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What Safety and Compliance Evidence Private Labellers Want to Receive From Their Chinese Suppliers

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Look, your brand reputation and future are on the line. Don't accept excuses, and read what you need to receive from your supplier. Or otherwise, go elsewhere.

A representative of a company selling products under their private label recently asked the following question. If you’re selling in the EU or UK, our reply might be helpful for you as well.

One of our suppliers from Far East has a certificate from 2016. They are telling me that they provide a self-declaration of the compliance to the regulation, and that is the reason for not updating the certification. Is this correct?

“Your company is selling under its brand various products that it buys from suppliers in the Far East. The regulations in the EU and UK require any product sold in the market to be safe and comply with its laws and regulations. The safety and compliance of those products depends on the suppliers product design and manufacturing process.

So please consider this: in the EU and UK, your company is liable to pay compensation for defective products and it is subject to possible recall measures and fines for products it purchases from a supplier on the other side of the world. Ask yourself: What securities you would like to receive from the supplier to ensure you can sell the product without safety and compliance concerns?

Self-declaration does not relieve the supplier from testing and conformity assessments. It still means that conformity of the products with the regulations/standards is assessed. If your supplier provides a ‘declaration’ without actually assessing the requirements of the regulations and standards have been complied with, the document has no value. It would be like signing a piece of paper declaring: “You can trust my blue eyes.” Particularly because your company is liable and takes over responsibility for product compliance, you’ll want a little more evidence. At least, you should. 

Whether a supplier provides a self-declaration or a certificate, you will still also want to receive a test report or assessment report that includes the minimum following information:

  • which product they assessed (product name and model number(s))
  • what test or assessment methodology was applied (e.g. which standards were used)
  • the date of the assessment/test
  • full names of the person(s) who conducted the assessment/test
  • if test equipment was used, a list of the test equipment that was used (with reference to their calibration records)
  • pictures of the samples under test

If your supplier is unwilling* to provide you with the necessary test reports, there is no other solution than that your company commissions the tests or conducts the assessments. It is an essential part of its compliance files. The authorities will demand these, and they will not accept a self-declaration alone.

* A supplier cannot claim to be unable to conduct the testing/assessments. It is always able to send samples to a test laboratory. Most often, those suppliers are simply not willing to pay for the testing and certification costs. Now these costs will fall on your company. With that in mind, the offers from suppliers you have dismissed may start to make more sense, if their prices may have include the costs of testing and certification.”

If you are in similar situation and would require further assistance, our experts at Alura Group can guide you throughout the way. 

Contact us via the contact details or webform provided here: https://aluragroup.com.