China GB Regulations From The UK Perspective
For a long time now, the UK’s textile, clothing and footwear industries have been trying to take advantage of China’s burgeoning retail market. This has meant understanding and complying with the country’s import rules, a task which at first seemed insurmountable is a vital first step for brands and retailers. For example, China’s publication of mandatory performance standards, known as “GB standards”, and a second level of “Product Standards” really had the industry in Britain in a whirl.
In the UK, legislation in these industries focuses mainly on restricted substance compliance. In China, the requirements go further and also cover physical and safety testing. For some years this has been seen as a real barrier to exporting products to China. It meant that in order to comply with the requirements of the destination market, the UK industry would need to carry out significantly more testing and get to grips with a new set of labelling and consumer safety rules before it could take advantage of this new and growing market.
In particular, it was recognised that many products would need to be designed or redesigned specifically to meet the requirements of Chinese standards. Even products with deemed high performance in the UK might fail the requirements on any number of ‘technicalities’, and therefore be subject to recall, or even be prevented from import into China.
In addition to conformance to the relevant component (e.g. leather) or product (e.g. garment, footwear) specifications, the complexity of the different authorities in China has led to confusion from a UK perspective and appears to have put many off wanting to try and gain a retail foothold in China. With different organisations within China being responsible at different stages of the supply chain, production, import and export and market circulation/retail, ensuring that the right testing is done by the right testing body and that the correct documentation was available at the right time for these different bodies has proved complex. Examples of relevant authorities include the Administration of Industry and Commerce (AIC), Administration of Quality Supervision, Inspection and Quarantine (AQSIQ), China Consumer Association (CCA), Entry-Exit Inspection and Quarantine Bureau (CIQ) and on a more local level Quality and Technical Supervision (QTS). Having no directly comparable system in the UK resulted in an understanding gap in certain UK supply chains.
SGS’s global team recognised this complexity, and working with our dedicated experts in China set in motion an organised and focused approach to solving these problems. As a result, SGS experts sit on the committees that are involved in drafting GB regulations. This means we are able to keep our global network, including the UK, well informed and devise strategies for each market to tackle the challenges of dealing with China GB regulations.
UK Supply Chain Event
In the UK, SGS organised a full day session which was offered to garment and footwear supply chains as a means to further understand the general requirements for compliance to Chinese standards. The differences between the relevant Chinese authorities along with information on specific garment, footwear component and finished product requirements were explained. Case studies were used to demonstrate important aspects.
Take footwear as an example, whilst there is no single GB standard that covers the physical performance requirements for all children’s footwear, there are individual GB standards relating to individual children’s footwear styles, such as GB 25036-2010 – Children’s canvas rubber footwear. It was further explained that there is also a general safety elements GB specification which relates to all children’s footwear, Safety technical specifications for children’s footwear (GB 30585-2014). One should also be aware that components such as shanks are also regulated. Failure to meet the GB standard Shanks for footwear (GB 28011-2011) was shown as one of the major causes of product rejection/recall for footwear in China. Examples of where shanks fail the GB requirements include ensuring that they are correctly marked (with a ‘1’ for men’s footwear and a ‘2’ for women’s and children’s footwear), that they meet the minimum shank length requirements based on shoe size, heel height and consumer (men’s or women’s/children’s) and that they conform to the requirements for longitudinal stiffness, hardness and bending performance.
This example highlights how failure to design a product specifically to meet GB standards could lead to major issues in GB conformance.
Whilst a number of different textile and garment GB specifications were presented and discussed, delegates were particularly interested in the ‘odour’ conformance requirement within the GB standard National General Safety Technical Code for Textile Products (GB 18401-2010). Discussion on how a subjective assessment for odour could be made in to a standard followed. Much discussion also followed presentation of the GB standard Labelling Requirement Instructions for the use of Products of Consumer Interest – Part 4 Textile and Apparel (GB 5296.4 2012), in particular for sizing which covers both actual sizes and general body shape. Again, this has no directly comparable system in the UK and interest was shown for how this was specifically determined.
Significant debate followed a section on the causes of product recalls in China. Statistics show that in 2014 the national inspection and quarantine agencies (CIQ) collected 23,818 batches of samples during inspection of imported garments with a sampling rate of 33.8%. Of these, 1,785 batches (7.5%) of goods did not meet the requirements. Much of the discussion focused around whether pre-approval (prior to the whole shipment being shipped) was possible. The cost and inconvenience of product being quarantined and destroyed for non-compliance was something that UK exporters had already faced and were keen to avoid.
Similarly, for recall cases in terms of level and type of failure across garments and footwear, attendees at the UK event were concerned with the detail required to ensure smooth import into China. Data from 4,364 recall cases in 2014 shows that 1,400 (32%) were due to inaccurate fibre content figures on product labels. As an explanation for this, it was demonstrated that small differences in how fibre content is measured can lead to incorrect calculations and therefore false labelling. A further 1,117 cases (26% ) were due to general issues in product labelling, which covers a multitude of non-compliances against GB labelling specifications. These two causes alone account for 50% of total recalls in 2014.
SGS Enables UK Trade With China
Due to the complexity and associated risks, many UK retailers have decided not to tackle the challenges of exporting to China. However, a growing number have done so thanks to the efforts of the SGS team globally. We are successfully supporting the UK softlines supply chain in the knowledge that the expected performance levels have been met, that labelling is correct and that certification will meet mandatory requirements.
With the help of the Global SGS team, fears can be allayed and business can proceed with relative smoothness. The number of questions asked by retailers has reduced rapidly as their experience grows and the new processes now seem routine.
For those that need refresher courses, updates or are new to the business, SGS is running the training seminars again in 2016 and these will be advertised on our website.
For further information, please contact:
Global Technical Manager
(Leather and Footwear)
SGS United Kingdom Limited
t: +44 7841 566777
Consumer and Retail
SGS United Kingdom Limited
t: +44 (0)1379 668625