by Fredrik Grönkvist
In this Product guide, we explain what you must know about buying ODM (Private label) and OEM (Custom designed) jewelry from Chinese, and other Asian, manufacturers. Keep reading, and learn more about product development, sample production and production regulations, applicable to Jewelry. We also guide you through the various labelling and testing requirements.
Most jewelry buyers opt for factory standard components, rather than OEM (custom designed) parts. Most suppliers can, directly or through subcontractors, offer extensive jewelry part catalogs. Hence, you have the following options when designing your products:
I. ODM Products (no design changes): Base your design entirely on the supplier’s existing ODM designs
Customize an existing ODM Product: Modify an existing ODM product by adding or removing parts (i.e., custom designed labels).
II. Custom Design (using ODM parts): Jewellery can be designed ‘from scratch’ using existing ODM parts from the buyers catalog.
III. Custom Design (using OEM parts): Custom designed parts results in high tooling costs, especially when buying a large number of SKUs.
Product documentation must be prepared for each SKU. Making jewelry samples require attention to detail, and key specifications are easily lost in translation. In order to reduce the risk of an endless number of sample batches, prepare the following for all SKUs:
If you intend to design your own jewelry using ODM parts, you might consider buying said parts directly from the manufacturer, rather than assembled samples. This approach can save weeks, and enable you to test new designs in a highly cost efficient way.
The Self Assembled Samples shall then be returned to the suppliers, acting as Pre-Production Samples. However, make sure to order two sets of jewelry parts as you need to keep at least one piece of each SKU for your own reference.
If you on the other hand intend to base the design on the supplier’s existing ODM samples, you should buy assembled samples, rather than ODM components. This also enables you to test the supplier’s attention to detail. However, the samples are only as good as the sample documentation. As explained in this guide, you shall expect several sample revisions before you are ready to place a first mass produced batch.
Purchasing parts and materials is the first step of the production process. As quality issues, when manufacturing jewelry, tend to stem from the production of the parts, rather than the later assembly stage, you shall consider hiring an inspector as soon as the parts arrive at the factory. Hence, quality issues can be avoided at an early stage, thereby reducing the risk of severe delays.
The final, and most important, inspection shall be carried out when the products are fully assembled. Some defects, for example scratches, occur during assembly and packaging, thereby making the final, pre-shipment inspection, essential when importing jewelry from China. However, as always, clear instructions are the key to a successful outcome. Provide the quality inspection agency with all design drawings and component lists well in advance of the inspection date.
Jewelry is subject to various substance and ‘mechanical’ regulations in the United States, the European Union and other markets. Jewelry made for children younger than the age of 12 is also classified as a children’s product, and is therefore subject to additional regulations. The table below explains what jewelry imports in the US and EU must know:
The Consumer Product Safety Improvement Act (CPSIA) regulates all toys and other children’s products imported to, or made in, the United States. Visit this link to read more about importing Children’s Jewellery to the United States.
|US||CA Prop 65|
California Proposition 65 restricts more than 800 substances in consumer products. Unlike CPSIA, which only applies to Children’s jewellery, California Proposition 65 also applies to jewelry sold to adult. Compliance is mandatory if you intend to sell in, or to buyers in, California and employ at least 10 workers. However, even if your total number of employees is less than 10, most (online and offline) retailers still require compliance with California Proposition 65.
REACH (Registration, Evaluation, Authorisation and restriction of Chemicals) restricts content of SVHCs in all consumer products sold in the European Union. Compliance is mandatory for all Jewellery imported to the EU.
EN 71 Part 1
EN 14682:2007 (Safety of children’s clothing. Cords and drawstrings on children’s clothing specifications) and EN 71 Part 1 restricts cord and chain length to prevent strangulation. Click here to read more.
AS/NZS ISO 8124.1:2002 regulates children’s products sold in Australia and New Zealand, including jewellery marketed to children aged 14 or younger. Click here to read more.
Buyers outside the mentioned markets, for example, in Asia, might still want to consider to ensure compliance with an EU or US standards. While many countries may not have regulations specifically for jewelry, general consumer safety regulations do apply in many Asian, South American and Eastern European markets.
Platinum, Silver and gold jewelry are subject to Hallmarking requirements. Many countries have their own specific Hallmarking standards. Customs authorities are prone to checking imported precious jewelry, and improperly marked precious jewelry is likely to be seized.
Apart from Hallmarking, which doesn’t apply to non-precious jewelry (i.e., stainless steel and pearl jewelry), country of origin markings may apply.
Whether or not compliance testing is mandatory depends on the market and the applicable regulation / directive. Compliance testing and certification is normally mandatory when importing Children’s Jewellery. However, even when testing is not mandatory, compliance always is. Hence, the question of whether or not your company shall submit samples for testing is often a matter of risk management.
It’s also a matter of costs. Testing companies charge based on the number of samples. A necklace, for example, can consist of 5 to 10 different components and thereby result in very high testing costs.
The testing cost per SKU can range from $100 to $800, depending on the regulation and the number of different parts. Testing an entire Jewellery collection is therefore very costly. There are, however, a few strategies that can help you reduce the testing costs:
Your parts can either be tested according to a specific set of substances, for example, those restricted by California Proposition 65 or part of the REACH SVHC list, or specific substances (i.e., lead, nickel and cadmium). However, keep in mind that some regulations, for example CPSIA, require that each SKU is certified, rather than individual parts.
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/.