Lifecycle of Imported etail Products
•Importing Products
forImporting
Retail Products for Retail
Presented by Mark Penton
Senior Consultant, TÜV Product Service
TÜV Product Service Ltd ©
Who Am I?
Name
Mark Penton
Title:
Senior Consultant
Employer:
TÜV Product Service Ltd
Experience:
20 Years experience in product testing and approvals
History:
Worked for Electrolux, TÜV Product Service,
Underwriters Laboratories (UL)
Telephone:
01489 558214
E-mail:
mpenton@tuvps.co.uk
TÜV Product Service Ltd ©
Product Lifecycle
Contents
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Overview of imported retail product lifecycle
Brief overview of CE marking
Issues faced with imported products
Combating these issues
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Compliance testing of products
Factory and shipping inspections
Retailer product checks
Complaints and returns
Minimising your risks
• What can happen if you don’t protect yourself
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PRODUCT
LIFECYCLE
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Product Lifecycle
Lifecycle Overview
Country of Origin
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Sales Territory
CE MARKING
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CE Marking
•
What is CE Marking?
1.
Designed to enable free trade and movement of goods
around Europe.
2.
Places responsibility with the manufacturer
or importer of goods. (The organisation which actually
places the goods for sale in the EU).
3.
Relates to EU directives designed to ensure
quality on the market place (Eg: LVD, EMC, Toy).
4.
It is “self certification”, i.e. there is no mandatory 3rd
Party involvement.
5.
It is NOT evidence of compliance in itself.
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CE Marking
•
What is Due Diligence?
1.
Knowing what is required.
2.
Demonstrating compliance with relevant directives.
3.
Being properly prepared for if things go wrong.
 Ready to defend yourself in court.
 Being able to produce a technical file.
 Being confident in your safety case.
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CE Marking and the European Market Place
•
What is a Declaration of
Conformity?
1.
A formal statement that the product complies with:
Relevant Directives

Applicable Standards
2.
Signed by responsible person.
3.
It is not evidence of compliance in itself.
4.
Minimum legal requirement.
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ISSUES FACED WITH
IMPORTED PRODUCTS
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Testing of Products
• Have products been properly tested at source?
– Are relevant reports and certificates available?
– Do they match the product?
– Are they still valid?
– Are they to latest versions of the standard?
– Less than 2 years old?
– Are they ‘tested’ or ‘certified’?
– Are all relevant testing requirements met?
(All applicable directives covered)
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Quality of Products
Typical Quality issues experienced
– Products supplied not the same as ordered.
– Product not of the same build standard as the samples
submitted for testing.
– Products are cost reduced for production.
– Mass production not made in the same factory.
– Products do not function properly or are unreliable.
– Instruction manuals are poor.
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Own Branding
Do you really want to apply your brand onto
imported products?
• Are reports & certificates valid for your products?
– Not if the make and model number on the products is
different
– Co – licence certificates may be needed
– Have you changed the product specification
• Brand association
– If consumer is not happy they will associate that with
brand
– Do you want to have your name on poor quality goods
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The Result
• High product complaints and returns
• Products unsafe / dangerous
• Product recall or withdrawal from the market
• Consumer dissatisfaction
• Loss of brand integrity
LOSS OF REVENUE
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COMBATING
THESE ISSUES
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Product Lifecycle
Compliance Testing
Importer arranges
relevant testing and
certification to be
carried out.
Vendor has already
tested and certified
the product
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Buyer requests
relevant testing and
certification to be
carried out as a
contract condition.
Retailer arranges
relevant testing and
certification to be
carried out.
Product Lifecycle
Compliance Testing
Consideration relating to product testing
• Has all relevant testing been conducted to meet CE marking requirements?
(eg: Safety, EMC, Toy, Telecom, Environmental, Pressure)
• Ensure that product buyers are aware of testing requirements for the
products they are selecting.
• It is best to select products that have already had suitable testing and
certification. (eg: products with a GS mark or third party certification mark)
• Have you ensured that you have met the requirements of the General
Product Safety Directive (GPSD)
• Declarations of Conformity are not evidence of testing or compliance.
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Product Lifecycle
Factory and Shipping
Inspections
Factory Inspection:-
Pre-Shipment
• Certification
• Quality Management
System
• Ethical Auditing
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Post Shipment
Product Lifecycle
Factory and Shipping Inspections
Typical Objectives of Factory Inspections
• Ensuring the ongoing compliance of certified products. Inspections are
conducted on a regular basis by the certification body (eg: TÜV Product
Service, SEMKO, VDE).
• Checking the Quality Management System implemented (eg: ISO 9000).
• Ethical auditing to review working conditions and treatment of employees
(eg: minimum age of employees, treatment of staff, living conditions and
facilities provided).
• Checking of retailer specific supplier requirements.
• Ensuring products meet the expected quality and safety standards.
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Product Lifecycle
Typical Objectives of Pre/Post Shipping Inspections (PSI)
• Inspection of the goods, to appraise whether or not what you actually
receive matches your purchase order and your contractual requirements.
• Assessment of overall build quality.
• Checks to ensure that mandatory requirements are satisfied, e.g. CE
marking.
• PSI scope covers build quality, packing, marking and labelling, audit against
customer purchase order / requirements.
• supervision of loading / unloading.
“Essentially PSI protects you as the importer and ensures that what you
actually receive is what you were expecting.”
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Product Lifecycle
Retailer Product Checks
Pre-production samples
released for inspection
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Samples sent for
independent inspection to
verify product quality and
approvals
Product Lifecycle
Retailer Product Checks
Typical Objectives of Retail Product Checks
• Review of product by independent expert
• Check that testing reports & certificates are to the correct and current
version of the standards
• Check the competence of the testing laboratory / organisation
• Checking of user guide for language and suitability
• Check overall build and product quality
• Check product for essential markings and warnings
• Check for correct mains plug, cord and fuse
• Conduct basic functionality checks
• Check packaging of product
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Product Lifecycle
Complaints and Returns
• Customer unhappy
with product quality
• Product defective
• Product Unsafe
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Product Lifecycle
Complaints and Returns
• Complaints from customers and enforcement authorities can be highly
damaging to your business and could well result in costly legal action.
• Seek independent investigation of complaints on your behalf to find if the
complaint is unsubstantiated or legitimate.
• Ensuring that the correct testing and inspection are implemented at an early
stage minimises the risk.
• Managing your product integrity protects your brand name.
• OEM branding is an increasing market and carries higher risks as price is
often the overriding factor in initial product selection. High returns or
product recalls can ruin brand name and reduce or destroy profitability.
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Product Lifecycle
Minimising Your Risks
Select products which
have already been tested
and certified.
Pre and/or post shipment
to ensure the goods
shipped are acceptable.
Seek independent
investigation and
advise in the event of
returns or complaints
Request pre-production
samples and compliance
documentation for
evaluation.
Ensure that the factory
has QMS and is regularly
Audited.
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Samples sent for
independent retail check
Product Lifecycle
What Can Happen if you
Don’t Protect Yourself?
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Product Lifecycle
Defective products can catch fire in the consumers home!
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Product Lifecycle
Poor quality products that
break whilst in use and
injure the consumer
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Product Lifecycle
Toaster
Danger
1. Insufficient insulation.
2. Excessive case
temperature >100 C.
3. Inadequate Earthing
Measures
Remove from market
Prohibition of sale
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Product Lifecycle
Toy Pistol
Danger
Swallow able arrows
Lethal accident of a Swedish
boy
Measures
Recall
Prohibition of sale
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Product Lifecycle
Laserpointer
Danger
Laser power is 4 mW,
1 mW is allowed
Burn hazard of eyes
Measures
Recall
Prohibition of sale
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Product Lifecycle
Cord Extension Set
Danger
• Incorrect outlet socket
dimensions
• Excessive temperature >150 C
under full load
• Insufficient insulation distances
• Insufficiently rated mains cord
Measures
Stop of sale
Recall
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Product Lifecycle
Hot-water bottle
for Children
Danger
Bottle lid too small
Choking hazard to children
Measures
Destruction
Prohibition of sale
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Product Lifecycle
Teddy Bear
Danger
Detachable eyes
Suffocation
Measure
Recall
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Product Lifecycle
Expanding Spider
Danger
Suffocation
Measure
Prohibition of sale
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Product Lifecycle
Pizza Oven
Danger
Missing label
Missing CE marking
Fire hazard
Power hazard
Measure
Stop of sale
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Product Lifecycle
Trampoline
Danger
Collapsing of frame
Injury to user
Measure
Stop of sale
Product recall
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Product Lifecycle
Steam Cleaner
Danger
Escaping Steam
Scalding of user
Measure
Stop of sale
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Product Lifecycle
Summary
•
•
•
•
Overview of imported retail product lifecycle
Brief Overview of CE Marking
Issues faced with imported products
Combating these issues
–
–
–
–
–
Compliance testing of products
Factory and shipping inspections
Retailer product checks
Complaints and returns
Minimising your risks
• What can happen if you don’t protect yourself
TÜV Product Service Ltd ©
Product Lifecycle
Mark Penton
Senior Consultant, TÜV Product Service
Tel: +44(0) 1489 558214
mpenton@tuvps.co.uk
www.tuvps.co.uk
TÜV Product Service Ltd ©