Comparing the old and the new in compliance software

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Comparing the old and the new in compliance software

Maintaining supply chain compliance is an issue retailers/importers have found more difficult to navigate in recent years with an increase in pressure from consumers for more ethical products, and the digitization of retail supply chains.

Dealing with compliance issues have long been managed by manual compliance document filing procedures, which may have provided one a greater level of control in some respects in the past, but also made it that much more difficult to stay on top of one’s supply chain with all the heavy paperwork.

The need for an update in the way that compliance was documented, implemented and achieved was evident.

This brought about the advent and introduction of an online compliance solution. Web-based filing presented an all-in-one platform that promised greater transparency, and control over one’s supply chain in real time.

However, even with this tool there are still retailers/importers today who rely on more traditional means by which to tackle ever evolving issues that can be more readily addressed with more the accurate reporting data, flexibility and speed of an online solution.

In this blog post we will take a look at the benefits of the online compliance software known as the TCF solution over traditional compliance filing procedures, in the hope of showcasing why bringing supply chain compliance into the online age is a must for your household goods business.

tcf_software_vs_traditional_compliance (2).jpg

Often times retailers locally and globally are unaware of the options that are available to them, and also what benefits they can have for their organization. This often leads to sticking with what you know, sticking to a solution that may not always have the best ROI for your organization.

Why is this TCF solution right for you?

TCF is an online compliance software solution that:

  • streamlines your compliance and regulatory operations
  • provides actionable insights into the performance of your suppliers
  • allows insight into areas of risk that you may not have seen before
  • is extremely cost effective and efficient

The kind of visibility that a solution like this promises goes very far to help increase your productivity, therefore having a positive impact on your ROI.  

Learn more about the TCF solution API provides for household goods here!

Achieving compliance traditionally is a challenge right from the start. The constant back and forth communication with your suppliers, with a flood of emails to your inbox to constantly keep track of, to the unreliable manual entry spreadsheets. There is too much room for human error here to remain as productive as what consumers today are demanding.  

The digital landscape we find ourselves in is all about keeping up with the constant demand of the retail supply chain. If your current compliance systems are holding you back with errors that can be avoided easily, then your supply chain may not be as competitive or as productive as it likely should be.

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Compliance issues? You need this online software

Completing a Technical Compliance File as we know is a requirement by regulation. Consolidating compliance documents is an immense challenge and is a web of complexities that often creates confusion and uncertainty. The many rules and regulations that are needed for a specific product to attain a certain level of compliance are so complex that it can be unclear on how to begin addressing them let-alone having the in-house capabilities to begin addressing them.

“Is there a solution to this web of complexity?”

An in-house developed, web-based platform with 24/7 availability and safe storage of your documents has been created. A platform like this can create immense value for retailers, importers and quality directors, helping to alleviate some of the compliance pressures and complexities by keeping everything in one place.

In this post, I interview Aurelien Dalle, Chief Operating Officer for API, where we endeavor to uncover some of the frequently asked questions surrounding this new compliance software, and the benefits that it can provide for brands that struggle with compliance issues brought on by missing, incomplete or incorrect documentation.  

Q: What are some of the common challenges that organizations face with TCF and compliance in general?

  • There is often difficulty in having and keeping all the product, standards and regulation expertise and regulatory watch internally as more often than not it needs technical experts in many different fields to assist.
  • There is difficulty in keeping track of the documentation with no proper IT system for support and often relying on many emails and excel files for documents.compliance issues.jpg
  • In many organizations, the quality team is small. In some instances the only teams big enough to support such task are within the purchasing team and even then they are often in need of assistance from the laboratories for advice and judgement regarding compliance and quality in general.
  • That it is a huge and tedious task to map out the requirements for each product and to contact the suppliers to collect the all the documents. It can also be a wearisome task to review 50 page documents all in one day.

Q: What is the follow-up action after applying the TCF service?

  • If the client is unaware of the standards and regulations that are applicable to complete a TCF, the API TCF team can define and give recommendations on the scope of compliance (mandatory standards and technical documentation as well as recommended performance requirements) of the product for its destination market.
  • The API TCF team start contacting the suppliers by providing them access to the database and inform them, through the TCF tool about the exact requirements applying to the products so that suppliers can begin uploading the documents, should they already have the documentation on hand, otherwise the supplier will start arranging the necessary testing in laboratories.

Q: How can an organization benefit from this compliance software?

  • The TCF tool provides centralized information, that is available 24/7. We offer technical expertise from the API lab and automatic statistics to monitor specific supplier performance. There are also organized reminders embed in the system, tracking all sort of activity and dates within the tool.
  • Tracking of standards/documents validity and expiry dates and versioning, so the same file does not need to be re-checked for the following orders.

Q: What is the turn around time of a completed TCF?

The turnaround time is dependent on the supplier’s performance, so generally it can be from 1-2 weeks all the way up to 2-3 months. It can sometimes be more as some specific endurance tests span over several months.

Q: What are the benefits of using a web-based platform?

This software and its information is centralized and can be accessed from different countries. It minimizes the amount of emails sent and received while also reducing the number of collections of large documents. These documents are also then automatically and properly archived for each item.

Q: How do you ensure document security and confidentiality?

There is password protected access and secure encrypted pages that guarantee confidentiality. Therecompliance software - safe storage is also a dedicated IT team to ensuring the safety of the software and only API employees are allowed to make modifications to the platform.

There are many benefits to this TCF compliance software, an all inclusive solution that is able to streamline all of your compliance issues creating operational efficiency for your brand, increased visibility into your supplier and their performance as well as being able to mitigate against any unnecessary risks. 

An informative interview that has been able to clearly define the benefits of this solution do you have thoughts or questions regarding this? Contact Us!


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[VIDEO] What is a Technical Compliance File (TCF)

Compliance and regulation has changed so much over the years with far more stricter regulations required for retail products today than ever before.The changing landscape has meant the very nature of compliance has become rather complex and difficult to achieve without adequate knowledge and expertise.

Compliance solution documentsMany of the compliance complexities that arise are in the collection and gathering of all the necessary documentation. Many manufacturers, importers and retailers today are still operating on outdated systems like spreadsheets, creating unreliable data and documentation, which creates an almost insurmountable task trying to maintain the information for each product reference.  

Often times professionals find themselves in a position of begging and pleading for documentation with nowhere to turn but to wait on the slow turning wheels of doing everything manually. Data, technology and cloud-based systems and solutions are where supply chains are headed.

Today’s consumers dictate the level of safety and performance they need to make a purchase of your product; this can either be seen as a challenge for your supply chain or as a golden opportunity.

What if there was an all inclusive compliance software that could streamline all your supplier and compliance operations in one place… accurately and reliably?

In this post, we seek to uncover the Technical Compliance File (TCF) solution – A compliance solution that will help relieve many of the compliance pressures that your supply chain currently faces.

What is a TCF?

Why a TCF?

At this point you may be wondering about the exact operating of this system, and what kind of benefits a compliance solution like this can have for your current operating systems. So let me tell you;

There are a number of reasons why retailers are in preference for this solution;

  • Technical expertise – There are dedicated teams to review what exact documents are required for the products and that the documents received are exactly what you are in need of, including all follow up with any supplier or factory that may be delaying you. These experts are also able to give technical advice where necessary, ensuring you don’t find yourself in a sticky supplier situation that can easily be avoided.
  • Online 24/7 access – The TCF solution has a 24/7 online dashboard with real-time updates allowingTCF compliance software you insight into your compliance status whenever you need it. There are also progress charts allowing you actionable insight into timelines and your supplier progress. This solution is also able to store all your documents for up to 10 years, ensuring your documents are safely stored for any future reference.  
  • Transparency – A solution like this can provide you with a real look into your supplier and/or manufacturer’s status in the workplace. It provides invaluable insights into the kind of supplier you have chosen to work with as you can track their compliance and regulatory progress online. 
  • Visibility – This allows you insight into what tests are being done and achieved in the lab, placing you in a better position of understanding the level of compliance your products are achieving.
  • Additional custom services – In having the expertise to analyze and determine the exact compliance and regulatory documents you are in need of, there are other custom services that can be offered if you find yourself short of an audit or specific product test that you need done to form a part of your TCF.
  • Separate supplier reporting – You are able to access reports on your organizational progress, but also your supplier’s progress. Your supplier is given access to a separate dashboard, so your information remains confidential.
  • Cost reduction – Streamlining the incredibly complex compliance process into one solution will be cost effective for your brand. Let me break this down for you; As mentioned earlier, a TCF is required as part of regulation, you already know what the process is in collecting documents from your factory, and all the follow-up communication that is required to get your documents. It’s often difficult and complex with little or slow results.

Regarding product compliance, let’s say for a furniture retailer, each item may need up to 30 documents (without counting all the submitted and rejected docs, which can be even more) to demonstrate compliance just for that product. As a retailer, you likely have more than 1 item that needs to achieve compliance, and with every document that is needed, each could take up to 30 minutes to evaluate properly, which equates to about 15 hours for just one product! If you have a whole range of products, you can begin to see how costly this whole process can become.

Risk Mitigation – The insight that this solution can provide into the most vulnerable areas of your supply chain can be invaluable information. The information that you will have access to should alert you to potential risks early on, allowing you the time to mitigate those potential risks. 

Enhancing your current quality management systems to include a web-based solution like this can set your brand at a benchmark above the rest.Compliance software web-based solution

As supply chains are increasingly becoming more digitally adaptive with cloud-based operating systems, it will be necessary for you to analyze your current solutions to be more adaptive to the current supply chain climate.

A comprehensive solution like this can create an operational efficiency for your supply chain that may have never even crossed your path. The benefits and increased visibility into your supply chain will be invaluable to optimizing your current quality systems.

In a better place of understanding this web-based solution, do you have thoughts or questions regarding the TCF? Leave your questions in the comments section; I would love to engage with you on this.

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Quality Vs Compliance – The Case For Supply Chain Synergy

The age old debate of quality vs compliance or compliance over quality is something that we still wrestle with today. By defining what these concepts mean, we can start to paint a picture of why one may take precedence over the other in your eyes: Quality – This specifically refers to the ability of a product or service to consistently meet and exceed customer expectation from its design to its functionality. Compliance – This specifically refers to whether or not your product meets specific product compliance regulations so as to be responsibly bought or consumed by a customer. Now, depending on your brand’s positioning and goals, you will likely be placing value on one over the other, putting your brand at unnecessarily high risks that can result in avoidable costs for you. “Does it really have to be one over the other?”  When quality and compliance are able to strike a harmonious balance within your supply chain, you create operational efficiencies that are able to create opportunities for growth in the marketplace, something your brand can benefit from by setting you at a bench mark above the rest In this blog post, we seek to uncover the importance of both quality and compliance and the benefits they have to manufacturers, suppliers and retailers all over the world, ultimately taking a closer look at what the perfect union of these two concepts can mean for you.

The case for quality

When one speaks of the quality of a product from a manufacturing perspective, it refers to the external review of a product. It seeks to satisfy consumers through its quality with regards to design, functionality, durability and aesthetic appeal. Quality vs compliance - aesthetic furnitureThe quality of a product can be defined in many ways and is almost always dependent on your specific consumer and their definition of quality for your specific item. So in that light, you will need to know exactly what your consumer is looking for to create the quality your brand is looking to achieve. When a consumer sets out to look for a quality product, they want to feel as though they have paid less than what the actual product is worth, the quality of the product far surpassing the amount they ended up paying. Fulfilling the need to exceed the consumer’s expectations, this is what true quality is all about. If fulfilling the need to meet your consumer’s expectations is at the top of your company’s agenda, is it not essential for your brand’s products to meet a level of quality that does just that? Let me leave you pondering that for a bit. In attempting to understand your customer’s definition of quality, it will be important to note that fulfilling consumer expectation and experience forms a part of that definition. Let me give you an example; If a consumer orders a product that has met and passed all quality tests it needed to meet, that product for all intents and purposes is a quality item. But, if the order arrives later than promised or arrives with a missing screw or the incorrect color, the consumer may not define this product as an item of value and quality. Striving for product quality is a stems right from the raw materials used, to the way in which it arrives to your customer, therefore every step needs to be taken into consideration.

The case for compliance

When a brand takes on compliance, it seeks to meet the minimum regulatory requirements specific to a product or item sold to a retailer. This may mean that although the product is not of the highest quality, it at least meets the minimum mandatory regulation requirements specific to it. Depending on your product’s destination market, it will likely need to comply with one or more of the following; * Product safety regulations * Substance regulations * Document requirements * Labeling requirements * Testing requirements You do not have to comply with all of these; as it will depend very much on your product and the market that it needs to enter. The importance of compliance is highlighted none the better than with the recent global Quality vs Compliance - Fidget Spinnerscraze of fidget spinners and, where 200, 000 of these spinners have been recalled due to it massive non-compliance failures. Many of these items that are being imported have been found to be non-compliant with the regulatory requirements specific to its markets. This is becoming a big problem as they have also proven to be a danger to children as the small parts they are made out of can and are causing serious harm. Where the confusion sets in, is that a product is capable of being compliant, but also not be the best quality product. The opposite is also true; you can have a quality item that does not meet all the regulatory requirements either. An issue like this can often arise within your supply chain whether it be in the design process, or even within the manufacturing process. This can create a high level of risk for your brand, and could land you in a position you do not want to be in.

The case for supply chain synergy

So as the debate goes, we seek to uncover the myth that quality supersedes compliance and vice versa. They need to work together, hand-in-hand, where they can create true value for your brand through optimized quality procedures from your factory to the consumers. Striving for compliance means to create operational efficiency for your supply chain. This means continuous improvements for your brand and its systems. These improvements can take the form of a compliance program which will begin to address the quality procedures (operationally and product quality) of your entire supply chain. The improvement of these systems will mean that you reduce your exposure to risk and also create a more visible and transparent supply chain, which consumers today base their buying decisions on. Always keep this in mind. A compliance program will also extend into the manner in which you select your supplier and evaluate the factory that your product will ultimately be made in. Ensuring that your supply chain is compliant will mean that you are essentially creating quality operating systems. Quality operating systems will mean that the product you produce is being made in the most optimal environment. A well-functioning environment where quality and compliance is a part of every operating system will flow into the very essence of your product, making consumers want to purchase your product at a price that they feel is undervalued for an item of such great quality Today’s consumer is empowered with access and knowledge into your product and your supply chain;Quality vs Compliance they want to know where its raw materials were sourced, how it was made, who made it and what its level of quality is. They ask themselves whether or not your product will be an investment in their lives. The key here will be to know your target market, know your consumer. If you do not know what they want, you will struggle to be their go-to brand; you will lose out on their brand evangelism and praise affecting your bottom line “Is this the type of brand and product you wish to create?” Retailers today are under so much pressure with the current supply and demand of products, that quality and/or compliance is not always a priority. “But, it should be!” Bad quality and non-compliance both mean that your brand is at an unnecessarily high risk with regards to meeting regulations and your reputation. It will be worth all the hard yards that you put in from the creation and design to the manufacturing and distribution of your products. This will help mitigate unnecessary risk, saving you money and precious time.

Conclusion

These two concepts can be integrated into your supply chain through a Quality Management System – “QMS is a set of policies, processes and procedures required for planning and execution of a product or service.” This should help you create a structured system for continuous improvements that can be made to all areas of your supply chain and its operations. Today’s empowered consumers show us just how important both quality and compliance are for your products and brand. It will be important to make these a priority in order to maintain that globally competitive advantage. If you are interested in learning how to build a compliance program that also addresses product compliance within your supply chain take a look at the eBook we wrote on how to go about doing just that.

Get started with your very own compliance program today!

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Golden Samples & Improved Quality (DIY & Tools Factory)

So you want to import DIY tools into Europe, you’ve sourced your supplier in Ningbo, China where you place an order for a shipment of a variety of DIY tools like hammers, star and flat screwdrivers as well as 8 meter tape measures. Your shipment arrives, but your hammer handles are the wrong color and the color of the flat and star screwdrivers are swapped around.If you have had these kind of experiences with quality that is below standard or defect rates that you just can’t seem to reduce, you may need to consider establishing a golden sample from your supplier to eliminate any unnecessary areas of risk.

Why?

Sourcing abroad is a challenge. As a means of overcoming this challenge, we recommend establishing a golden sample which is deemed industry best practice. Along with your golden sample you should consider the use of a third-party quality provider to ensure the quality of your sample is of the highest quality.

Why are golden samples important for improved product quality?

A golden sample allows you to evaluate the quality of product that your chosen supplier can produce.

This process gives you a baseline for how you will continue with your supplier. It will showcase how they interpret your product specifications and how they can stick to them.

**Insiders Tip

Have you communicated your product specs clearly?

Product specifications can be sent to your supplier in the form of drawings, sketches or images with the correct dimensions and color specifications. A hammer will have a particular color handle, the same with the screwdrivers, so be sure to mention this in your spec sheet.

There is no such thing as too much. Add everything to minimize any confusion.

Why?

You are up against cultural, language and distance barriers, so be as specific as you possibly can be.

Once you have received your golden sample from your supplier, you will need to evaluate whether the quality level is acceptable or not. Once you approve this, you can then give your DIY tool supplier the go-ahead for mass production.

What goes into approving a golden sample for DIY tools?

You need to make sure that your golden sample has met all product specifications along with the necessary compliance standards and regulations.

How do you go about this?

As you would normally do with production…

By inspection.

Your golden sample can be inspected for any visible defects; you can also send it off to a lab for corrosion and chemical testing.

The corrosion test commonly used according to ISO 9227:2017;

Neutral salt spray (NSS) –  useful for detecting discontinuities, such as pores and other defects, in certain metallic, organic, anodic oxide and conversion coatings.

The type of chemical tests commonly used for plastic handles;

Polycyclic Aromatic Hydrocarbons (PAH) – Is a harmful carcinogenic. A consumer can be exposed when a product comes into direct and prolonged or repetitive contact with the skin or the mouth. High doses of this substance can lead to recalls like the below product;

Mallet recall.jpg

Short chain chlorinated paraffins (SCCPs) – SCCP’s persist in the environment and are toxic to aquatic organisms at low concentrations and bioaccumulate in wildlife and humans, posing a risk to human health and the environment. The below hammer handle contains SCCP’s (A banned substance) as well as PAH and has therefore resulted in a recall of the below hammer;

Hammer recall.jpg

There are three common testing types to ensure improved product quality for your DIY tools like;

  • User testing; this kind of testing evaluates the ergonomics of the tools that have been produced. This evaluation will be based on your product specifications and the overall purpose of the product; e.g., A hammer to hammer nails into walls, so the handle length, grip, and head will be evaluated accordingly. An example of this would be the below axe in which the handle can crack after use, which dislodges the axe head, which poses a serious injury risk to the user or even bystanders.

Axe_Recall_.jpg

  • Comparative testing can also be done. This test is done to evaluate yours against a competitor’s. The functionality, safety, and ergonomics will be evaluated. This kind of test will give you insight into the kind of quality your brand should be achieving.
  • Hardness testing – While this is not a testing requirement, this measurement forms an objective criteria for either the metal or plastic components of the item. For example; the hardness of the metal part of a hammer could affect the performance and durability of the product likewise the plastic could affect the feeling when holding the handle of the product.=

Therefore golden samples are not only used to evaluate acceptable quality limits for your DIY tools factory.

What do I mean?

A golden sample will be of huge value for your third-party quality inspection service provider so that they can compare what has been produced through the mass production process to that of the golden sample.

Key Takeaways

Establishing a golden sample is industry best practice, and it is never recommended to begin your mass production process without an approved sample.

This sample allows you to benchmark your supplier and hold them accountable to your acceptable quality levels.

Key things to remember;

  • Communicate your product specifications clearly. Bear in mind that you are facing cultural, language and distance barriers, so clarity and over communication is an absolute necessity.
  • Approving your golden sample requires due diligence; be sure to send your golden sample for the appropriate inspection and testing.
  • Know your testing and inspection procedures to ensure improved product quality for your brand.

Be sure to remember that your golden sample is reflective of an ideal quality standard from your supplier, and is not a reflection on the mass production process of the factory.

This method of reducing product defects for your brand will help avoid costly delays addressing defects after the fact. Adopting best practice sets you in the best possible position for sustainable and competitive growth.


 

TAKE A DIVE INTO OUR QUALITY INSPECTION GUIDE for IMPROVED PRODUCT QUALITY and reduced defect rates

 

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8 Steps To Limit Risk in Your Toy Testing Procedures

Production competitiveness has become so high in countries like China that suppliers often find ways to cut corners in order to save costs, often putting the quality and safety of your toys, and their extremely vulnerable user base, in jeopardy. When it comes to upholding product safety and compliance, no other consumer goods product is more highly regulated than toys. However, despite stringent requirements and mandatory safety toy testing around the world, unsafe children’s products continue to reach the market today.

As recent as 2017, many importers of the popular ‘fidget spinners’ were found to be selling products in the US that contained alarmingly high levels of mercury and lead leading to mass product recalls and damaged brand reputations.

Non-compliance in the toy industry present a myriad of dangers for brands that can lead to heavy financial losses, unnecessary recalls, and a damaged reputation. It’s reasons like these that quality managers constantly live in fear of quality issues with toys, but it doesn’t have to be this way with strict compliance regulations and proper toy testing procedures.

Improving Your Existing Toy Quality Assurance Processes

Toy quality assurance and toy testing As a quality manager who is responsible for producing toys you know that where quality is concerned the stakes are sky-high. You need to know that toys adhere to the demands of every test they might face when being exported globally to markets with different demands. At API, our quality inspectors and laboratories follow a comprehensive set of 8 toy quality testing steps (built through decades of experience) that helps quality managers effectively manage quality right from the outset. This article will take a brief look at the global toy testing standards themselves, and the step by step procedures API follows to help minimise the risk of quality issues sneaking through and danger of recalls happening, as well as protecting your supply chain and ensuring customer safety and satisfaction.

API’s 8 Step Toy Quality Assurance Process

Click here to watch our comprehensive toy testing process video

1. Preventing Mechanical Risks In The Design Stage

Product Design Specification (PDS) serves as the guideline for understanding the various problems identified early on in the design stage. Possibilities need to be investigated and filtered through various criteria laid out in the PDS to be set forth as practical, viable solutions that require further evaluation.

Through comprehensive design evaluation and hazard assessments, API help you identify potentially dangerous design features and mechanical risks from the outset, helping you save on costly redesign and engineering resources related to product modification, and more serious quality and safety issues later down the line. Furthermore, the evaluation also helps to identify all of the necessary tests that you would need to submit your product to.

2. Preventing Toxic Risks With Raw Materials Testing

Raw material toy testing to ensure toy quality Raw material quality control is paramount in helping to prevent product failure and ensuring a consistent level of quality that you and your customers expect. Making sure that players in your supply chain are continuously subjected to testing of raw materials being used in your toy production, or when they decide to switch suppliers, verifies that the materials are at the level of quality you’re paying for and that no toxic elements such as lead and cadmium finding their way into your finished product. Complying with chemical restrictions in raw materials laid out by the EU and US chemical content regulations such as REACH, EN71 and CPSIA starts with chemical testing. API’s laboratories help to identify toxic elements that can aid you in defining a list of approved materials to be used in the toy production process early on, ensuring your products comply with the limits set for safe use now and into the future.

3. Evaluating Toy Safety Before Mass-Production Through Prototype Testing

The practical solutions and tests identified in the design evaluation stage are embodied in the form of a prototype. The aesthetics, functionality, mechanical aspects, as well as the potential manufacturing issues are all considered, and these aspects need to be thoroughly tested. API’s technical experts are part of technical committees that discuss and write standards for toys, and can ensure you are up to date on the latest developments and discussions on regulation before new regulations are officially published. API’s Hong Kong Laboratory is accredited by HOKLAS to perform laboratory testing for the European, American and Australasian markets. The three main areas of testing are:

1) ‘Mechanical and Physical Properties’

  • Drop Test
  • Compression Test
  • Torque Test
  • Tension Test
  • Flexure Test
  • Bite Test

2) ‘Flammability’

  • Conducted on  toys to examine their flammability characteristics

3) ‘Restricted Substances – Chemical Testing’

  • Lead content test
  • Cadmium content test
  • Phthalate content test
  • Other applicable chemical tests

Prototype testing helps to identify the shortcomings of initial toy design and how they will hold up in real use case scenarios.

Toy testing at a factory

Evaluate your Factory

Perform a quality management audit with specific points related to toys, such as ensuring that sharp tool equipment and a broken needle policy has been used and properly calibrated. It is also important to ensure that your factory has also established traceability system for identification and tracking materials through production. Through this testing process, API helps you to further refine the product design and remove any obstacles that may detract from the original concept by making it safer for use, and ultimately, preventing the need for costly recalls well before the products hit the production line. On top of this testing process, API are also entitled to issue certificates of conformity as a ‘Notified Body’.

4. Ensuring Compliance Through All Inclusive Compliance Software

Whether your brand is directly or indirectly affected by Directive 2009/48/EC, it is of vital importance to ensure the collection and gathering of all the necessary technical documentation needed from your manufacturer to demonstrate the conformity of the product to the applicable requirements of the TSD.

It is up to your product manufacturer to draw up this technical documentation, or request it from relevant parties, and keep it and the EC declaration of conformity for a period of 10 years after the toy has been placed on the market. It is up to you as the importer to ensure that the manufacturer fulfills this duty, that the toy bears the required conformity marking, and is accompanied by the required technical documents. These documents must be made available to national surveillance authorities upon request for the same period of time to demonstrate conformity of the toy. Technical documentation to be drawn up and collected must be presented in one of the official languages in the EU and shall include: 1. Description of the design and manufacture 2. List of components and materials 3. Safety data sheets 4. Safety assessments 5. Conformity assessment procedure 6. EC declaration of conformity 7. Addresses of manufacture and storage 8. Documents submitted to a Notified Body 9. Test reports 10. Conformity of series production details 11. EC-type examination details 12. Conformity of series production details Today, many manufacturers, importers and retailers are still operating on outdated systems like collecting multiple spreadsheets and files, leading to unreliable data and outdated documentation, which creates an almost insurmountable task of trying to accurately trace and maintain the information for each product reference. API’s Technical Compliance File (TCF) solution is a one process procedure that consists of 5 steps to ensure total product compliance: 1. Expert intervention to define the scope of compliance 2. Document collection 3. Document review 4. TCF report issuance 5. Record keeping and database integration (all available online 24/7)
A solution like this promises increased visibility and transparency into your supply chain that will prove invaluable to optimizing your current quality systems, allowing you the time to mitigate any potential quality risks as and when they become apparent.

5. Monitoring Production Consistency With DUPRO/Inline Inspection

The production line is inspected when at least 25% of the order has been completed. The DUPRO verifies that initial discrepancies found out during an Initial Production Check (IPC) have been rectified.

Each stage of the assembly process will be analysed and samples of the goods in progress will be collected and checked. This means that any impending problem can be identified on-site and addressed at the very stage where it is occurring. By checking unfinished products during production and assessing if AQL standards are being met, API assures that corrective actions can be taken in order to assure the quality of your toys moving forward.

6. Checking and Classifying Non-Conformities Right Before Shipping

API conduct both Final Random Inspections and Loading Check inspections to ensure your products conform and that they are being shipped in a safe and secure manner.

Final Random Inspection

A FRI (Final Random Inspection) is basically an acceptance sampling inspection performed prior to shipment. The Sampling is derived from the inspection level requested in accordance with MIL-STD-105E (ISO2859-1). API is also certified HKIAS which endorses third-party inspection based on an in-house procedure. The sampled goods are then checked piece by piece and the non-conformities found, if any, will be classified into three categories (critical, major and minor). The selection of an AQL (Acceptable Quality Level) per type of non-conformities will determine the acceptance or rejection of the goods.

Sample Collection For Lab Testing

Products randomly picked from mass production for pre-shipment testing which can occur in DuPro or FRI. The test checks the alignment of product quality from mass production and pre-production.

Pre-shipment Testing

The aim of pre-shipment testing is to verify the consistency of the production quality with a focus on critical aspects of the toys, without having to perform the full test again. API provides tailor-made testing solutions based on client requirements to ensure quality is maintained at this stage of the process. Loading check inspections to ensure toy quality

Loading Check Inspections

The loading check serves as a way to control container quantity and to adequately manage stuffing arrangement. API performs inspections of packed goods as they are being loaded into the shipping container to ensure the correct products are loaded, in a secure and safe manner.

7. Taking Quality Assurance Full Cycle With Reorders and Random Sampling

Sample collection for testing during the reorder process is a concept of a highly effective continuous quality improvement monitoring program, helping you determine the frequency of testing per supplier performance. This policy sends a clear message to suppliers that you’re watching their product quality closely, and that any unauthorized product/material change is strictly prohibited, and at the same time encourages them to improve.

8. Business Intelligence Tools

In order to the determine the frequency of sampling per factory, you’ll need a comprehensive vendor scorecard. API have developed its own platform for you that records quality data of each factory’s test and defect levels during inspection.

It also provides you with a comprehensive data analysis on factory performance across your own suppliers and across others in our database that you may not currently be working with. The database record does not simply include just the pass or failure of the product test/ inspection, but also a record and classification of each defect. Through this database we’re able to point out top defects recorded per factory and compare your own suppliers against others in the industry.
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REACH – Extension of Phthalates Requirements (Entry 51)

As per the European Union additions published in December 2018, the scope of Entry 51 of Annex XVII to REACH Regulation (EC) No 1907/2006 has some changes starting on 7th July 2020. The changes include an increase in the number of restricted phthalates from three to four, and an extension of the scope of restrictions as per below:

 

Restricted Substances

Scope of Restriction

Current Entry 51

DEHP, DBP and BBP:
≤ 0.1% by weight of the plasticized material (individually or in combination)

Plasticized materials in toys and childcare articles

Revised Entry 51 as of 7th July 2020

DEHP, DBP, BBP and DIBP: <0.1% by weight of plasticized material (individually or in combination)

All articles containing plasticized materials*

What are plasticized materials?

  • Polyvinyl chloride (PVC), polyvinylidene chloride (PVDC), polyvinyl acetate (PVA), polyurethanes
  • Any other polymer except silicone rubber and natural latex coatings
  • Surface coatings, non-slip coatings, finishes, decals, printed designs
  • Adhesives, sealants, paints, and inks

DIBP was frequently used as a replacement for DBP for lots of plasticized materials. With the new restrictions in place, manufacturers will need to look for alternative options to comply with the normative.

What are the main product types affected by the extension?

With the extension of phthalates requirements (entry 51), all articles containing plasticized materials* will be affected.

These can include:

  • Indoor and outdoor furniture
  • Decoration articles
  • DIY items
  • Office supplies and equipment
  • Bathroom supplies and equipment
  • Accessories, gifts and premium items
  • And more.

*Exemptions

(As included in Annex XVII to REACH – Conditions of Restriction)

(a) articles exclusively for industrial or agricultural use, or for use exclusively in the open

air, provided that no plasticised material comes into contact with human mucous

membranes or into prolonged contact with human skin;

(b) aircraft, placed on the market before 7 January 2024, or articles, whenever placed on

the market, for use exclusively in the maintenance or repair of those aircraft, where those

articles are essential for the safety and airworthiness of the aircraft;

(c) motor vehicles within the scope of Directive 2007/46/EC, placed on the market before 7

January 2024, or articles, whenever placed on the market, for use exclusively in the

maintenance or repair of those vehicles, where the vehicles cannot function as intended

without those articles;

(d) articles placed on the market before 7 July 2020;

(e) measuring devices for laboratory use, or parts thereof;

(f) materials and articles intended to come into contact with food within the scope of

Regulation (EC) No 1935/2004 or Commission Regulation (EU) No 10/20111;

(g) medical devices within the scope of Directives 90/385/EEC, 93/42/EEC or 98/79/EC, or

parts thereof;

(h) electrical and electronic equipment within the scope of Directive 2011/65/EU;

(i) the immediate packaging of medicinal products within the scope of Regulation (EC) No

726/2004, Directive 2001/82/EC or Directive 2001/83/EC;

(j) toys and childcare articles covered by paragraphs 1 or 2.

Do you have any questions about how this extension will impact your products?

With the new restrictions in place, brands, retailers and manufacturers must ensure that the products placed in the market do not contain any of the restricted substances. At API, we can provide technical advice and adapted chemical product testing for your affected product categories to ensure your products comply with the new REACH requirements. Our combined expertise in chemistry x manufacturing x household goods and toys allows our experts to provide tailor-made solutions suited to your needs.