This is the second blog post in the beginners guide series on importing from China. In this post I will discuss an outline on what you have to pay attention to when importing household products from China that are not chemical, not electrical or have no food contact.
For other household product such as pans, plates, knives etc you can find a guide HERE. For other household products that are electrical, such as toasters, blenders, vacuum cleaner etc you can find a guide HERE. Before you get started with this blog post I highly recommend that you check out my general but extensive guide on compliance and certification when importing from China HERE.
Generally, importing household products from China don’t fall under very strict regulations as for example electronics. However there are still a few things you’ll have to consider. This guide covers some of the following products:
• Dust pan
• Cleaning cloths
We will be looking at mainly 2 regulations that you have to comply with, both for the US and Europe. In Europe we have the REACH and the GPSD (General Product Safety) Directive. A few other things have to be considered such as the Prdoduct Safety Law (ProdSG). In the US we have the CPSC (Consumer Products Safety Commission) and the CPSIA (Consumer Product Safety Improvement Act). You may also want to have a MSDS (Material Safety Data Sheet) for your product. So lets dive in:
Disclaimer: Some of the products may contain an affiliate link and we may make a commission if you click on it at no additional costs to you.
GENERAL UNITED STATES HOUSEHOLD PRODUCTS IMPORT REQUIREMENTS
- Third Party Test Certificates for children’s products: Children’s products are generally defined as a consumer product designed or intended primarily for children 12 years of age or
younger. Importers of such products will be required to have a product tested by a CPSC accredited independent or third-party test facility. Based on such testing, a certificate will be issued evidencing compliance.
- General Conformity Certificates for all other products: The general conformity certificate must certify, based on a test or a reasonable testing program, that a product complies with all
standards or regulations applicable to the product. The certificates must accompany the shipment of such products. The certificate is not required to be filed with the entry, but must be furnished upon request to the CPSC and CBP. CPSIA has identified new standards for certification of consumer products. These standards follow different requirements and timelines that should be considered in the certification (California Prop65):
• Lead Standards that began February 2009 including paint and other surface coatings
- Phthalates Standards that began February 2009. In general a statement by the manufacturer about the intended use of the product, including a label on the product, if such statement is reasonable.
Whether the product is represented in its packaging, display, promotion, or advertising as appropriate for use by children 12 years of age or younger.
Whether the product is commonly recognized by consumers as being intended for use by a child 12 years of age or younger.
The Age Determination Guidelines issued by the Commission staff in September 2002, and any successor to such guidelines.
CHEMICAL REQUIREMENTS UNITED STATES
DECLARATION OF CONFORMITY California Prop65
California Prop65 – Lead Declaration of Conformity California Prop65 – Phatalate Declaration of Conformity
Labeling – Meet General labeling requirements
LABELLING REQUIREMENTS UNITED STATES FOR HOUSEHOLD PRODUCTS
The following labelling requirements are necessary for the United States on your imported household product:
1. The name of the manufacturer.
2. The name of the country where the product was processed or manufactured (e.g.
Made in China). To be printed or applied
3. For own-brand products, add name and address of your company
4. Item number and item description in local language
5. Instruction manual in local language and in adequate translation
6. National trademark of organization if applicable (FDA)
7. UPC bar code or Third Party Seller Identification (e.g. Amazon’s FNSKU)
GENERAL EUROPEAN UNION HOUSEHOLD PRODUCTS IMPORT REQUIREMENTS
These requirements DO NOT cover cleaners like detergent, bleach etc. The products must meet statutory requirements such as generally accepted rules of technology: No visible defects in coating, coating must cover the edges. No sharp edges, no burrs.
Surface: No visible defects in coating, coating must cover the edges. No sharp edges, no burrs
Metal: Metal components and fittings must be durable corrosion-protected, or made form brass or stainless steel.
Wood: Moisture content in wood and wood based material: < 15%
Stableness: 10 degree tilt test pass
Hooks: Max. load shall be indicated on the packaging
CHEMICAL REQUIREMENTS EUROPEAN UNION FOR HOUSEHOLD PRODUCTS
SVHC according to REACH Recommended < 0.1%
PAH’s REQUIRED Declaration of Conformity
Product Safety Law (ProdSG) – Declaration of Conformity (EC-DOC)
Textile Labelling Act -TKG (if textile
included) – Declaration of Conformity (EC-DOC)
Prohibition of Chemicals Ordinance
(ChemVerbV) – Declaration of Conformity (EC-DOC)
LABELLING REQUIREMENTS EUROPEAN UNION
The following labelling requirements are necessary for the European Union on your imported product:
1. Brand / Name and address of the manufacturer or importer
2. For own-brand products, add name and address of your company
3. Item number and item description in local language
4. Indication of the kind of material (if applicable)
5. Instruction manual in local language and in adequate translation
6. National trademark of a packaging recovery organization (e.g. WEEE)
7. EAN and or Amazon’s FNSKU bar code
PRODUCT REQUIREMENT PROFILE / TECHNICAL FILE
Ideally you will have a Product Requirement Profile (PRP) or sometimes also referred to as technical file. What this file is is basically a document that includes all the necessary information that your supplier needs to comply with. Rather than sending a long email with regulations and compliance laws you could send this PRP as an overview to your supplier. I have prepared a fully comprehensive Profile Requirement Profile for all products (including household products) that I send to my suppliers. These are available for purchase from me here at the bottom of this page.
So now that you know what kinds of regulations you need to comply with you need to decide whether you go for full certification or self-declarations. You are probably asking what’s the difference?
A full certification is basically issued by a third-party testing laboratory such as INTERTEK, QIMA, TUV, SGS or others. It’s the best insurance for your product that you can get.
Obviously these cost money and in some cases thousands of $. The second option is to self-declare your product.
Meaning you issue the “certificate” yourself. I would only recommend doing that if you know what you are doing.
On top of that if you self-declare you blindly trust your supplier (if they do not have certificates in the first place). There are self-declaration templates for almost any regulation. E.g. for the CPSC or the REACH certificate you can self-declare with a pre-made template. I urge you to understand what you are importing and what the potential risks of your products are. For example a heater with 2000Watt has a much higher risk to import than a salad bowl. The heater can be tipped by a child and potentially burn down the house if there isn’t a safety switch (or tip over switch in this case). A salad bowl can’t really cause much damage. I think you get the picture.
Having a full certification on a product is the best and safest way to go. What does that actually mean? Lets look at an example: You want to import kids t-shirts. You’ll want to avoid issues with Amazon or local authorities (depending on which channel you sell). You’ll also want to avoid any product quality issues such as chemicals inside the fabric that would give a child a rash. So ideally you’ll want a supplier with a OEKOTEX or similar certification for your specific product. You may also want a Children’s Product Certificate (CPC) for the US or a REACH certificate for the EU which tests different kind of chemicals that are harmful to the human body.
If possible find a manufacturer who has a fully certified product. Those are likely suppliers who work with large western retailers. Having said that if say the material used for your t-shirt has not been tested with the particular color that you want but on other solos I’d be fine with it. If you want to make sure that you comply or satisfy authorities you may ask the supplier to issue a Letter of Guarantee that the entire product has been manufacturerd according to standard or regulation “X”. But satisfying authorities should not be your eventual goal. Your evenutal goal should be to import a safe and reliable product that lasts and delivers good reviews or sales.
A full certification is quite expensive and therfore not often found. Yet some markets like Germay demand full certification especially from retailers. If you are an online seller and your exposure to the authorities is minimal you could start by meeting only minimum requirements (CE, FCC for example).
In some cases it doesn’t make sense to fully certify a product because your quantities are low or the product is so cheap that the certification cost don’t justify certifying it. In that case you may ask the supplier to issue a self-declaration which is in some cases accepted by authorities. Please note that you can issue a self-declaration based on applicable laws but you need to make sure that your supplier fulfils these requirements.
Meaning if the supplier doesn’t have any certificates or testing done for the product you need, you need to make sure trough other ways that the product is safe to import. For example if the specific product I want hasn’t been tested or certified by the supplier BUT he may have a certificate or test report for a critical component used in your very product it would partly satisfy me. On top of that I would also feel much safer if the supplier has history importing to 1st world countries (e.g. Germany, UK, US etc.). But if my supplier has no certificate, test report and only experience selling to countries like Ethiopia, Thailand or Colombia for example I wouldn’t go ahead. Why? Because these countries (no offense) have very low quality requirements. I think you get the point.
You would at least need to be compliant with basic requirements like raw material being certified or tested and according to regulations. However most countries in Europe only allow CE, REACH or RohS self-declarations for several items, mainly low voltage or battery powered products. Check with your supplier what he can offer you.
I can’t stress enough how important inspections are. Irrelevant of your product category, you will want your goods to be inspected to avoid a high rate of returns, defects or not compliant manufactured products. Pre-Shipment inspections can save you a lot of troubles and are well worth the investment. The inspectors will not only test the product but they will also make sure that all is compliant with laws and regulations.
PRODUCT LIABILITY INSURANCE
I also recommend once you import electronics in larger quantities that you contact your local insurance company and have a product liability insurance on your products. This is to protect yourself from any unforeseeable issues. I recommend that you check out a local provider in your country. Even you may have manufactured a product to the best of your knowledge something can go wrong or someone mishandled the product but you may not proof it. More on product liability insurance HERE.
So what kind of certifications do you actually need for sure? Thats difficult to say as it depends on the product and ideally you will want the supplier to provide you all of the above. But realistically that never happens. In most cases suppliers do not even have a CPSC or a REACH certification which is actually easily obtainable. If you are starting out I can only recommend to have a supplier who has the minimum requirements.
REACH for example is also easily obtainable these days and if a supplier doesn’t even have a self-declaration or certification for incoming raw materials look elsewhere. Unfortunately each product has different regulations however above general guidelines give you an idea what to look for. Again, the best thing would be to prepare a technical file (or product requirement profile – PRP) that you can send your supplier. It’s also essential that you learn about regulations and compliance in general. I’ve created an online education course for this very reason where you can learn everything about regulations as well as certifications for your specific product (inducing household products) here: