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No more wing and a prayer

Compliance is not an issue that can be swept under the carpet. Suppliers have to work to instil best practice, says Andrew Gorrie

Gone are the days in our industry where suppliers can ‘wing it’. During the past 15 or so years, the EU Commission has systematically introduced new legislation for product compliance. One part is for safety which makes logical sense, but the other part is for the environment which can be misconstrued. 

Well known British safety standards have been incorporated into EU legislation but Germany, Holland and France have been the spearhead of new requirements. The REACH regulation which means ‘Registration Evaluation Authorisation of Chemicals’, was introduced in 2008 and is the most challenging for manufacturers and importers.

The easy part is registering chemicals imported into the EU in amounts of more than one tonne per year. The more difficult part is assessing if a product contains a Substance of Very High Concern (SVHC). There are currently around 168 substances on the list but some are banned such as AZO dyes within garments and phthalates in toys. The difficulty is risk assessing a product because the downstream supply line is so long that one has to go back to the actual chemical companies. Retailers do not want to advertise SVHCs in their products as any public relations person would expect. Laboratory testing is expensive unless it can be amortised over a large quantity.

We have recently had three major corporations request documentation to prove compliance to EU regulations because they have woken up to the fact that if their name is branded on the product, they have to take responsibility. Ultimately the manufacturer or importer (the producer) would be liable but the first call would be to the name on the product.

Brand Addition imports products as well as buys from local importers, decorators and manufacturers. We have been following mandatory EU compliance testing since the 1990s but sadly a lot of local companies have not, as we have discovered in recent months. Product compliance documents sent to us have been either out of date or meaningless because the vendor does not know the regulations. Sometimes the vendor does not have any compliance documentation.  

We have therefore been proactively running workshops to educate suppliers and to persuade them to carry out risk assessments on their products, and these have proved quite successful. 

During the past four years, we have had to recall three different products from the market due to non-compliance with EU directives, or quality in one case. One example was a travel adapter which should have complied with a safety test so that two plugs could never be exposed at the same time. Unfortunately, it was possible to have a live circuit exposed with the result that a person could suffer an electrical shock. Product recalls are expensive, time consuming and damage the reputation of the end client as well as us.

Nowadays the risks are too high for non-compliance and we are working with local vendors to persuade them that the old days have gone.

Andrew Gorrie is senior quality manager at Brand Addition

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