAre?

41

Concernsaboutenvironment Bad chemicalsfoundinriversinEurope BannedfromproductioninEuropeforyears Comefromchemicalsusedinimportedgoods Thereforeneedtomonitorchemicalsusedincludingimports

WhereWeAre?

42

SubstanceofVeryHighConcern (SVHC) Listgetslonger RighttoKnow:ImporterstoEuropeneedtoanswerquestionsfromconsumers(NGOs) withinalimitedperiod

REACH (Europe)

REACh Challenges?

43

Latestupdate:6countriesinEuropehavedecidedthattheywillapplythe0,1%limittothecomponentsandnottothearticle,soSVHCabovethe0.1%withinacomponentwouldhavetobedeclared.:6SVHC0.1%,,SVHC0.1%,.

REACH (Europe)

REACh Challenges?

44

UpcomingSVHC? SVHC?ItisimportanttoanticipateupcomingSVHCSVHCWedothisthroughSmartTestingScreening ProbabilitytofindtheseSVHCincomponentsSVHC AssessmentoftheneededtoxicologicalpropertiestobeaSVHCSVHC

Probablyforthischemicaltobeincludedinthecandidatelist

ImmediatestartingofchemicalsubstitutionprogramsorprocesschangestoeliminatethesubstancetoavoidanyREACh conflictsandrecalls,SVHC

REACH (Europe)

REACh Challenges?

45

About120SVHCcandidatesarepossible120About5to10candidatesbyproducttypeasapriorities510Afewofthemwillbeachallengeforsubstitution(timeline,cost,quality,safety)(,,,)

REACH (Europe)

REACh Challenges?

46

Watchout:Beingbelow0.1%limitdoesnotmeansafeproductsAbove0.1%limitdoesnotmeanunsafeproducts0.1%,0.1%

Ourlimitsarebasedonriskbasedsafeproducts/componentlimits./ThisalreadypreventedProductRecallsinEurope.

REACH (Europe)

Wherearewegoing?

47

Restricted Substance List (RSL) are getting longer

Major Brands / Retailers anticipate the laws and ban chemicals before they are forbidden by law > even longer RSL

WhatIsInItForYou?

48

Consequences for you?

Concerns about cost?

How to minimize additional costs?

WhatIsInItForYou?

49

1) Chooseyourmarkets:

SomemajorsmarketshaverelativelylowProductSafetyrequirementsforchemicals:Australia,SouthAmerica,MiddleEast,;,,

WhatIsInItForYou?

50

2)Chooseyourcustomers:

Somecustomersrelyondeclarationsignedbymanufacturers. DoesitprotecttheimporterstotheUSandEuropefroma

legalpointofview??

Expertisefromcutandsawmanufacturersintermofchemicalrequirements?

- Somecustomershavehighexpectationsandassisttheirsupplierstoimprovetheirprocesses:exampleAFIRMtraining>usethissupporttodevelopthisintoacompetitiveadvantage.

WhatIsInItForYou?

51

3)Morefocusoncomponentcompliancemeans:

Moresuppliersnomination

Lesscompanieslookingforcheapercopiesoffabric

Fightagainstfakefromreputabletrimsuppliers

WhatIsInItForYou?

52

BrandsRetailers

Cut&SawManufacturers

MillsSundriesSuppliers

Benefitsformills/sundriessupplierswho: ComplywithextendedRSL Developpropertraceability Knowwhentotestandmostimportantlywhen nottotest, Haveinitiatedasubstitutionprogram

Getinvolved

53

Several leading Apparel & Footwear Brands, Retailers and Manufacturers met in Hong Kong end March to assess the potential to work together towards more alignment across companies in different areas including Product Safety requirements&,,,.

Getinvolved

54

Contact meAndre Leroy

[email protected](852) 3604 1393

Understanding Government Product Safety Standards and Regulations

Hangzhou

May 11, 2010

Coffee BreakSponsored by Oeko-Tex

Hangzhou

May 11, 2010

Document Certification for Customs and Retail

Hangzhou

May 11, 2010

Consumer Product Safety Consumer Product Safety Improvement Act of 2008 Improvement Act of 2008

Documentation & Compliance IssuesDocumentation & Compliance Issues20082008

AAFA CHINA SEMINARS: May 6 & 11AAFA CHINA SEMINARS: May 6 & 11, 2010, 2010: 2010: 20105566&11&11

Andrew B. Schroth, Esq. Andrew B. Schroth, Esq. Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLPGrunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP

No. 9 QueenNo. 9 Queens Road Central, Suite 2407, Hong Kongs Road Central, Suite 2407, Hong KongTel.: +852Tel.: +852--21372137--2700 2700 Fax: +852Fax: +852--21372137--27012701

EE--mail: mail: [email protected]@gdlsk.com

Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLPGrunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP

CPSIA OverviewCPSIA Overview

Consumer Product Safety Consumer Product Safety Improvement Act of 2008 Improvement Act of 2008 ((CPSIACPSIA) ) signed into law on signed into law on August 14, 2008.August 14, 2008.20082008 -- 20082008881414

CPSIA is geared towards CPSIA is geared towards children's products but imposes children's products but imposes a a compliance certification compliance certification requirementrequirement for for any productany productwhich is subject to which is subject to any consumer any consumer


General ruleGeneral rule An ADULT product that is subject to a CPSC An ADULT product that is subject to a CPSC

rule/regulation requires a general compliance rule/regulation requires a general compliance certification based on a certification based on a reasonable testingreasonable testing programprogram / / ,,

A CHILDRENA CHILDRENs product requires a certification based on s product requires a certification based on testing by an accredited 3testing by an accredited 3rdrd party lab (unless currently party lab (unless currently delayed)delayed),,

Who must issue the certification?Who must issue the certification? ?? The importer (or domestic manufacturer)The importer (or domestic manufacturer)

(()) Testing labs Testing labs cannotcannot certifycertify

Manufacturers are usually requested to prepare this Manufacturers are usually requested to prepare this documentdocument

COMPLIANCE CERTIFICATION REQUIREMENTCOMPLIANCE CERTIFICATION REQUIREMENT



Content of CertificatesContent of Certificates::

1. Identification1. Identification of the product covered by the certificateof the product covered by the certificate

Must describe the product in enough detail to Must describe the product in enough detail to match the certificate to the covered productmatch the certificate to the covered product

2. 2. Citation to each CPSC product safety regulation to which Citation to each CPSC product safety regulation to which the product is being certifiedthe product is being certified

It is not acceptable to issue a certification that It is not acceptable to issue a certification that offers only a offers only a general compliancegeneral compliance statement.statement., , ..

3. 3. Identification of the U.S. importer certifying compliance of Identification of the U.S. importer certifying compliance of the productthe product

Name, full mailing address and phoneName, full mailing address and phone, ,



Content of Certificates (continued)Content of Certificates (continued): : (())

4. 4. Contact information for the individual maintaining records Contact information for the individual maintaining records of test resultsof test results

Name, full mailing address, email and phoneName, full mailing address, email and phone, ,

5.5. Date and place where the product was manufacturedDate and place where the product was manufactured

Provide at least month and year; city and country or Provide at least month and year; city and country or administrative regionadministrative region; ;

If same manufacturer operates more than one If same manufacturer operates more than one location in the same city, provide street address of location in the same city, provide street address of the factorythe factory, ,



Content of Certificates (continued)Content of Certificates (continued):: (())

6.6. Date and place where the product was tested for Date and place where the product was tested for compliance with the regulation(s) cited abovecompliance with the regulation(s) cited above

Date of test reports and location of testingDate of test reports and location of testing

7.7. Identification of any thirdIdentification of any third--party laboratory on whose party laboratory on whose testing the certificate dependstesting the certificate depends

If third party lab was used, give name, full mailing If third party lab was used, give name, full mailing address and phone of lab.address and phone of lab., , , ,



FormatFormat: There is currently no required format: There is currently no required format

: :

The certificate does not have to be signed by the The certificate does not have to be signed by the issuer(sissuer(s). Rather, ). Rather, the the act ofact of issuing the certificate satisfies the new law.issuing the certificate satisfies the new law., ,

Whether hard copy or electronic Whether hard copy or electronic -- Must be created prior to arrival of Must be created prior to arrival of the shipment in question into U.S. domestic commerce.the shipment in question into U.S. domestic commerce.

Avoid Avoid overcertifyingovercertifying.. e.g., including standards that are not e.g., including standards that are not applicable CPSC standardsapplicable CPSC standards. . ., ., ..


COMPLIANCE CERTIFICATION CERTIFICATION REQUIREMENTREQUIREMENT

How must the certification be presented at time of importation?How must the certification be presented at time of importation??? Certification must Certification must accompanyaccompany each shipment each shipment

which contains goods covered by CPSC standardswhich contains goods covered by CPSC standards, , MythsMyths

Must be on or in the shipping cartonMust be on or in the shipping carton

Must be filed with the GovernmentMust be filed with the Government


CERTIFICATION CERTIFICATION REQUIREMENTREQUIREMENT

Must be available to Customs/CPSC (if requested) as soon Must be available to Customs/CPSC (if requested) as soon as the product itself is available for inspection in the U.S.as the product itself is available for inspection in the U.S., , //(() )

Electronic format permitted as long as CPSC has Electronic format permitted as long as CPSC has reasonable access to it and it contains all required reasonable access to it and it contains all required informationinformation , , CPSCCPSC, ,

Reasonable Access? Reasonable Access? -- accessible via the internet and accessible via the internet and identified by a unique identifier which must be created in identified by a unique identifier which must be created in advance and be available with the shipment. advance and be available with the shipment. ? ? Internet, Internet,

Provide electronic or hard copy to customs brokerProvide electronic or hard copy to customs broker

Include hard copy with shipping documents, orInclude hard copy with shipping documents, or, ,


COMPLIANCE COMPLIANCE CERTIFICATION CERTIFICATION REQUIREMENTREQUIREMENT

CPSC and CBP may at some point provide for the electronic CPSC and CBP may at some point provide for the electronic filing of certificates up to 24 hours before arrival on an filing of certificates up to 24 hours before arrival on an imported product.imported product. 2424,,

Importers must also furnish copy of certification to its Importers must also furnish copy of certification to its customers (distributors, retailers)customers (distributors, retailers) ((, , )) Provide a copy or reasonable means Provide a copy or reasonable means

to access the certificateto access the certificate


RecordkeepingRecordkeeping

CPSC currently recommends that importers CPSC currently recommends that importers maintain certifications and supporting test maintain certifications and supporting test records for at least 3 years (possibly 5 years if records for at least 3 years (possibly 5 years if it becomes a required U.S. Customs entry it becomes a required U.S. Customs entry document)document) ,,, , 33((, , 55))


Delayed Enforcement of Certain Delayed Enforcement of Certain Compliance CertificationsCompliance Certifications

The testing and certification requirements are being phased inThe testing and certification requirements are being phased in

ChildrenChildrens Productss Products Certifications and testing by accredited 3rd party labs are currCertifications and testing by accredited 3rd party labs are currentlyently

required for the following:required for the following:::

1.1. Lead paint and surface coatings Lead paint and surface coatings --manufactured after 12/21/08 (lead manufactured after 12/21/08 (lead content content not until 2/10/11)not until 2/10/11) 08/12/2108/12/21 (( 2/10/11)2/10/11)

2.2. Small parts regulations Small parts regulations --manufactured after 2/15/09manufactured after 2/15/09 09/2/1509/2/15


Delayed Enforcement of Delayed Enforcement of Compliance CertificationsCompliance Certifications

ImportantImportant: Although cert./testing is postponed for : Although cert./testing is postponed for

certain standards, products are still required to comply certain standards, products are still required to comply with the underlying standard (e.g., flammability, total with the underlying standard (e.g., flammability, total lead content, phthalates, etc.).lead content, phthalates, etc.). ::, , ((., ., , , , , ))

For various childrenFor various childrens standards, 3s standards, 3rdrd party testing and party testing and certification is delayed until 90 days after lab accreditation certification is delayed until 90 days after lab accreditation requirements are published, for examplerequirements are published, for example:: , , 9090, , ::

Wearing apparel flammability (both adult and children)Wearing apparel flammability (both adult and children) (())

Phthalates Phthalates 16 CFR 1610 16 CFR 1610 the clothing flammability the clothing flammability standard.standard. 16CFR1610 16CFR1610 --


Avoiding Shipment Avoiding Shipment Delays at Entry PointsDelays at Entry Points Invoice descriptionsInvoice descriptions make sure make sure product description is accurateproduct description is accurate -- e.g.,e.g., whether for adults or children whether for adults or children if for children, what is the if for children, what is the

intended age range.intended age range..,., , ,

Properly classified under the HTS. Properly classified under the HTS. If misclassified under a If misclassified under a targetedtargetedHTS #, could result in additional HTS #, could result in additional unnecessary scrutiny. unnecessary scrutiny. HTSHTS. . HTS#HTS#

If goods are detained or seized, If goods are detained or seized, must be proactive must be proactive , , , ,


Consequences of NonConsequences of Non--ComplianceCompliance

Goods will be refused entry and possibly Goods will be refused entry and possibly destroyed ifdestroyed if::, , ::

No certification or nonNo certification or non--compliant certificationcompliant certification

Product is tested by CPSC at time of entry and Product is tested by CPSC at time of entry and failsfailsCPSCCPSC It may be possible to obtain release under bond if It may be possible to obtain release under bond if

the importer is able to recondition the product to the importer is able to recondition the product to bring into compliance (e.g., replace buttons on shirt bring into compliance (e.g., replace buttons on shirt which contain lead).which contain lead)., , ((.,.,))



If nonIf non--compliant product is found at retailcompliant product is found at retail:::: Will likely result in a product recallWill likely result in a product recall

If company had actual knowledge or notice, If company had actual knowledge or notice,

criminal penaltiescriminal penalties, ,

Must have Must have CPSCCPSCss permission to export, only to permission to export, only to correct deficiency, cannot sell to 3correct deficiency, cannot sell to 3rdrd countries!countries!CPSCCPSC, ,

NonNon--Resident Importers of RecordResident Importers of Record (DDP sales) (DDP sales) treated as US Importertreated as US Importer(DDP(DDP) )



Civil PenaltiesCivil Penalties

New Penalties amounts effective New Penalties amounts effective 8/14/098/14/09 09/8/1409/8/14

Increased to $100,000 (up from Increased to $100,000 (up from $5,000) for each violation$5,000) for each violation , , $100,000 ($100,000 ($5,000$5,000))

Maximum of $15,000,000 in total Maximum of $15,000,000 in total violations (up from $1,250,000). violations (up from $1,250,000). $15,000,000($15,000,000($1,250,000$1,250,000))


Consequences of NonConsequences of Non--Compliance Compliance

Criminal Penalties: Knowing and Willful Criminal Penalties: Knowing and Willful ConductConduct

Increased finesIncreased fines Imprisonment up to 5 years Imprisonment up to 5 years 55 Ability to seek asset forfeiture for assets Ability to seek asset forfeiture for assets

associated with the criminal violationassociated with the criminal violation

Can be imposed for:Can be imposed for: :: failure to issue a required certification, or failure to issue a required certification, or

to issue a false or misleading certificationto issue a false or misleading certification, ,

misrepresenting the scope of a product misrepresenting the scope of a product recallrecall



Examples of Prohibited Acts under the CPSAExamples of Prohibited Acts under the CPSACPSA CPSA

Import into the U.S. a product Import into the U.S. a product that is not in conformity with a that is not in conformity with a CPSC rule, regulation, CPSC rule, regulation, standard, or banstandard, or ban CPSACPSA, ,

Fail to furnish a certificate, or Fail to furnish a certificate, or issue a false certificateissue a false certificate , ,


What Should a Producer/Exporter Do Now?What Should a Producer/Exporter Do Now?//??

Know Your CPSC Requirements In Advance:Know Your CPSC Requirements In Advance:CPSACPSA::

Determine the following or ask for CPSC advice:Determine the following or ask for CPSC advice:::

Is my product a childrenIs my product a childrens product?s product? ?? What CPSC standards apply to my products?What CPSC standards apply to my products?

CPSACPSA?? Do I need to test my product/use a 3Do I need to test my product/use a 3rdrd party lab?party lab?

?? Do I need a compliance certification?Do I need a compliance certification?

??

Consider amending terms and conditions to limit Consider amending terms and conditions to limit liability on this issue with buyers/importers (hold liability on this issue with buyers/importers (hold harmless, indemnification agreements)harmless, indemnification agreements)//, , ((, , ))



Identify the standards that apply to the CompanyIdentify the standards that apply to the Companys s productsproducts

Understand the requirementsUnderstand the requirementslevels, effective levels, effective dates, testing and certification requirementsdates, testing and certification requirements, , , ,

Create a program for implementation: Create a program for implementation: :: Incorporate CPSC standards during product Incorporate CPSC standards during product

development stagedevelopment stage CPSCCPSC Quality assurance programQuality assurance program

Screen raw materials for lead paint, content and Screen raw materials for lead paint, content and flammabilityflammability , ,

Request product information from material suppliers Request product information from material suppliers and seek out compliant materialsand seek out compliant materials

Certification and testing programCertification and testing program



Adopt procedures for handling nonAdopt procedures for handling non--compliant inventorycompliant inventory

Adopt a recall policy Adopt a recall policy criticalcritical

Adopt procedures for communicating Adopt procedures for communicating with and challenging with and challenging CPSC/Customs with regard to CPSC/Customs with regard to seized goodsseized goods, , CPSC/CPSC/


Questions?Questions?Andrew B. Schroth, Esq.Andrew B. Schroth, Esq.

Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLPGrunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLPNo. 9 QueenNo. 9 Queens Road Centrals Road Central

Suite 2407Suite 2407Hong KongHong Kong

Tel.: +852Tel.: +852--21372137--27002700Fax: +852Fax: +852--21372137--27012701

EE--mail: mail: [email protected]@gdlsk.com

Document Document Certification for Certification for

Customs and RetailCustoms and Retail

Hangzhou

May 11, 2010

LunchSponsored by Micro-Pak Ltd. And

Thermo Fisher Niton Analyzers

Hangzhou

May 11, 2010

Case Study: Non-Compliance: What is the Cost to the Factory the Workers, the Brand, the Consumer

Hangzhou

May 11, 2010

Hennes & Mauritz

Non Compliance

What is the cost of Factory, Workers, Brand/ Consumers

Albert Liu

Quality Assurance Manager - H&M Hong Kong

May, 2010

Contents Facts about H&M Chemical Restriction & Legislation Non compliance, what is the cost? How to secure a good quality? What is the benefits?

Facts About H&M International Clothing Retailer Established in Sweden in 1947 More than 2000 stores over 37 countries Over 76,000 employees Around 700 suppliers in 16 production offices The turnover in 2009 was SEK 118 billion

Fashion and Quality at the Best Price

QUALTY ASSURANCEFacts about H&M

Quality Standards

Chemical Restrictions

Color Standards

Label content

Legislation EU

Legislation REACH (Registration, Evaluation and Authorisation of Chemicals)

USA California Proposition 65 CPSIA (Consumer Product Safety Improvement Act)

Japan Law 112 (Law for the control of household products

containing harmful substances)

China GB 18401-2003 (National general safety technical code for

textile products)

H&M Chemical Restrictions (RSL)

List of restricted chemicals Implementation Toolkits Follow most stringent

legislations & restricted chemicals of concern

Frequent review & update Dye stuffs, pesticides, heavy

metals, formaldehyde, APEO, PVC, phthalates etc

Restricted Chemical listsH&M Chemical Restrictions

Are all parties following the legislation?

Non compliance what is the cost?

Workers Environment Customers Garment manufacturer Brand

Workers Cost of Non Compliance?

EnvironmentCost of Non Compliance?

CustomerCost of Non Compliance?

Brand Cost of Non Compliance?

Children jackets as poisonous as harbour waste sludgeGerman newspaper Hamburg Morgen Post 23 October 2001

Hormone disruptors in Children-Rainwear

Brand Cost of Non Compliance?

November 2005

Adidas and H&M are best

Brand & SupplierCost of Non Compliance?

T-shirt in organic cotton

Lost sales: >300 000 USD

Fail Phthalates in Print

Cr VI in Leather

Leather jacket

Lost sales: >350 000 USD

Brand & SupplierCost for Non Compliance?

How to secure a good quality?

Production ProcessFactory AuditCommunication

GarmentButton

Zipper

Sequin

Accessories

Wet processing

Spinning

Knitting

Weaving

WashingFibre

Oil

Size

Dyes

Auxiliaries

Print paste

Pigment

Plastic

Metal

Synthetic fibre

Natural fibreDetergents

Bleach

Production ProcessHow to secure good quality?

Audit for H&M Chemical Restrictions Document check Certificates compliance from Chemical manufacturers Test reports

Audit for chemical handling MSDS (Material Safety Data Sheet) PPE (Personal Protective Equipment) Labelled chemical containers Correct storage etc.

Chemical waste disposal Waste water Left over chemicals

Customer/Environment

Worker

Environment

Factory AuditHow to secure good quality?

Factory Audit How to secure good quality?

H&M

SUPPLIER

Chemical restrictions (RSL)

SUB CONTRACTOR

DYER

PRINTER

TANNER

CHEMICAL

MANUFACTURER

CommunicationHow to secure good quality?

Compliance declaration

Lack of Communication/Information

APEO in Cotton fabric

Reason: Scouring agent contained APEO

Action: Called chemical supplier and asked for confirmation and APEO-free alternative

Time needed: 5 min

Cost: almost nothing

BUT nobody asked the question before

Lead in Polyurethane (PU) coated fabric (rainwear)

Reason: PU manufacturer received incomplete RSL from garment maker: PVC and phthalates not heavy metals

Action: Give complete restrictions list

Time needed: 5 min Cost: almost nothing

Lack of Communication/Information

CommunicationHow to secure good quality?

Flow of information through out the supply chain Clarity of what is required How Implement it Test / follow up

Cooperation AFIRM AAFA Chemical supplier 3rd party testing lab

What is the Benefits? Workers working conditions Environmental impact Production Leadtime Reduce testing cost/ claim Better Quality

Thank you

Case Study: Non-Compliance: What is the Cost to the Factory the Workers, the Brand, the Consumer

Hangzhou

May 11, 2010

Chemically-Compliant Supply Chains

&Corporate Restricted

Substances Listsc

Hangzhou

May 11, 2010

2009

Corporate Restricted Substances Lists - Levi Strauss & Co.

Kitty Man

2009 116

Content

Levi Strauss & Co. RSL recent changes Working with suppliers - meeting LS&Co. RSL Documents needed for RSL management AAFAs RSL and AFIRMs toolkit

2009 117

Levi Strauss & Co. RSLWhy and what?

Global standard on chemicals on products or used in production

Laws and regulations GB 18401 CPSIA REACH

Protect workers and consumers Environmental initiatives Brands, eco-labels and AAFA (American Apparel and

Footwear Association) etc

2009

Working with suppliers - meeting LS&Co. RSL

2009 119

Working with Suppliers - Meeting LS&Co. RSL Areas to focus

Human Behavior Raw Material Management Chemical Management Production Processes

Robust factory RSL management systems is needed.

2009 120

Working with Suppliers - Meeting LS&Co. RSL Areas to focus - Human Behavior

Read the RSL and Toolkit Education / Communication

All staff, with focus on: Material / chemical purchaser Production manager Chemical room manager anyone that touches chemicals

Your Supply Chain

Connect with LS&Co. Product Safety TeamTake away # 1

2-way communications.

2009 121

Working with Suppliers - Meeting LS&Co. RSL Areas to focus - Raw Material Management

Know what you purchase Type of material Chance for failure

Source of raw material Reputable supplier Small corner shop

Assurance from supplier Test reports, eco labels, declarations Recent date, valid test method, same material

2009 122

Working with Suppliers - Meeting LS&Co. RSL Areas to focus - Raw Material Management

Follow testing requirements Proactive internal random testing Understand potential failures for each type of material

and test accordingly Example: Natural Fibres - azo dyes

Maintain a comprehensive understanding of your raw material to minimize failure risk.

Take away # 2Know what you are buying.

2009 123

Working with Suppliers - Meeting LS&Co. RSL Areas to focus - Chemical Management

Chemicals include: Dyestuff and colorants Printing inks and binders Detergent, fixing agents, softeners Chemicals for special finishing (wrinkle free / easy care) Adhesives and solvents

If the chemical company dont know what theyre selling, dont buy their chemical.

2009 124


Chemical purchase price is not the only factor when selecting chemicals

$1.20$1.25Price per garment

8 grams25 gramsUsage per garment

$150/kg$50/kgPrice

BAChemical

2009 125


In-house chemical management Maintain a current chemical

inventory Label and segregate all chemical

containers properly Cover all containers avoid spillage

and contamination Obtain assurance from chemical

company Document and maintain formulations

2009 126

Working with Suppliers - Meeting LS&Co. RSL Areas to focus - Production Processes

Document chemical formulations Document production conditions

Drying temperature/duration

Regular calibration of equipment Appropriate chemical use

Dying, printing, finishing

Comprehensive documentation Technical Data Sheets (TDS) Material Safety Data Sheets (MSDS)

2009 127

Documents needed for RSL management

RSL Training log Material/chemical inventory list Test reports / certification from suppliers Bill of material Recipes Machine calibration record Production process control variables Etc

2009

AFIRM Toolkit

2009 129

129

RSL Management System

RSL Toolkit

www.afirm-group.com

2009 130

AFIRM Toolkit Contents

Introduction Restricted Substance List (RSL) Where are the risks? Educate the Supply Chain RSL Testing RSL Implementation Links to brand RSLs Appendices

www.afirm-group.com

2009 131

Successful Manufacturers

Understand restrictions Understand what you are doing Setup in-house RSL team Ensure thorough communication and engagement

throughout supply chain Maintain chemical inventory list Document the formulation / recipe Ensure controls are in place Be transparent Take ownership

132AAFAAAFA

American Apparel & Footwear Association

Establishing a Chemically Establishing a Chemically Compliant Supply Chain Compliant Supply Chain

Dongguan Dongguan May 06May 06

Hangzhou Hangzhou May 11May 11

AAFAAAFA

HBI Chemical Management

ObjectivesRegulatory ComplianceEmployee SafetyConsumer ProtectionReduced Product Testing

AAFAAAFA

The System HBI Owned Locations

Chemical Approval SystemAll Chemicals Must Receive Corporate Approval Prior to Purchase

The Approval ProcessReduce Wastewater PollutantsEliminate Hazardous Waste GenerationMinimize Air PollutantsAccurate Regulatory ReportingImprove Employee Chemical SafetyManage Chemicals in Consumer Products

AAFAAAFA

The System HBI Owned Locations

Maintain Electronic Corporate Database of Approved Chemicals by Facility/Department

All Chemicals Must be Approved Prior to PurchaseScreen all chemicals for compliance prior to use or

integration into product design and/or manufacturing

Standardize chemical management systems in all manufacturing plants

Continuous improvement to more sustainable chemistries

AAFAAAFA

The System Supply Chain

Contract/Purchase Order Language includes Compliance with Restricted Substance List(s)

Certification of Compliance has been Required when Mandated by Law

Assistance was Provided to Supply Chain Facilities Upon Request

AAFAAAFA

The System Supply Chain

A Third Party Chemical Audit Program Has Been Implemented

ChinaThailandTaiwanBangladeshHondurasUSA

AAFAAAFA

The Audit

The First Audit is Financed by HBI Chemicals used for HBI product and all other production chemicals on site will be reviewed

FindingsAll findings are confidentialIf a regulated chemical is found on HBI products, replacement must be immediate

There will be an evaluation of existing products and liabilitiesHBI will assist in locating alternative chemicals

If a regulated chemical is discovered, but not in use on HBI products, it will be referenced in the report in order to assist the facility in its chemical management

AAFAAAFA

The Audit

Subsequent AuditsAt facility expenseUse of restricted chemicals on HBI product will result in immediate loss of the contract

AAFAAAFA

The System - Chemical Suppliers

HBI Reduced the Number of Process Chemical Suppliers from Greater than 65 to 12

Partnerships Have Been Established with Preferred Dye and Chemical Suppliers

Demonstrated Chemical ExpertiseRegulatory KnowledgeRecognition of Restricted SubstancesExisting Chemical Management SystemsTransparency

AAFAAAFA

Supply Chain Classification - Developing

Fabric Mills are Divided into Tiers Based on Chemical Management Systems

Tier IWell Established Chemical ManagementUse only HBI Preferred Chemical SuppliersThe Tier I Guidelines

Third party chemical audits every three years (HBI cost)Limited compliance testing (Factory Cost)Preferred supplier status

AAFAAAFA


Tier IIWell defined Chemical ManagementUse of Preferred Chemical Suppliers for HBI Products but Chemicals are on Site from Non-Preferred Chemical SuppliersThe Tier II Guidelines

Third party chemical audits every two years (Factory Cost)Increased compliance testing (Factory Cost)Second in chain of preferred supplier status

AAFAAAFA


Tier IIIUse chemicals with unsubstantiated compliance in the HBI chemical management system

Third party chemical audits six to twelve months (Factory Cost)Aggressive compliance testing (Factory Cost)Lowest level of supplier status

AAFAAAFA

Supply Chain & Preferred Chemical Suppliers

Efforts are in Process to Use the Combined Dye and Chemical Usages of HBI and its Supply Chain to Negotiate Reduced Costs with the Preferred Dye and Chemical Suppliers

AAFAAAFA

AAFA and Industry Approaches

The AAFA Restricted Substance ListA Goal of One Standardized Global RSL for

the IndustryDeveloped by a Group of Industry Experts

ManufacturingRetailTesting LabsCertification Companies

AAFAAAFA

AAFA and Industry Approaches

Updated Semi-AnnuallyVersion 6 Released in February 2010Version 7 to be Released in September 2010

Value and Rationale for Using AAFA RSL

AAFAAAFA

The AAFA List

The StructureChemicals with Regulatory Concentration LimitsGlobal Regulatory ReferenceReferences Regulations With Exposure or Contact Limitations by Reference

New RegulationsTwo Appendices

Government Required LabelingGovernment Required Reporting

AAFAAAFA

The AAFA List

Chemical Management Seminars

FREE !FREE !

http://www.apparelandfootwear.org/Resources/RestrictedSubstances.asp

AAFAAAFA

RSL Tool Kit

AFIRM

http://afirm-group.com/supplierstool.htm

AAFATool kit for use by smaller companies with limited resources IN DEVELOPMENT

Chemical Management

and Compliance in Esquel

by Yugao Zhang

May 2010

Chemicals used in Esquel

Synthetic fibre

Natural fibre

AccessoriesButton

Label

Package

Dyes

Auxiliaries

Chemicals

Pigment

Plastic

Metal

Wet processingLoose fibre dyeing

Yarn dyeing

Piece dyeing

Garment dyeing

Washing

GarmentYarn

Heather YarnSpinning

FabricKnitting

Weaving

Detergents

Softeners

Dyes

Auxiliaries

Chemicals

Pigment

Plastic

Metal

Wet processingLoose fibre dyeing

Yarn dyeing

Piece dyeing

Garment dyeing

Washing

GarmentYarn

Heather YarnSpinning

FabricKnitting

Weaving

Detergents

Softeners

Chemical Management Procedure

Global Legislation

REACH

CPSC

California Proposition 65

Japan Law 112

Customers RSL Requirement

Esquel Chemical

Management system

Require Suppliers and Subcontracts guarantee the

RSL compliance

Esquel products compliant with legislations and

customers requirement

Esquel identified and eliminated the RSL

substances

Esquel RSL


Supplier Selection Criteria Internationally operated company or well known large scale local

company

Good record of environmental protection should meet local environmental protection law and regulations

Be able to provide complete documents on chemical product and safety, e.g. Product technical instruction, MSDS and testing report

Confirmation letter to Esquels RSL

For dyestuff, the supplier should be a ETAD member

Chemical Management ProcedureApproval Process

First Step: Must provide documents before trial TDS

MSDS

Confirmation Letter

Second Step: Approval for trial

Third Step: Monitoring testing

Final approval: Approval to use in production

Management: Issued chemical management policy across all manufacturing divisions and operated in line with ISO14001

Updating Esquel RSL

Approval Record

Documentation

Product Management

Final product Certificate - Okeo-Tex 100 Certificate

Yarns, Fabrics and Garments

Product testing against RSL

Sample developing: Third party testing

Bulk: Third party monitoring testing initiated by Customers

and Esquel, such as AZO, heavy metal, phthalates


Esquel RSL and Certificate

Esquel Supplier RSL Declaration


RSL

Main Chemicals in RSL

Azo dyes Disperse Dyes Sensitizing Chromium VI Heavy Metals Pentachlorophenol Phthalates Organotin APEO Formaldehyde

160

Thank you!

Chemically-Compliant Supply Chains

&Corporate Restricted

Substances Lists

Hangzhou

May 11, 2010

Coffee BreakSponsored by

IntertekHangzhou

May 11, 2010

Understanding Testing When to Test, How to Test, What to Test

Hangzhou

May 11, 2010

From Application Form to Report

Dr. Jane JiangSoftline Technical Director (Asia Pacific)

SGS-CSTC Standards Technical Services (Shanghai) Co., Ltd.

Email: [email protected]

11 May, 2010

------ How to Achieve RS Control and Quality Improvement through the Lab Testing

165

Outline

Process flow of testing How to test QA and QC lab programs Reporting

166

Quality Management and PDCA Circle

Testing is not target and answer Important part of the quality systems Feedback from testing result Continuous Improvement

Build quality into system

Testing

167

Process Flow of Testing

Samples in Sample review & breakdownSample cutting

/ weighing

Extraction / DigestionInstrument analysis

Record test data + comments

Issue draft report Report reviewed by authorized personnelSend test report

to client

Application form & contract review

Method

Matrix

Sample

168

Outline

Process flow of testing How to test QA and QC lab programs Reporting

169

Selection of Test Parameters

Regulatory-based testing matrices Product category End-market

Common market requirements End-buyer RSL programs Product safety Production process

Tailored tests Special request from clients

170

Application of Different Test Methods

Regulations that specified the test methodse.g. Nickel release, Azo dyes, CPSIA

International / National test standardse.g. ISO, EN, DIN, ASTM, etc

In-house methods When there is no official method available,

laboratory may use its own method after thorough research and validation of the method.

Tailored methods Special request by clients / end buyers.

E.g. for sample with bad smell or cause any allergenic reaction

171

Sampling

Homogeneous material It is necessary as per legal or buyer requirement And hence, test sample should be separated into

the lowest homogeneous level

Individual / Composite test All legal requirement is based on Individual test

result Composite test is an cost effective-risk balance

approach, by mixing 3 of components in 1 test At the same time, increase of deviation in test

result may result due to the influence of matrix and dilution effect

For some test parameters such as Chromium (VI), pH value composite is not allowed due to the interference from sample matrix in the mixture

172

Sampling

Sample amount Different chemical tests required different amount

of sample It depends on the sample pre-treatment, analytical

technique and the legal requirement

Insufficient sample With less sample amount, it will also reduce the

accuracy of test result In worst situation, testing cannot be performed

when the sample is less than the minimum amount

Client may be requested for additional sample

173

Outline

Process of testing How to test QA and QC lab programs Reporting

174

QA & QC Lab Program

Accreditation against ISO/IEC 17025 Within the lab

Personnel Systematic training to the staff Only qualified staff is allowed to carry out the testing

Quality control during routine testinge.g. calibration curve, calibration check, spikes, blank, Certified Reference Materials (CRMs) etc

Per batch of samples / Every 1-in-20 / cover all samples tested

Records Quality control chart/ QC data to monitor

performance Training record to ensure the professionalism of

staffs Regular instrument calibration and maintenance

programs

175

QA & QC Lab Program

External Proficiency-testing programs

e.g. IIS, CHEK, FAPAS, LGC etc Inter-laboratory correlation exercise

Audit External audit by accreditation bodies

e.g. HOKLAS, DAkkS, CNAS Internal audit

Global platform for internal alignment Technical alignment with affiliates Global SOPs, report templates, guideline etc Frequent workshops/meetings among the affiliates

176

Outline

Process of testing How to test QA and QC lab programs Reporting

177

Reporting How to Read a Report

Client information

Overall results

Result for each individual

parameters

178

Reporting How to Read a Report

Test result for each component

Description of test method

Component list

Special note of testing, e.g. DL

179

Quality Management and PDCA Circle

Testing is not target and answer Important part of the quality systems Feedback from testing result Continuous Improvement

Build quality into system

Testing

Dr. Jean-Pierre Haug, COO, TESTEX Swiss Textile Testing Institute, Zrich

Understanding Testing: At the Factory

International Product Safety & Restricted Substances Conference

5 May in Dongguan, 11 May in Hangzhou

Topics

Testing at what stage, also raw materials? How to avoid contamination RSL management, communication with

suppliers, processing of non-compliant input

Communication within supply-chain

Typical Supply Chain(1 single test, responsibility at the fiber production)

625

125

25

5

1

5

160000

8000

400

20

1

20

10000

1000

100

10

1

10

16

8

4

2

1

2

Apparel industry

Dyehouse

Fabric producer

Yarn producer

Fiber producer

Supplier

Testin

g at a

n earl

y stag

e save

s mone

y!

1

1

1

1

1

1number of clients

Who is responsible for what?

Fibre producer:

Master Batch(Pb, Phthalates?)

Spinning oils(PAHs?)

Pesticides, heavy metals

Polymerisation(Heavy metals, monomers?)


Yarn producer:

Reviving agents(PAHs?)

Waxes


Fabric producer:

Warp-Sizing(Active chemical

products, chlorinated

phenols, i.e. PCP and similar?)

Bonding of non-woven(Formaldehyde?)


Dyehouse/Finishing:

Colouring(banned azo colorants, sensitizing colorants,

heavy metals,chlorinated

benzenes/toluenes, phthalates, )

Finishing(heavy metals,

chlorinated phenols/benzenes/toluenes

phthalates, fluorinated substances, )

Sewing thread

Labels

Accessories

Lining

Fabric


Apparel industry:

Avoid cross-contamination

Sources of contamination:

Use of contaminated chemicals/dyes/auxiliaries (Problem of supplier) make them aware of restricted substances

Improper machine maintenance (cleaning between production batches)

Packaging of produced materials / testing samples Dont forget transport conservation (dimethylfumarate)!

RSL management Make all of your suppliers (raw materials, chemicals, dyes,

auxiliaries, accessories) aware of your needs Encourage/commit your suppliers to be part of an existing

certification network: for example Oeko-Tex for textiles (also for intermediate products and accessories), Eco-Passport for chemicals/colorants/auxiliaries

Validate the certification scheme: Do you know exactly what the scope of the certification is (transparency, quality control

measures)?

Supply chain communication Ask your supplier for any valuable information (MSDS,

specific statement about restricted substances, test reports) Validate this information Set up your own testing scheme/program (based on a true

and fair risk/knowledge assessment) Communicate open and truthfully with your buyers about

your own product (What are the characteristics? Where are potential problems? What has been tested? When/on which sample? What has not been tested why not?)

OR

Make you and your suppliers part of a net-work having a uniform and easy communication tool (for example Oeko-Texcertificates). In an unbroken certification chain along the supply chain enormous amount of testing costs can be saved!

Unbroken certification chain(again the same single test influenced by the fiber production)

625

125

25

5

1

5

160000

8000

400

20

1

20

10000

1000

100

10

1

10

16

8

4

2

1

2

Apparel industry

Dyehouse

Fabric producer

Yarn producer

Fiber producer

Supplier

1

1

1

1

1

1number of clients

Each member of the supply chain takes over responsibility for his own sector!

0 0 0 00

0 0 0 00

0 0 0 00

0 0 0 00

Sewing thread

Labels

Accessories

Lining

Fabric

Making-up using certified components!

Apparel industry:

No additional tests are necessary!

Angelina Jolie and Vivien arriving at the Narita International Airport in Tokyo on the 27th of January 2009.

As seen in numerous newspapers and web-sites all over the world (for example www.celebuzz.com)

00-091 IFP Research AB Mlndal

Thank y

ou for y

our

kind att

ention

AAFA Seminar

Understanding Testing on the ProductWhen to Test, How to Test, What to Test

May 2010, Dongguan & Hangzhou

STR Testing & Inspection AGDr. Anne Bonhoff

Certification and Eco Labels

Certification refers to the confirmation of certain characteristics. This confirmation is often, but not always, provided by some form of external review, education, or assessment.

Product certification is the process of certifying that a certain product meets minimum standards. The qualification requirements are stipulated e.g. in regulations, certification requirements, RSL.

Certification and Eco Labels

ECO Labels: Certify products and services that are kinder to the environment

What is behind these labels which requirements needed to be fulfilled?

What do they mean?

etc. etc.

RSL Requirements

Each Eco Label stands for specific requirements which had to be fulfilled.

The Restricted Substances List defines those chemicalswhich are not allowed in products or which are not allowedto exceed a specific limit.

Is it necessary to test the final product for all those chemicals listed in the RSL?

Is it possible to select critical substances/chemicals?

If yes, how?

How to test the product

Focus on high risk material in your product.

Specific chemicals are related to specific materials or processes.

Test high risk material regularly if they are used continuously.

Test real product not special test sample.

Focus on critical parameters.

Test according to a matrix which identifies high risk substances.

What to Test

Matrix to identify high risk materials

xxxPCP, TeCP

xCr VI

xDisperse DyesxxxxAzo Dyes

xxPhthalatesxNickel

xxCadmium totalxxx(x)Lead total

MetalsPlasticSyntheticLeather

SyntheticFibre

NaturalFibre

LeatherRSL Parameter

What to do in case of Failures

1. Stop- stop production, stop shipping

2. If already shipped- inform customer immediately- avoid deliverance and unintended use- avoid recalls by officials

3. Dont repeat production and hope for a different lab result.

4. Investigate with support of laboratory, customer and raw material supplier.

What to do in case of Failures?

5. Identify- identify material of failure - which component, which colour.- can it be easily replaced e.g. shoelace.- collect and trace all related documents of raw materials, production steps, production records.

- review and analyze.

6. Root Cause- contamination e.g. forbidden azo dyes from an unclean dye container.

- sample variation e.g. cadmium residues in recycled PVC.- wrong raw materials, chemicals used during production e.g. forbidden azo dyes, forbidden phthalates, lead.

- did it occur after production e.g. Cr VI formation.

7. Action Plan- work to improve the material.- test corresponding raw material and products.- do selective testing for these parameters.- find alternatives e.g. for lead(lead used as pigment, speed dying, increase durability, avoid corrosion, retain a fresh appearance, heat stabilizer in plastic).



7. Action Plan- replace using alternatives

(e.g. use substitutes of lead as heat stabilizer such as barium, calcium, zinc, magnesium, or mixtures of these,rare earth, auxiliary heat stabilizers such as epoxides, phosphate ester).

- test with harder conditions to simulate the risk of Cr VI formation = test after agingaging: high temperature, low humidity.

- add additives to reduce the risk of Cr VI formation.

Thank You

www.STRQuality.com

Understanding Testing When to Test, How to Test, What to Test

Hangzhou

May 11, 2010

International Product Safety & Restricted

Substances Conference

Hangzhou

May 11, 2010

Chinese Rsl Restrictions by Aafa Vvv

Documents

Transcript of Chinese Rsl Restrictions by Aafa Vvv