Global Product Problem Observations from EU RAPEX System-Taiwan v.s. China status

The Rapid Alert System for non-food consumer products (RAPEX), implemented in Europe in 2004, not only ensures that European consumer products are safe but also serves as an information-exchange platform that EU member state market-surveillance authorities and the European Commission can use to quickly share and report hazardous products. Since RAPEX was activated in 2004, thousands of products have been blacklisted every year. Makers of notified products are required, through EU market surveillance, to take different levels of preventive or corrective measures, and in serious cases a product recall will be requested.

Certain groups, especially babies and young children, generally require the most protection, so toys and children's clothing frequently appear on EU RAPEX lists. Other product categories such as electrical appliances, motor vehicles, and cosmetics see more frequent notifications as well. In 2011, for example, the product category with the highest number of RAPEX notifications was clothing textiles and fashion items, with 423 cases (27%), followed by toys with 324 cases (21%), motor vehicles with 171 cases (11%), electrical appliances & equipment with 153 cases (10%), and cosmetics with 104 cases (7%). These product categories alone accounted for 76% of all notifications in 2011, so extra care should be taken by vendors looking to export to Europe.

The 2011 RAPEX annual report also showed that 54% (839 cases) of all notified products in 2011 came from China (including Hong Kong), while second place went to products with unclear place-of-origin labeling, with 128 cases (8%). The huge gap between first and second place highlighted China's status as the factory of the world, as well as the high penetration rate of Chinese products in the European market. Notified products manufactured in Taiwan totaled 21 cases, or 1.3%.

Trend data from 2010 through to October, 2012 show that the number of notified products from China has been decreasing. Notified products from Taiwan have remained on average at around 20 cases a year, a relatively low number overall.

Textiles have been the leading RAPEX notification category for many years. According to TÜV Rheinland Taiwan's Softlines department manager, Carl Chang, textile notifications have remained high because textiles are a necessity and are used in large quantity, which makes it a large category in absolute terms. Other problems include the large number of supply sources and tracing difficulty. People now expect

higher levels of clothing quality as well as glossiness and anti-bacterial, anti-odor, and water-repellent properties. As a result, more additives must be used during the production process, increasing the risk of exposure to hazardous substances.

As for toys, the second-largest notification category, regulations were not updated for two decades, so the market often paid little attention to potential chemical hazards. More attention was paid to unsafe designs that cause injury to young children. Since toy regulations have been extensively revamped in the past few years, Carl Chang predicts that toy notifications will peak in the next 2~3 years. Technological innovations can be a double-edged sword, improving quality of life but also increasing the risk of chemical hazards. Manufacturers should therefore take more care.

As for why product notifications for China are decreasing at a rapid rate, RAPEX member states have been more proactive in introducing risk-assessment principles, stepping up enforcement efforts on product safety, and strengthening cooperation with customs authorities. At the same time, the EU has continued to cooperate with product-safety organizations in China to strengthen controls at the source, and the effort appears to be making a difference.

General Product Safety Directive 2001/95/EC requires each EU member to conduct market surveillance. National authorities are required to inspect samples at points of sale or during the customs-clearance process. The goal of market surveillance is to ensure that products on the market are safe, and is one of the main tools of product-safety policy. The authorities can use market-surveillance results to oblige manufacturers to improve or recall products deemed to be dangerous. Sales bans can also be executed if necessary. Market surveillance not only upgrades product quality and safety for consumers, but also helps suppliers monitor product hazards and brand management.

Independent certification bodies such as TÜV Rheinland can be considered another type of market-protection mechanism. They not only help suppliers reduce safety concerns for unregulated products, but also avoid trade barriers that arise as a result of excessive regulation.

E-commerce today means goods can now flow freely between nations. In many cases, the origin of products purchased through online shopping are unknown. For the international market, there is an OECD product-recall platform (http://globalrecalls.oecd.org), where government authorities list compulsory or voluntary product recalls. Apart from helping consumers check their products for safety concerns, enterprises can also use the platform to follow up on global-market concerns about potential hazards as early as possible.

With 140 years of experience in testing and certification, TÜV Rheinland Group has set up product-safety testing laboratories in 500 locations around the globe. We understand the product safety and quality issues that suppliers are concerned about, and are driven to promote safe living.