Product safety requires both a broad overview and focus on detail
Product safety requires both a broad overview and focus on detail
Companies are experiencing an increasing demand from all sides to know what their products contain. And there is no indication that this trend is abating. This places great demands on product safety, and not least on the employees who are responsible for product safety. It requires both an overview and a focus on detail to ensure that the articles you buy comply with the regulations they must, according to consultant Lars Wassmann, Mediator A/S.
Basically, all items bought or sold in Europe must comply with REACH, the EU's chemicals legislation. And it is not without reason that it is called the strictest legislation in the world. REACH operates with three lists, among others: The Candidate List, which contains substances suspected of being endocrine disruptors. The Authorisation List, which contains hazardous substances that are banned 1-2 years after they have been added to the list, and the Restriction List, which contains substances that are banned in certain contexts.
– When it comes to product safety, we are dealing with an area that is so complex that even a single word can have an impact on whether one or the other piece of legislation must be complied with. In addition, there are ongoing changes that must continuously ensure the responsible use of hazardous substances with the least possible impact on the environment and health, and that hazardous substances are replaced by less hazardous substances. If you have a wide product range, it requires an enormous overview to take into account and, not least, to implement the changes, for example when a substance moves from the candidate list to the authorization list, explains Lars.
The handbag that became a toy
A very special discipline within product safety is the so-called borderline products, which for one reason or another suddenly fall under different legislation. And here Lars Wassmann has a wealth of examples, some more entertaining than others.
– The legislation for toys is much stricter than for many other products, and it doesn't take long before the strict rules come into effect. One of the better examples was a women's bag that had a small teddy bear in the zipper. This meant that the bag could be considered a toy, and therefore there were suddenly some much stricter rules for what the zipper can contain, says Lars and continues:
– The same applies to bicycles, for example, where we have a special rule in Denmark. Imagine that the buyer is at a trade fair and sees a bicycle in three different sizes. He buys all three, but the smallest of them has such a low seat height that it suddenly falls under the legislation for toys instead. Even though it is the same bicycle as the other two, just smaller. It really requires that you know the legal stuff to avoid getting into trouble.
Conformité Européenne or China Export
When buying goods in China, it is important to obtain the necessary documentation to ensure compliance with the regulations. Toys, machinery, electrical appliances and medical equipment, among others, must be CE marked as a guarantee that the product complies with EU legislation.
– In principle, it is the EU producer who must ensure that there is CE mark on. This also applies even if you are an importer. In the EU, you are a manufacturer even if you have imported the product. Therefore, it is important to get as much documentation as possible from the supplier, because the product is CE-certified, the authorities will see documentation, says Lars, adding:
– As an extra leg brace, there is a marking that looks suspiciously similar to the CE marking, but which stands for China Export. You just have to take a closer look to see the difference, and fortunately, the certificate and test report can always be looked up at the major testing agencies if you have any doubts about the authenticity.
Clear solution models
According to Lars' experience, it's about having a system that is easy to set up, control and maintain.
– Depending on the type of business you run, there are different solution models: List of unwanted substances, material specifications, product specifications and a combination of material and product specifications, explains Lars and elaborates:
– If you produce articles yourself, you can prepare a list of unwanted substances so that sub-producers have control over which substances are not allowed to occur. The list of unwanted substances is easy to prepare and can be divided into materials to make it clear for the recipient. A product specification makes it easy for suppliers; it is easy to check, but on the other hand, it is time-consuming to maintain. The material specification contains requirements for each individual part within plastic, textile, etc. It is more complicated for suppliers because there are several specifications per product. On the other hand, it is good for products that do not have special requirements. The combined material and product specification is the best if you have a standard or legislation that must be complied with. The difficult part of the exercise is that you have to go into each individual product and choose which specifications should be sent to the supplier.
A question of interpretation
Although REACH is intended to help ensure that chemical legislation is standardized across Europe, there is still much to be aware of.
– In addition to the EU regulations, there are also national requirements. Therefore, you should be aware that even if you comply with a requirement in Germany, it is not certain that you will comply with the legislation here. In Denmark, the requirements for phthalate content in toys, for example, are stricter than in Germany. And to make it extra challenging, there may be differences in how the different countries interpret the EU regulations, concludes Lars.
If you or your company need professional consulting or advice on product safety, Mediator is always ready. Contact consultant Lars Wassmann on tel. 91892000 or lw@mediator.as for further agreement.