GB Testing esting in China China – New Requirements, 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
[email protected] April 30, 2013
GB Testing in China – New Requirements, Time to Get Ready Presented by Ben DeVito 978-427-0901
[email protected] April 30, 2013
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Our heritage: 146 years of business success 1866
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1910
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1926 1958
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1990s
Conglomeration of TÜVs from the southern part of Germany to form TÜV SÜD and the expansion of business operations into Asia 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
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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").
Organizational Chart of State Council of P.R.C The State Council of the People's Republic of China Departments (total of 28)
l i c n u o C e t a t S e h t f o e c i f f O l a r e n e G
s r i a f f A n g i e r o F f o y r t s i n i M
……
e c r e m m o C f o y r t s i n i M
Admin. Offices
Direct Institutes (total of 18)
s m o t s u C f o n o i t a r t s i n i m d A l a r e n e G
, e e n c n i r i o t e s i n m v a r r m e a o p u C u Q & S & y t y i r l n t o i s a t u u c d Q e n f p I f o s n I o n o n i o t i t a r t a r i s t s i n i n m i m d d A A l a e r t e a n t S e G
……
SAIC
AQSIQ
Direct Units (total of 14)
(total of 4) n o i t a r t s i n i m d A g u r D & d o o F e t a t S
s e c i f f O s r i a f f A o c r a M & g n o K g n o H
……
e c i f f O s r i a f f A n a w i a T
y c n e g A s w e N a u h n i X
……
s e c n e i c S f o y m e d a c A e s e n i h C e h T
Direct Bureaus
(total of 11) s l l a C & s r e t t e L f o s u a e r u B e t a t S
……
n i a r G f o n o i t a r t s i n i m d A e t a t S
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) • •
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
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 •
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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
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
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.
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
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
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
Essentials for Department Stores – 3C Certification Criteria of Test Reports •
Department stores require you to present test reports which satisfy the following conditions: a. 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 b. Product quality conforms to: Safety code: GB 18401-2010 Label requirement: GB 5296.4-1998 2012 version will implemented on May 1, 2014) Quality requirement: Product standards •
•
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
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 General Safety Requirement Product Grade
GB/T 8878-2009
Fiber component and Content:
GB 18401-2010 A or B
Care Instruction:
Certification Fiber component and Content
Acceptable (not required for v. 2012) QC-001 XX% XX%
GB/T 8685-2008
Country of origin
XXX
FZ/T 01053-2007
Manufacturer’s name
XXX
Care Instruction
Manufacturer’s address XXX Tel.
XX-XXXXXX
Fax
XX-XXXXXX
GB/T 1335.1~1335.3 GB/T 6411
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
Product Standards (in addition to GB18401 test requirements) GB/T 8878-2009 Cotton Knitted Underwear
Test Item Formaldehyde Content pH Value Presence of Odour Banned Azo Dyestuff
Test Method GB/T 2912.1 GB/T 7573 GB 18401 6.7 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 Ball Burst Strength
GB/T 8629 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
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
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
GB 18401-2010: Technical Requirements The General Safety and Technical Specifications of Textile Products are shown below: 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
−
−
Formaldehyde content (mg/kg) pH value (1)
colorfastness (2)
Product for Babies 0 to 36 months
Product with Direct Contact to Skin
Test Item
Unpleasant odor
None
Dyestuff that produce banned aromatic amines (3)
Prohibited ( <20mg/kg)
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
GB Testing Cross Reference
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.
What is Adornment? •
Generic term of jewelry and ornaments. – –
•
Gems are exempted from this standard –
•
Jewelry- Articles for personal adornment. Ornaments - Articles for adornment of indoor environment. 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).
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）
Comperison between GB 11887-2008 & GB 28480-2012 Technical / Testing Requirements – Toxic Element
Standard Code
GB 11887-2008
Standard Name
Jewelry--Fineness of precious metal alloys and Adornment--Provision for limit of baneful elements designation
Toxic Element
Limit
Test Method
Limit
Test Method
Remarks
Total Lead (Pb)
<1‰
GB/T 21198.6
≤1000mg/kg ≤300mg/kg
GB/T 28020,GB/T 28021 GB/T 28020,GB/T 28021
Children's Jewelry
Total Mercury (Hg)
<1‰
GB/T 21198.6
≤1000mg/kg
GB/T 28020,GB/T 28021
Total Cadmium (Cd)
<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)
GB 28480-2012
No requirement
Comperison between GB 11887-2008 & GB 28480-2012 Technical / Testing Requirements – Nickel Release
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
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
Remarks
FAQ about GB 28480-2012
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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.
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.
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”
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
testing.
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.
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.
1
GB - Review
2
GB – What Next
3
GB – What We’ve Learned
4
Summary
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 • • •
• •
Thank you! Ben DeVito 978-427-0901
[email protected]
www.tuv-sud.com/consumerproducts
Time for Q & A
