FEATURE SUPPLY CHAIN SOLUTIONS
DEALING WITH COUNTERFEIT GOODS IN THE SUPPLY CHAIN
win a big order and this leads to an adaption of the final product and its components, and a degradation in the quality of the final product compared to the original sample. Ideally, testing should be done before
the product is shipped to provide the evidence that it complies with all functional and regulatory requirements, and the buyer should insist that this be a condition of sale. Factory inspections can also be carried out to check the authenticity of manufacturing facility, as sometimes the quality of products in mass-production are not of the same standard as those submitted for testing and certification.
by Clare Gittens, business line manager CPS at TÜV SÜD C
ompanies that buy directly from manufacturers outside the EU need to
be aware that this changes their responsibilities as they cut out the traditional supply chain. By law, whoever is placing a final product for sale anywhere in the EU is responsible for its compliance. Companies buying directly from outside
the EU must therefore take steps to ensure compliance, rather than rely on their supply chain to take on the burden of proof. With the laws of demand and supply fuelling the dramatic rise in counterfeit products, this complicates the situation further. Products that fall under a CE marking
directive cannot be imported into the EU unless they show the mark, which is simply a manufacturer’s self-declaration that the product complies with the relevant European legislation. Less scrupulous manufacturers may not bother to test products and simply affix the CE marking and sign the declaration of conformity. Due to language issues, other manufacturers who mean well are misunderstanding the requirements of a complex set of directives – giving a CE marking to products that should fail tests. This is particularly becoming an issue
for UK and European manufacturers which design and develop products in their own country, but outsource the manufacture outside the EU. While they may have checked the quality of their immediate supplier’s operations, must
18 NOVEMBER 2018 | FACTORY EQUIPMENT
also go further and check that the various component manufacturers further down the supply chain are as rigorous in their quality control.
GATHER EVIDENCE Not only can products be counterfeit, their testing and compliance documentation can be too. It is therefore essential that importers gather evidence to ensure that their supply chain complies, and then validate that the evidence is correct. This means ensuring that reports and certificates have been issued by recognised testing laboratories, that they match the product; are properly dated and signed, are relevant to the current requirements and do not use out of date standards. A signed declaration of a product’s
conformity against the requirements of all applicable EU Directives, which is mandatory when CE marking a product for the European market, can also be faked. Any declaration of conformity needs to be backed up by a technical file, which is the evidence that a product has been tested correctly, demonstrates compliance, and justifies the CE marking on a product. Another issue in the supply chain is
that very often the final products supplied are not the same as those ordered. For example, a product exhibited at a trade show may subsequently require a reduction in production costs to
Below: Clare Gittens, business line manager - consumer product service at TÜV SÜD Product Service
VALIDATION One important tip is to save valuable time by selecting products which have already been tested and certified, asking for pre-production samples and compliance documentation for evaluation. Such products may carry a price premium, but they will help to protect brand reputation and save costs further down the line when validating the evidence becomes more burdensome. It is also important to ensure that any
factory you deal with outside the EU has a Quality Management System in place and is regularly audited by an independent third-party. Also, consider pre-shipment and post-shipment inspections, taking random samples from boxes to ensure that the goods meet expectations before taking delivery of them. Before the products are sold in the EU,
send samples for a ‘spot-check’ so that they, and their test and certification evidence, can be verified as being compliant. Ensuring the correct testing and inspections are completed at an early stage minimises the risk of customers complaining about a product and enforcement authorities insisting on it being withdrawn from the market. An integrity failure within the supply
chain can have major implications, and tackling may at first appear a complex task. However, investing in the validation of products will reassure importers, distributors and retailers that their supply chain complies with applicable legislation and that customer are protected.
TÜV SÜD
www.tuv-sud.co.uk T: +44 (0)1489 558 100
/ FACTORYEQUIPMENT
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