Export to China? Regulatory compliance always comes first!
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Do you export or intend to export your products to China? It is seen to all that great numbers of businesses are exporting their products to China as they see the growing purchasing capability and huge market potential in recent years.

However, China strengthens its quality surveillance on its market in pursuit of quality and safe products. Random inspections are common to ensure China regulatory compliance. The inspections usually take place at entry banks, circulation fields and manufacturing companies when competent authorities take potential hazards into consideration.

There are 1.1432 million of imported consumer products recalled by Entry & Exit Quarantine Inspection Authorities at all levels for defects covering electrical and electronic equipment, apparel, toys (and child conveyances), disposable sanitary products, food contact materials, fashion items and other consumer products in 2016. Apple, Toshiba, Sony, Fujitsu and other world-famous brands are on the recall list originating from the United States, Italy, Japan, South Korea, Malaysia, Germany and Sweden.

Meanwhile, Chinese General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) launched special quality inspection campaign on toys, disposable diapers, garments and kitchen ware imported from cross-border e-commerce. To our shock, 40.9% of 1,013 lots of products proved to be non-compliant.

Case Analysis on Imported Products Non-Compliance

[KEYWORD] Toys

Details: Rolling horses imported from Germany bears no instructions and warning information. The migration of chromium (Cr) is 378mg/kg as high as 5 times of the limit set forth in relevant Chinese standard.

Measures adopted: Re-dispatch

[KEYWORD] Garments

Details: On the March 15, China Central Channel validated notifications on garments including ALLO& LUGH (children’s wear from South Korea), OKADI (children’s wear from France), JACADI, GUESS, Marks and Spencer, A&F, H&M, ESPRIT and PUMA.

Measures adopted: Destruction, re-dispatch

[KEYWORD] Fashion jewllery

Details: The fashion jewellery falls far behind of relevant standard requirements as they contain dangerous levels of lead and nickel. Alarmingly, in the worst case that the lead present in a design of necklace even exceeds 699 times as high as the limits set forth in relevant standards. To be more specifically, the product virtually consists of 70% lead.

Meanwhile some bracelets released nickel at a level of 7 times as high as the limits set forth in relevant standards. Due to its carcinogenic properties, nickel can infiltrate into human skin through pores and sebiferous gland leading to allergy and inflammation.

Measures adopted: Destruction

[KEYWORD] Disposable sanitary products

Details: Excessive levels of total bacteria colonies were detected in disposable diapers from South Korea and tissue from Italy. Such products make consumers exposed to great hygiene hazards.

Measures adopted: Destruction

[KEYWORD] Children’s straw cups

Details: Pigeon children’s straw cups (from Japan) were found non-compliant with relevant Chinese standard as regards safety and hygiene.

Measures adopted: Destruction, re-dispatch

Of course, the above cases just account for a very small part of trade alerts in China. More stringent regulation is also in place for consumer products such as food contact materials (FCMs), children’s products, electrical and electronic equipment, rubber and plastic articles.

2016 Regulatory Updates in China

The new China regulatory framework of FCMs gradually takes shape along with the publication of new standards. The newly released standards as regards FCMs can be divided into 3 categories, namely, general standards, product standards and testing standards. Notably, these product standards (excluding GB 4806.2 for rubber nipples) under the new China FCMs regulatory framework become effective on 19 Apr. 2017. The compliance of food contact materials (FCMs) will undoubtedly be the highlight of this year.

The development of China RoHS is still a rising concern for electrical and electronic operators. China RoHS 2.0 has come into operation since 1 July 2016. Pursuant to the Administrative Measures, all products listed under Compliance Management Catalogue shall fulfill marking requirements and be regulated under the Assessment System for Restriction of the Use of Hazardous Substances in Electrical and Electronic Products. But the catalogue is still unclear at the moment.

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