by Fredrik Grönkvist
Today, one or more safety standards and substance regulations apply to most consumer products imported to the European Union, United States, Australia and other markets. As compliance is rather exception than rule among Chinese manufacturers, third party compliance testing is often the only way to be sure that you are not importing non-compliant, thus illegal, goods. In this article, we guide you through the different types of compliance test and their each respective cost structure. We also explain what you can do to reduce said costs.
Substance regulations, such as REACH in the European Union and California Proposition 65, restricts substances in some, or all consumer goods. Such substances often include lead, cadmium, formaldehyde and phthalates. While batch testing is not always mandatory, compliance is. Therefore, an importer may choose to which extent its products shall be tested. Testing companies set the cost based on the number of substances (as requested by a certain regulation or standard) and the number of materials or variations, of said material. The following may count as a variation:
Thus, the same fabric, but dyed in different colors, are considered two different variations. It makes perfect sense, as their chemical composition differs, albeit to a limited degree. However, product testing companies often allow up to 4 or 5 different materials or variations per compliance test, without extra cost. Testing one material for one substance can cost as little as $40 to $50. However, both REACH and CA Prop 65 lists hundreds of substances. Importers should therefore expect their fabric and material substance testing to cost somewhere between $300 to $550.
Depending on the market and usage, furniture, construction materials, children’s products and clothing may need to be compliant with at least one applicable fire retardant standard. The testing costs are usually set on the number of materials, each test costing around $120 – $300. However, such third party testing may not always be required. Certain fire retardant standards, such as the German DIN 4102 (B1) standard, set requirements for flame height and extinguishing time that can be tested by a trained quality inspector on site. That being said, many retailers still require a proper test report.
Most countries and markets have some sort of mandatory safety and performance standards concerning electronic products. In the European Union, there are various such directives, including the EMC Directive, Low Voltage Directive and R&TTE. In the United States, all electronics must be FCC Part 15 compliant, and Australian importers must ensure compliance with similar regulations. A compliance testing company can, through testing, verify if your product is compliant with all applicable regulations and safety standards, and provide the necessary test files acting as support documentation, or technical files, for the Declaration of Conformity. In the case of the EU, such certification is mandatory.
Electrical safety and EMC compliance testing can cost between $800 up to $5000, or above – for more complex systems. However, what a testing company cannot do is to actually make the product, or system, compliant. Ensuring, for example, compliance with the European Union EMC Directive requires extensive technical expertise on the supplier side, extra shielding and high quality components. All of which translates into higher unit prices.
Originally developed and implemented in the European Union, RoHS was put in place to restrict usage of certain heavy metals, including lead and cadmium, in electronic components and solder. Now, South Korea and India are rolling out similar legislation, all having a major impact on the world’s electronics industry. Fast forward a decade, and the restricted heavy metals may be entirely phased out. However, that’s not where we are today. Compliance testing may not be mandatory, but compliance is. The good news is that companies, such as Asiainspection.com, offer RoHS testing for only $10 per component. Then again, your phone is made of quite a few components.
Children’s products and toys are, for obvious reasons, regulated in most markets. What differs such compliance testing is that the scope of regulations, applicable to toys and children’s products, cover many different aspects, including substance restrictions, electrical safety and mechanical / physical properties (e.g. plastic buttons and drawstring length). Many different types of tests may be required to ensure compliance, thus driving up costs. Furthermore, compliance testing, sometimes on every batch, is mandatory when importing toys and children’s products.
Whether or not compliance testing is required by law differs between regulations, markets and products. However, as mentioned many times in this article, compliance with said regulations is never optional – and it’s always you, the importer, not the supplier, that is ultimately held responsible to do so. Importing and distributing non-compliant goods may not only result in a forced recall, but also major fines, or even a lawsuit. The conclusion is that it’s entirely up to you to decide on ‘how sure’ you want to be.
You may choose to hope for the best and skip out on essential testing, therefore running the risk that you are in fact importing illegal products. Considering that non-compliance with overseas regulations is rather rule than exception among Chinese manufacturers, that is a very bad idea. What you should do instead is to apply a procurement strategy that allows you to reduce said testing costs. As all testing costs are essentially multiplied based on the number of SKUs and/or materials, you may consider the following:
The benefit of the 3rd point is that it may also enable you to reduce the MOQ, which is of great benefit when placing test orders from new manufacturers.
Portable devices are rapidly developing, which will allow quality inspectors to carry out substance, electrical safety, EMC and other compliance testing for low costs directly in the factory, thereby reducing the need for submitting samples to a third party testing company. New technology combined with increasingly strict regulations is set to drive down testing costs in the decade to come. Until then, however, we remain in the twilight zone where importers are squeezed in between high costs and strict regulations.
|Type of testing||Cost Structure||Cost Range|
|Fabrics & Material Substances|
4. Other variations
5. Number of applicable regulations / restricted substances
a.) $40 – 80 (single substance and material)
b.) $300 – $600 (several SVHC and materials)
2. Number of applicable regulations
|$120 – $300|
|EMC & Electrical Safety|
2. Number of applicable regulations
3. System complexity
4. Number of subsystems
|From $10 / Component|
1. Number of components
|$800 – $1500|
|Toys & Children’s Products|
1. Number of applicable standards (e.g. mechanical, substance and electrical)
2. Number of SKUs (only material testing is not always allowed)
$200 – $3500
Fredrik Grönkvist is the co-founder of ScandinAsian Enterprise in Shanghai. Since 2010, he and his team have helped hundreds of companies worldwide, primarily in the EU and US, to develop and manufacture products in China. He is also the main contributor on www.chinaimportal.com, a leading knowledge base for small- to medium-sized enterprises importing from Asia. For further questions, you can contact him on www.chinaimportal.com/contact-us/.