In this week’s product guide, we share our experience on making children’s and baby clothing in China. What may come as no surprise, especially to our regular readers, is the emphasis this guide places on product compliance with regulations, including those on substances, labeling requirements, and the physical properties of the product. In addition, we will also explain what you need to know about product testing and why, in this industry, importers should stay away from “mass-produced” products.
The challenges of importing children’s and baby clothing
Children’s products, including clothing, are strictly regulated in all major markets, including the European Union and the United States. Penalties for non-compliance are severe, ranging from $5,000 to $100,000 per violation in the United States. Penalties in Europe, for example in the UK, are slightly lower, but can lead to arrest for up to 6 months and a fine of €5,000 for each violation. All this, of course, is in addition to the obvious fact that all non-compliant clothing for children and babies is subject to immediate seizure.
Who is responsible for ensuring compliance with regulations when importing children’s and baby clothing?
The importer is responsible for this, without exception. This responsibility cannot be transferred to a foreign manufacturer. Ensuring compliance with regulations is therefore the main challenge when importing children’s and baby clothing, especially when the goods come from China.
Firstly, most Chinese suppliers in this sector are unable to comply with regulations. As I will explain later in this article, the directives in this area apply to various elements, including substances, physical properties and labelling.
In order to comply with these regulations, a manufacturer must comply with the following:
• Must already have experience in the production of articles according to ISO (European Union) and ASTM (United States)
standards• Has subcontractors, as far as fabrics and components are concerned, able to control the use of certain substances (e.g., lead and phthalates)
Many, if not most, of China’s manufacturers are not predominantly geared towards Western markets. That being the case, they have no concrete incentive to ensure compliance with the regulations and directives in force in these foreign markets. This is also why finding, for example, the right supplier that complies with these directives is a real challenge.
Many suppliers on the market are not real manufacturers, while wholesalers are. Small businesses are likely to favor these merchants, as they tend to offer slightly lower Minimum Order Quantity requirements than manufacturers. However, the products marketed are generally mass-produced for the Chinese domestic market and are not produced in accordance with European and US regulations.
For this reason, importers of children’s and baby clothing have only one alternative: to order only from manufacturers who can demonstrate extensive prior compliance with current regulations. This concerns the requirement of the Minimum Order Quantity often between 500 and 1,000 pieces. This is quite a lot of goods for a new venture, yet there is the possibility of reducing the Minimum Order Quantity.
Regulations relating to substances: heavy metals and chemicals
The EN 71 (European Union) directive, REACH (European Union), CPSIA (United States) and California Proposition 65 (United States) restrict the use of several substances, including lead, cadmium and formaldehyde (a chemical found in textiles). Many Chinese manufacturers struggle to comply with these regulations, as the content of chemicals is not directly under their control. Fabrics and other components, such as zippers and buttons, are purchased from subcontractors, so they are not produced “in-house”.
For a supplier to comply with the regulations, it must already have established business relationships with highly sought-after sub-suppliers of fabrics who can ensure this compliance. Yet, many of them are unable to do so.
You can never be sure that a batch is compliant until you have the test report in your hands that confirms it. On the contrary, it’s all about risk management. It is very likely that a supplier who can demonstrate broad compliance (e.g., has many recent test reports) can provide compliance compared to a supplier who cannot produce any test reports.
Physical Property and Flammability Regulations: Buttons, Seams and Zippers
In addition to restrictions on substances, physical properties are also regulated in the European Union and the United States. The CPSIA Directive, for example, is not a uniform piece of legislation that regulates all the components of an article. Instead, it refers to various industry standards developed by ASTM which, in turn, applies to specific products. In the European Union, importers are required to ensure compliance with ISO regulations. The following is a brief but incomplete overview of the main ASTM and ISO standards:
• ASTM F1816-97 (2009) Detailed description of the safety regulation of drawstring closure of children’s
coveralls• ASTM D6545-10 Detailed description of the regulation on flammability testing of children’s
pajama fabrics• General Product Safety Directive 2001/95/
• EN 14878:2007 Textiles – Combustion behaviour of children’s pyjamas and nightgowns – Detailed
description• EN 14682:2007 Safety in children’s clothing – Drawstrings and drawstrings in children’s clothing
Labelling requirements: washing labels, country of origin and fibre content
Each market has its own labelling requirements, some of which apply to all products, while others only cover textiles and, in particular, children’s clothing. Non-compliance with all applicable labelling requirements is reason enough for customs authorities to quarantine a consignment; Therefore, you better take it seriously. Depending on where you are, you need to consider the following:
• Country of origin
• Fibre
content• Warning
labels• Size of size
• Washing instructions
That said, ensuring compliance with labelling requirements is very simple, compared to the complexity and risks of substances, flammability and physical properties. However, never assume that the supplier is aware of how a product should be labeled in Italy. Instead, importers need to provide a “pre-packaged” design file (e.g., in EPS format), which includes the following:
• Text
• Graphics
• Colors
• Dimensions
Compliance testing is often mandatory
Unlike adult clothing, substance testing is often mandatory when importing children’s and infant clothing. Clearly, such tests are not free of charge and the importer, and not the manufacturer, is always expected to finance them.
Testing companies such as SGS and Asiainspection charge based on the number of changes made, not the number of items. An item made of the same fabric, but in two different colors, is considered as if it were two tests. As a result, the costs of testing substances are completely based on the number of different fabrics and colors. Assuming you buy a number of items all made from different fabrics and in various colors, the overall cost could be up to thousands of dollars per order!
For small and medium-sized enterprises, this is a big problem.
The only solution to all this, in addition to setting up a structure of your own where you can carry out the tests, is to reduce the number of materials and colors. In other words, use the same fabrics and colors for as many products as possible. In addition to reducing costs, this strategy has additional benefits, as discussed in this article.
Baby & Baby Clothing Manufacturer Checklist
Compliance with regulations is certainly the main qualification criterion by which to select a manufacturer of children’s and baby clothing. It’s pretty useless to consider prices, quality of materials, and quantity requirements before you’ve verified that a manufacturer belongs to this small group. It is for this reason that I have divided the qualification requirements into two groups:
1) Primary qualification requirements
- Is the supplier registered as a manufacturer of children’s and baby clothing? (As specified in your registered business)
- Main markets
- Can the supplier produce the test reports for the substances?
- Can the supplier produce ISO or ASTM test reports?
- Can the supplier make a label according to the buyer’s specifications?
2) Secondary qualification requirements
- Quality of materials and components
- Share capital
- Social compliance protocols and audit reports
- Quality Management Systems
- Buyer’s References
As I’ve said a hundred times, regulatory compliance is critical, but it doesn’t necessarily guarantee the “high quality” of a product.
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