GB Testing in China – New Requirements, Time to Get Ready Ben DeVito, Sales Manager, Consumer Products – Retail, TÜV SÜD America, Inc. Moderator: Danielle Abdul, Government Relations Manager, AAFA Webinar sponsored by GB Testing in China – New Requirements, Time to Get Ready Presented by Ben DeVito 978-427-0901 bdevito@tuvam.com April 30, 2013 TÜV SÜD Product Services Choose certainty. Add value. Today, TÜV SÜD stays true to its founding principle of protecting people, environment and property against the adverse effects of technology. TÜV SÜD Product Services Slide 3 Our heritage: 146 years of business success 1866 Establishment of a Mannheim-based steam boiler inspection association by 21 operators and owners of steam boilers, with the objective of protecting man, the environment and property against the risk emanating from a new and largely unknown form of technology 1910 First vehicle periodic technical inspection (PTI) 1926 Introduction of the “TÜV mark / stamp” in Germany 1958 Development of a Bavaria-wide network of vehicle inspection centres in the late 1950s 1990s Conglomeration of TÜVs from the southern part of Germany to form TÜV SÜD and the expansion of business operations into Asia 2006 Expansion of services in ASEAN by acquiring Singapore-based PSB Group Launch of Turkey-wide vehicle inspection by TÜVTURK TÜV SÜD pursues a strategy of internationalisation and growth 2009 Today TÜV SÜD Product Services Slide 4 TÜV SÜD in numbers: Growing from strength to strength 1 One-stop technical solution provider 150 years of experience 800 locations worldwide 1,700 million Euro in sales revenue 2011 17,200 employees worldwide TÜV SÜD Product Services Slide 5 The Consumer Products Division Testing & product certification Chemical, physical, mechanical, electrical and environmental testing and product certification. TÜV SÜD Product Services Inspection Product, system, building, plant and infrastructure inspection. Auditing & system certification Audits system certification in a variety of fields including quality, safety, energy, social compliance and environment. Slide 6 Knowledge services Safety, quality, risk, environmental protection and regulatory advisory. Training Training in work safety, technical skills, management systems and executive programs. Our asset. Your advantage. TÜV SÜD: A brand synonymous with quality and safety. Our certification marks and certificates are excellent marketing tools for our customers. Our test reports provide customers with the confidence to market their products’ safety, quality and sustainability attributes. > 320,000 product certificates TÜV SÜD Product Services Slide 7 > 46,000 system certificates TÜV SÜD Product Services Slide 8 1 GB - Review 2 GB - What’s Next 3 GB – What We’ve Learned 4 Summary GB is Guobiao This webinar is the sequel to “Enter the Chinese Market with Ease” which was presented last August. GB standards are the Chinese national standards issued by the Standardization Administration of China (SAC). The SAC is a department of AQSIQ. Mandatory standards are prefixed "GB". Recommended standards are prefixed "GB/T" (T from tuījiàn, "recommended"). TÜV SÜD Product Services Slide 9 30 April 2013 Ministry of Foreign Affairs General Office of the State Council …… TÜV SÜD Product Services SAIC …… Hong Kong & Marco Affairs Offices State Food & Drug Administration Slide …… Direct Units …… …… State Administration of Grain (total of 14) State Bureaus of Letters & Calls (total of 4) The Chinese Academy of Sciences (total of 18) Admin. Offices Xinhua News Agency Direct Institutes Taiwan Affairs Office (total of 28) General Administration of Quality Supervision, Inspection & Quarantine Departments State Administration of Industry & Commerce General Administration of Customs Ministry of Commerce Organizational Chart of State Council of P.R.C The State Council of the People's Republic of China Direct Bureaus (total of 11) AQSIQ 30 April 2013 Stakeholders of Product Quality Supervision in China State Administration for Industry and Commerce (SAIC) SAIC is the authority at ministerial level directly under the State Council. It is mainly responsible for: • Regulate the market through administrative enforcement. • Regulate product quality and food safety in the market; protect consumers’ rights and interests in the service sector. • Lead and guide operation of local Administrations for Industry and Commerce (AICs) nationwide. SAIC directly administers the following bureaus provincially : • Administration for Industry and Commerce (AIC) • Consumer Association (CCA) TÜV SÜD Product Services Slide 11 30 April 2013 SAIC – Has 2 Main Departments AIC – Administration for Industry and Commerce Works in conjunction with QTS as opposed to CIQ Has inspection responsibility for local Market. These local market checks are random in nature. CCA - Consumer Association Where a consumer can report a non-compliant product CCA has a hotline – phone number that Chinese consumers can call Has inspection responsibility for local Market. When CCA receives a complaint they will work with AIC to test TÜV SÜD Product Services Slide 12 30 April 2013 Stakeholders of Product Quality Supervision in China China Consumer Association (CCA) Approved by the State Council and managed by the SAIC, CCA is mainly responsible for: • Provide information and advisory services to consumers • Participate in the supervision, inspection of goods and services with the relevant administrative and government departments • Bring to the attention of and make recommendations to the relevant departments on issues concerning the interests of consumers • Manage, mediate and investigate consumer’s feedback and complaints • Request for evaluation from the quality department of goods and/or services • Support consumers in the pursuit of litigation when their interests have been violated • To expose activities that infringe consumer interests through the mass media TÜV SÜD Product Services Slide 13 30 April 2013 Stakeholders of Product Quality Supervision in China General Administration for Quality Supervision, Inspection and Quarantine (AQSIQ) AQSIQ is a ministerial-level department under the State Council of the People's Republic of China that is in charge of national quality, metrology, entry-exit commodity inspection, entry-exit health quarantine, entry-exit animal and plant quarantine, import - export food safety, certification and accreditation, standardization, as well as administrative law enforcement. AQSIQ directly administers the following bureaus provincially: • Entry - Exit Inspection and Quarantine Bureaus (CIQ) Responsible for imported and exported goods as well as the supervision and quality control of domestically circulated imported goods • Bureau of Quality and Technical Supervision (QTS) Responsible for management of production and supervision of product quality TÜV SÜD Product Services Slide 14 30 April 2013 AQSIQ – Has 2 Main Departments CIQ – Oversight at the Import and Export Responsible for conducting 100% Inspections (pulling samples for testing and evaluation) against GB standards. (heightened enforcement as of January 1, 2011, for certain HS codes) QTS – Local product oversight Both CIQ and QTS have QA responsibilities Both CIQ and QTS have their own labs QTS will conduct its own, independent annual “inspections” as requested by the local government. For instance: 1. QTS may get a request by local government in winter to check on “feather and down” products. 2. QTS, on 1 Sept. school starts so QTS may get a request by local government to check children’s garments TÜV SÜD Product Services Slide 15 30 April 2013 Introduction to China Quality Standard System China’s Quality Standard System is defined into four levels: Standard Level Code Definition Level 1: National Standard GB The most stringent technical requirements nationwide. Level 2: Industry Standard FZ: textile industry QB: light industry Applicable in a certain industry and not related to national standard. Level 3 Local Standard DB Enacted by local government and applicable only locally in a specific industry Level 4: Enterprise Standard Q Internal standard developed by a company and registered in the database of related government department Note: If there are more than one standards applicable to a given product, the more stringent requirement needs to be adopted. TÜV SÜD Product Services Slide 16 30 April 2013 Summary of Government Stakeholders CIQ AIC QTS CA *Government department Government department *Government department Half government organization Scope of enforcement based on HS code By brands By product Items sold in domestic market Enforcement frequency Never in domestic circulation Very frequent Seasonal Random Recall / Media exposure Impose fine**/ Media exposure Destruction of goods / Media exposure Media exposure Category Action required * CIQ and QTS have their own test facilities **Fines are in a range of : 50% x selling price x order qty to 3x selling price x order qty TÜV SÜD Product Services Slide 17 30 April 2013 Process for Importing Goods into China – 3 Levels of oversight CIQ Port Inspection and Supervision • Implement statutory inspection according to respective inspection requirements and regulations • On-site inspection • Testing and labeling review Entering The Market/ Department Store • Counter in Department Store: • Test report required by mall • Qualifications of test report: • CMA • CNAS • CAL (optional) • Store in Shopping Mall • No report required Note: CNAS: China National Accreditation Service for Conformity Assessment CMA: China Metrology Accreditation TÜV SÜD Product Services Slide 18 Domestic Market Supervision • AIC • Whole market regulator • Administer penalties for violations • QTS • Provide technical support to SAIC • Random market supervision • Issue CAL report • CCA • Complaint hotline XX315 • Media exposure 30 April 2013 Essentials for Department Stores – 3C Certification Criteria of Test Reports • Department stores require you to present test reports which satisfy the following conditions: a. b. Test reports should have the approval of: CNAS - China Accrediting Body CMA - China Equipment Calibration CAL logo • A requirement of most of the department stores. • Certification only available to Government Labs in mainland China Product quality conforms to: Safety code: Label requirement: GB 5296.4-1998 (2012 version will implemented on May 1, 2014) Quality requirement: Product standards TÜV SÜD Product Services GB 18401-2010 Slide 19 30 April 2013 Potential Pitfalls Frequently failed test parameters identified during market supervision conducted by the SAIC Note: Percentages refer to the number of cases where products that do not meet the requirements of the stipulated test parameter. Calculated by SAIC Shanghai in 2011 TÜV SÜD Product Services Slide 20 30 April 2013 GB 5296.4- 1998 (look for update for v. 2012) Labeling Requirement Product Name Cotton Knitted Underwear Permanent Label Type and Size XX-XXX Type and Size: Product Standard GB/T 8878-2009 General Safety Requirement Fiber component and Content: GB 18401-2010 A or B Care Instruction: Product Grade Acceptable (not required for v. 2012) Certification QC-001 Fiber component and Content XX% XX% GB/T 8685-2008 Country of origin XXX FZ/T 01053-2007 Manufacturer’s name XXX Manufacturer’s address XXX Tel. XX-XXXXXX Fax XX-XXXXXX Care Instruction TÜV SÜD Product Services GB/T 1335.1~1335.3 GB/T 6411 Slide 21 30 April 2013 Listing of Common Textile Product Standards Knitted Garments Woven Garments GB/T 8878-2009 Cotton Knitted Underwear GB/T 2660-2008 Shirts and Blouses FZ/T 43015-2011 Silk Knitting Garments GB/T 2662-2008 Cotton Wadded Clothes FZ/T 73005-2012 Low Wool Content And Wool Like Knitting Goods GB/T 2664-2009 Men's Suits And Coats FZ/T 73006-1995 Acrylic Knitted Underwear GB/T 2665-2009 Women's Suits And Coats FZ/T 73018-2012 Wool Knitting Goods GB/T 2666-2009 Women and Men's Trousers GB/T 22853-2009 Knitted Sportswear GB/T 14272-2011 Down Garments GB/T 22849-2009 Knitted T-Shirt GB/T 18132-2008 Silk Garments FZ/T 73009-2009 Knitting Goods FZ/T 81001-2007 Pajamas FZ/T 73010-2008 Knitted Workmanship Sweater GB/T 23328-2009 Woven garments for students FZ/T 73020-2012 Knitted Casual Wear FZ/T 81004-2012 Skirts And Skirts Suit FZ/T 73013-2010 Knitted Swimming Suits FZ/T 81006-2007 Jeanswear FZ/T 73016-2000 Knitted Thermal Underwear-Wadding Category FZ/T 81007-2012 Casual Wear FZ/T 73017-2008 Knitted Night Clothes FZ/T 81008-2011 Jackets FZ/T 73024-2006 Knitted Underwear In Chemical Fibers FZ/T 81009-1994 Garment with Faux Fur FZ/T 73026-2006 Knitted Skirt Suit FZ/T 81010-2009 All-Weather Coats FZ/T 81014-2008 Infant's Wear Updated since August 2012 TÜV SÜD Product Services Slide 22 30 April 2013 Product Standards (in addition to GB18401 test requirements) GB/T 8878-2009 Cotton Knitted Underwear Test Item Test Method Formaldehyde Content GB/T 2912.1 pH Value GB/T 7573 Presence of Odour GB 18401 6.7 Banned Azo Dyestuff GB/T 17592 Colour fastness To Water GB/T 5713 Colour fastness To Perspiration GB/T 3922 Colour fastness To Rubbing GB/T 3920 Above for GB 18401 part Fibre Content FZ/T 01057 etc. Colour fastness To Washing GB/T 3291 A (1) Dimensional Stability to Washing GB/T 8629 Ball Burst Strength GB/T 19976 Note: CIQ will test to all the testing listed, The product standard GB/T 8878-2009 is listed on the garment label TÜV SÜD Product Services Slide 23 30 April 2013 Footwear Testing Standards - Summary The contents in this workbook are only for internal reference. Tests will be performed according to the Original standards in Chinese Products' standards classification Leather and Leather Shoes Rubber Shoes Sports Shoes Others Products' Standards Products' Standards Products' Standards Products' Standards QB/T 1002:2005 Leather Shoes QB/T 2880:2007 GB Children's Leather Shoes 25036:2010 GB/T 22756:2008 Leather Sandals GB 25038:2010 HG/T 2018:2003 GB HG/T Leather and Fur-Limit of 20400:2006 2182:2008 Harmful matter Rubber Shoes-Healthy GB/T and Safety 15107:2005 Specification Children's canvas rubber footwear Casual Athletic Shoes HG/T 2019:2011 HG/T 2017:2011 Sports Shoes HG/T 2020:2011 GB/T 19706:2005 Football Shoes HG/T 3085:2011 GB/T Cotton-padded rubber 24152:2009 shoes QB/T 1873:2010 Upper Leather HG/T 2016:2001 QB/T 2680:2004 Lining Leather HG/T 2870:1997 TÜV SÜD Product Services Slide 24 QB/T Sport footwear for 2955:2008 basketball and volleyball Black rubber rain shoes Color rubber rain shoes Rubber -- Plastics adhesive shoes Casual Shoes Sport footwear for HG 3081:1999 Smash-proof rubber basketball and volleyball safety shoes Special table tennis sport shoes 30 April 2013 GB 18401-2010: Technical Requirements The General Safety and Technical Specifications of Textile Products are shown below: Test Item Formaldehyde content (mg/kg) (2) Product with Direct Contact to Skin Products without Direct Contact to Skin ≤20 ≤75 ≤300 4.0 to 7.5 4.0 to 8.5 4.0 to 9.0 - Water (Change in color, Staining) Grade≥3−4 Grade≥3 Grade≥3 - Acidic Perspiration (Change in color, Staining) Grade≥3−4 Grade ≥ 3 Grade≥3 - Basic Perspiration (Change in color, Staining) Grade≥3−4 Grade ≥ 3 Grade≥3 - Dry Rubbing Grade≥ 4 Grade ≥ 3 Grade ≥3 - Saliva (Change in color, Staining) Grade≥ 4 − − pH value (1) colorfastness Product for Babies 0 to 36 months None Unpleasant odor Dyestuff that produce banned aromatic amines Prohibited ( <20mg/kg) (3) Note: (1) For the products which have to go through wet conditioning in the subsequent procedures, the pH value can be extended to the range of 4.0 to 10.5. (2) Not applicable for products of intended color fading subjected to laundering (3) The list of banned aromatic amines released under recovery conditions are provided in Annex C in the technical code of GB 18401-2010 TÜV SÜD Product Services Slide 25 30 April 2013 GB Testing Cross Reference TÜV SÜD Product Services Slide 26 30 April 2013 TÜV SÜD Product Services Slide 27 1 GB - Review 2 GB - What Next 3 GB - What We’ve Learned 4 Summary GB 28480-2012 An Introduction to the Provision for Limited Baneful Elements of Adornments, Implemented as of May 1, 2013. What is GB 28480-2012? • GB 28480-2012: Adornment – Provision for Limit of Baneful Elements. – Baneful means “ Exceedingly Harmful“ – Baneful - Joint term of chemical elements causing damage to human health or jeopardizing the environment during the process of use, mainly referring to nickel, arsenic, cadmium, chromium, lead, mercury, antimony, barium and selenium. • This is the 2nd mandatory GB standard for jewelry • GB 11887-2008 is the existing standard (precious metals). (2012 version coming soon!) • GB 28480-2012 will need further explanation once implemented. • GB 28480-2012 will be the inspection basis for CIQ when they perform port inspection for fashion jewelry and for AIC/QTS when they perform domestic market quality supervision for adornments. TÜV SÜD Product Services Slide 29 What is Adornment? • Generic term of jewelry and ornaments. – Jewelry- Articles for personal adornment. – Ornaments - Articles for adornment of indoor environment. • Gems are exempted from this standard – Joint name of natural jewelry and jade (including natural jewelry, natural jade and natural organic gemstone) and artificial gemstone (including synthetic stone, manufactured stone, splice stone and reconstructed stone). • For Nickel release - Prolonged Contact with skin includes items such as: – necklace, bangle, bracelet, anklet and finger ring; – watch cover, watch chain and watch buckle; – press button, agraffe (fastener), rivet, zipper and metal tag (if not pegged on clothing). TÜV SÜD Product Services Slide 30 Comperison between GB 11887-2008 & GB 28480-2012 General Part Standard Code GB 11887-2008 GB 28480-2012 Standard Name Jewelry--Fineness of precious metal alloys and designation Adornment--Provision for limit of baneful elements Issued Date 2008-12-31 Issued Date 2012-06-29 Implement Date: 2009-11-01 Implement Date: 2013-05-01 Issue & Implement Scope The standard is applicable to all Jewelry which manufacture and sale in China The standard is applicable to all kind of adornment (gems excluded) Purity Required Not Required Label Label of jewelry need to include mark & labelling Children's Jewelry need indicated(Below 14 years old) TÜV SÜD Product Services Slide 31 Comperison between GB 11887-2008 & GB 28480-2012 Technical / Testing Requirements – Toxic Element Standard Code GB 11887-2008 GB 28480-2012 Standard Name Jewelry--Fineness of precious metal alloys and Adornment--Provision for limit of baneful elements designation Toxic Element Limit Test Method Total Lead (Pb) <1‰ GB/T 21198.6 Total Mercury (Hg) <1‰ Total Cadmium (Cd) Limit Test Method ≤1000mg/kg GB/T 28020,GB/T 28021 ≤300mg/kg GB/T 28020,GB/T 28021 GB/T 21198.6 ≤1000mg/kg GB/T 28020,GB/T 28021 <1‰ GB/T 21198.6 ≤100mg/kg GB/T 28020,GB/T 28021 Total Cr(VI) <1‰ SN/T 2004.3-2005 5.3/4/5 ≤1000mg/kg GB/T 28019 Total Arsenic (As) <1‰ GB/T 21198.6 ≤1000mg/kg GB/T 28020,GB/T 28021 Soluble Antimony (Sb) ≤60mg/kg GB/T 28021 Children's Jewelry Soluble Arsenic (As) ≤25mg/kg GB/T 28021 Children's Jewelry Soluble Barium (Ba) ≤1000mg/kg GB/T 28021 Children's Jewelry ≤75mg/kg GB/T 28021 Children's Jewelry ≤60mg/kg GB/T 28021 Children's Jewelry Soluble Lead (Pb) ≤90mg/kg GB/T 28021 Children's Jewelry Soluble Mercury (Hg) ≤60mg/kg GB/T 28021 Children's Jewelry Soluble Selenium (Se) ≤500mg/kg GB/T 28021 Children's Jewelry Soluble Cadmium (Cd) Soluble Chromium (Cr) TÜV SÜD Product Services No requirement Slide 32 Remarks Children's Jewelry Comperison between GB 11887-2008 & GB 28480-2012 Technical / Testing Requirements – Nickel Release Standard Code GB 11887-2008 Standard Name Jewelry--Fineness of precious metal alloys and Adornment--Provision for limit of baneful elements designation Nickel Release Limit Test Method Limit Test Method Pierced skin <0.2μg/(cm2·week) GB/T 19719 <0.2μg/(cm2·week) GB/T 19719, GB/T 28485 Direct contact with skin <0.5μg/(cm2·week) GB/T 19719 <0.5μg/(cm2·week) GB/T 19719, GB/T 28485 Direct contact with skin product with plating <0.5μg/(cm2·week) GB/T 19719 <0.5μg/(cm2·week) GB/T 19719, GB/T 28485 Plating part TÜV SÜD Product Services GB 28480-2012 Slide 33 Remarks FAQ about GB 28480-2012 • Q1: Costume jewelry is on the mandatory inspection list requested by CIQ from 2011, will they use GB 28480-2012 as the safety requirement from the effective date? • HS Code Commodity Description 71171100 Cuff-links and studs of base metal, whether or not plated with precious metal 71171900 Imitation Jewelry, of base metal, whether or not plated with precious metal 71179000 Imitation Jewelry, not of base metal TÜV SÜD : It depends on the action taken by different port CIQ. Currently CIQ used GB 11887-2008 as the requirement for the imported costume jewelries and with the formal release of GB 28480-2012 from May, CIQ may take both of these two standards as the quality requirements. TÜV SÜD Product Services Slide 34 FAQ about GB 28480-2012 • Q2: Any further explanation of Adornment / Jewelry / Ornament? • TÜV SÜD : Currently no comment from official channel. But the author of GB 28480-2012 said that since this standard is somehow a prospectively GB standard, the main purpose is to protect the people and the environment form some baneful elements by direct contact, so most of the Adornment / Jewelry / Ornament which is normally defined as direct skin contact are with the loop, such as glasses, sunglass, watch belt, ring, earring, necklace, bracelet, anklet, rivet buttons, rivet, metal label and so on. TÜV SÜD Product Services Slide 35 TÜV SÜD Product Services Slide 36 1 GB - Review 2 GB - What Next 3 GB – What We’ve Learned 4 Summary China- Domestic Testing Overview China has a national testing scheme that we have dubbed as “GB” testing. There are some “parallels “between China testing and the US testing There are just as many differences, that make it difficult for us to correlate back to US testing requirements You need to appreciate these differences to sell effectively in China TÜV SÜD Product Services Slide 37 30 April 2013 China- Domestic Testing Overview - Similarities Similarities China has a national testing system – think CPSIA China has regional/provincial differences in the application of the regulations. Think Ca. Prop 65 Like in the US, there oversight agencies, like FTC, CPB, CPSC China retailers can, and do, require testing that is not mandated by the Chinese government. TÜV SÜD Product Services Slide 38 30 April 2013 China- Domestic Testing Overview - Differences Differences China regulates much more than the USA China has both mandated and recommended testing protocols by specific product categories that move past safety and include chemical and physical testing. China has a robust enforcement policy and also has a network of government labs that conduct testing. Most of the tests in China are based on ISO or European standards. US testing is based on AATCC or ASTM standards. TÜV SÜD Product Services Slide 39 30 April 2013 TÜV SÜD Product Services Slide 40 1 GB - Review 2 GB – What Next 3 GB – What We’ve Learned 4 Summary 30 April 2013 Summary Make sure you have an appreciation of the Chinese testing standards and how the apply to your products. Understand the potential pitfalls of importing into China. Select partners with • Knowledge of local market – by region • Relationship with Chinese government testing facilities • Ability to partner with you to understand your current and future retail strategy in China • Technical Capability (testing, labeling and consulting) • Ability to provide training, education and industry updates TÜV SÜD Product Services Slide 41 30 April 2013 Thank you! Ben DeVito 978-427-0901 bdevito@tuvam.com www.tuv-sud.com/consumerproducts Time for Q & A TÜV SÜD Product Services Slide 42 30 April 2013 Thank you for attending! You will receive a re-cap email from AAFA including a link to today’s presentation by the end of the week. We look forward to your participation at future AAFA events. Special thanks to TÜV SÜD for sponsoring today’s webinar!