Upon discussing around with clients when developping their new products, it seems there are many things people ignore about product certification and lab testing in China. I have decided to write this blog post for people who still have lack of a clear understanding of some points related to product testing and certification and who are currently buying in China or manufacturing products in Asia.
I hope you will find this article informative and that it will help you better manage your product certification in China and lab testing in Asia.
Understanding the product certification process and the documentation
Most of time if you ask a manufacturer if they have a certification for a product, if they have it they may show you a certificate. Yet, I consider having the certificate of a product is not enough and here is why:
The certification process is usually made in two phases: first the testing phase, second the certification phase.
Testing phase
Most of the time the lab, after asking you to provide them with a certain number of sample will start testing the product based on a standard framework which is most of time recognized by a certain market. For example, for electronic products, the most well known standards are: CE (including EMC, and LVD if electrical) for European which sometimes an extension per country (NF for product including electrical power supply for France, GS for similar products for Germany), FCC for USA market with some additional UL or ETL if some electrical elements are considered etc… All of those norms have standards which via their documentation indicate a series of requirements which the product should reach. To make sure those products reach those requirements some testing is performed on the product.
Testing can be very diversified depending on the standard and on the product. For example, for some UL certification for electrical appliance products, a test of flammability might be made to make sure the product can resist to fire ignition, another test for drop fall might be made to verify strenght of the enclosure, another test for cord pull and strength test might be made to make sure the user will not get electric shock easily if the cord get broken etc…
Potentially, all those tests have the capability to destroy the product during the test (if you take the example of flammability test you may understand why). So, for the next test needed in the standard, a totally new sample of your product being totally new might be needed. For example you would not perform a drop test on a product which has been already used for flammability testing because then the product structure has been altered by flame, so the sample tested would not be the same as the original product, so the drop test result would be biased. So, now you probably understand why when you need to perform a product testing based on a certain standard, the lab will ask you to provide N samples. Sometimes N can be a small number, and sometimes it can be a high number.
For the story, I remember one of our US customers who wanted to pass UL certification on an appliance product which they had started to develop by themselves. They had selected electrical parts by themselves without caring too much about the certification step, so actually many of those parts were not pre-certified for UL. The lab was requesting almost 15 samples of the product to perform the whole batch of test. As the product was still in product development process and tooling was not opened yet, we only could supply prototypes for pre-testing and pre-certification. Prototypes costed almost 500 USD each, and the UL certification pricing was above 10,000 USD. Total of the operation was above to 17,500 USD. Those costs could have been reduced drastically if the customer could have selected parts properly during product development process.
Coming back to the test phase, typically a long series of different test are performed and results of those tests are recorded in a documentation. This can be very helpful sometimes to debug a design issue. Normally during the testing phase, the lab will document every test they do on the product. Most serious labs will even take pictures of the product being tested and will include those pictures inside a document called “Test Report” or “Testing Report”. This test report is a kind of log, history and result of the test being done and their related status.
Phase 2: Certification issuance
Once testing has been done, and if the tests done have been passed against the standard, then the product can be certified. If the product is certified then the lab will issue a Certificate. Normally, on this certificate is indicated a reference which relates to the Test Report (usually a serial number or case number). It means that each certificate for each product has a Test Report which allows for checking which test has been done and on which product.
Now, here is the point: sometimes when a client asks a manufacturer if they have a certification for product A, the manufacturer may give only the certificate to its client or prospect without giving the associated Test Report. Now, what I have seen in the past is some manufacturers not having certification for product A, but having certification for another product B having a very similar name or reference number or sometime even similar appearance. They would give to their prospect only the certificate of this product B pretending it is the certificate for product A.
An easy way to check if the certificate is proper for your product is simply to ask the manufacturer to also provide the Test Report, to scroll down into the document and check the pictures that are included: Is the product in the image the same as your product ? If yes, everything is fine, but if not then there is a very high chance that your product certification would not be accepted by customs officers.
So, one tips to avoid unnecessary problem is to always verify the Test Report and not only to rely on a certificate.
Lab qualification
The qualification of “being a lab” is actually very wide.
They are some labs which are accredited and some labs which are not. Tomorrow, I can open myself a testing house in my office and say it is a lab, yet I could not certify a product without being accredited to deliver the certification. So, in short, it would mean that almost anybody could open a lab and start doing testing. This is true, but customs and regulation do not recognize all labs the same way.
Indeed, to avoid getting some product from being certified by labs which do not have proper qualification and who do not have proper testing procedure, an organization named ILAC is regulating the lab testing industry. It regulates the lab industry via some locally based representative organization. In China it is called CNAS (previously called CNAL and CNAB which finally merged).
In short, it means this organization gives accreditation for certification process to some labs and not to others, this being based on several criteria. For example, to be CNAS certified, a lab will have to demonstrate certain capabilities to properly manage with calibration of their testing gauge and apparatus to make sure that their measurement is accurate all the time when they perform testing. If they fail to do so, it would mean they would potentially issue some certification which are unreliable since measurement done during testing phase would be wrongly made.
There is a long process of accreditation which usually goes through a series of pre-certification. Notably, for lab testing, a lab should be certified against ISO 9001 first, then ISO 17025, then being accredited by the local representative body of ILAC in the country of the lab.
They are plenty of labs in China pretending to be certifying labs, but who actually have no accreditation to deliver certification. So, if you choose a lab, you better make sure the lab is ISO 17025 and ILAC certified via ILAC member in the country you are considering (here is the list of the ILAC representation per country), otherwise your certification may be worthless on the eyes of customs authorities in your country and you would have paid for a certification which you can not use and which is not recognized at all.
Verifying if a certificate is genuine
Sometimes some manufacturers give some certificate and test report and you can doubt whether this certificate and test report is genuine or not. With Photoshop, it is quite easy to modify a certificate and a test report by simply generating some JPEG file, modifying it and regenerating a PDF.
If your product has been certified by a top 5 lab, then you may have a chance to browse their lab testing report database directly online. In this case, you usually input the report reference number and the online system will give you access to the document. You can then check if the information you get is same as the information which is recorded on the document held by the lab.
Some labs are sub-contracting to other labs
A current practice I have seen in the industry is some labs to sub-contract some tests to other labs. For example, you apply for UL to a tier 2 or 3 Chinese lab which has a low price. They tell you they can do it, but actually they don’t have the equipment to do it (and don’t have the accreditation to do it). In this case, they may sub-contract those tests and certifications to another lab who is certified to perform this test, after what the tier 2 Chinese lab will emit a test report or/and certificate with his own name using the previous test report. Is it legal? Yes it is, as long as the report they give to you mentions the reference of the official certificate and test report and as long as you have capability to get access to the official test report.
Sometimes even some lab will take your product testing and certification request and will sub-contract the testing and certification to several different laboratories. After that, they issue a consolidated final test report and certificate to you. Why do they sub-contract to different labs? Well because lab A might be cheap for test X but expensive for test Z, while lab B might be expensive for test X and cheap for test Z.
Is it interesting to use a lab that sub-contracts? I would say yes and no. Yes may be for pricing concern and if you are not too curious, but if you want to master your product testing and certification you better use a single lab and be directly connected to them because it would simplify the communication process and would provide easier feedback.
You can ask a lab to remit a certificate with your own name
Knowing that some certifications are expensive, if you source a supplier or manufacturer who already certify the product you would like to import, you may want to use the certification already done by this manufacturer to import this product safely. Yet, in some certain situations you don’t necessarily want to get the name of this supplier on the certificate. This is particularly the case if you are acting as opaque middlemen buying and reselling the goods to another client who is not suppose to know who is the manufacturer.
In this case, you may ask to the lab who has issued the certification through your manufacturer to change the name on the report so that you can hide the name of your manufacturer. Most of time, labs will ask for fees to perform this process.
You can use a testing certificate to trace back the source of a supplier through a trading company
Related to the previous remark, sometimes you can reverse the process to find the manufacturer of your own supplier. I have done so in the past: I was sourcing a product which it seems only some trading companies were offering. I had very high difficulties to identify the source of the manufacturer who was producing the product I wanted. On one of the website of the trading company, the testing certificate of the product was publicly disclosed. I checked the certificate and it indicated the name of the original manufacturer. Bingo!
You can get the bill of material of your product through testing certificate
Sometimes, depending on the kind of testing and certification standard requirement for your product, some reliable labs will establish and indicate the bill of material of the product. For some certification, this bill of material is requested by the lab to the manufacturer and is then integrated to the test report. It can be very useful if you want to reverse engineer a product or if you want to identify a component during a defective product root cause analysis.
You can use a lab testing certificate to cover yourself against consumer safety issue
A lab testing report and certification for your product can help you to “cover” partly your company against lawsuit, or at least attenuate a judgement decision.
In most of western countries, the importer is responsible for any damage caused to consumer. In short, even your Chinese manufacturer doesn’t manufacture your product properly, if your product is defective and endanger consumers due to safety issue, this the importer who is legally responsible, not the manufacturer. Why? Well it is very simple to understand: imagine yourself being a judge in a jurisdiction having its own law. In case even you would judge guilty a company being located in a jurisdiction where you have no power, how can you enforce the law in the other jurisdiction to enforce the court decision in this other jurisdiction? Well, simply, you can not (particularly China doesn’t recognize other jurisdiction judgement). So, since the law has to go to someone they can “seize” to get compensation, they will go to the organizations on their own ground: the importer.
So typically the importer would be the one liable for consumer safety issue. Now, in order to make a judgement, the law would look at the case the following way: “Did this importer do everything possible to avoid this situation or did it take it lightly?”. If you have tested and made certified your product via an accredited lab being recognized in your own market, then in theory you have already done almost everything possible you could to avoid this consumer safety issue. A consumer safety issue still might happen (if for example your manufacturer swaps material and you don’t control the supply chain enough tightly) but then the responsibility is not fully on yourself: by having tested and certified your product, you have transferred a substantial part of the consumer safety responsibility to a third party which is the testing lab. In case a court comes to you, you can demonstrate you have been doing the maximum you could do.
I also heard that some product safety or liability insurance will not cover your company if your product harm consumer while still not having your product being certified.
I hope this article helped you to understand a bit better what you can get from lab testing and product certification. Is there anything important you think is interesting to mention which I missed?
Feel free to comment below and give your opinion.
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