Global supply chain includes many stakeholders, and it is an ecosystem to be precise.  Compliance and testing come first before any mass production plan can be executed. General Supply has dedicated partners throughout Asia for compliance and testing task. We work with independent testing partners to ensure compliance with CPSIA, Prop 65 and other required safety requirements. General Supply coordinates testing protocols in the whole process. The protocols include the regulatory requirements for main product categories.

The standards we routinely conduct testing for include: UL, CSA, CA Prop 65, 16 CFR 1303 lead in surface coatings, FDA, EPA Certifications, BPA screening, Toxics in Packaging materials, CPSIA lead in surface coatings and substrates, CPSIA phthalates, CPSIA physical / mechanical tests 16 CFR 1500-1501, flammability of solids and apparel, ASTM F963-11 for toys. In addition to protocols, we have a SOP (standard operation procedure) in place with lab partners to outline the scope of our testing relationship.

General Supply deploys Manager of Product Safety & Compliance and a China QC/QA team on site in our Nanking branch office who are responsible for tailoring protocol to specific products and delivering protocol standards to our manufacturers. Our Director of Product Safety and Compliance is home based in USA. The tasks include lab selection, protocol development with the 3rd party labs,  time negotiations and report review.

Picking the ISO certified or quality-focused manufacturers is equally important. General Supply trains our partners on site to make sure the fully understand the project requirement. Our core vendor factories receive a handbook outlining the expectations for working with General Supply, which among other factors, outlines our safety and compliance standards, testing requirements, quality expectations, social compliance guidelines and best business practices.

Each of our projects is tested according to the audience communicated to us by our clients. For example, an adult product abides by different regulations than a child product. We are also able to test for voluntary performance standards if the client desires standards beyond mandatory requirements. If you would like to discuss the applicable standards for your order, please contact your General Supply Import Executive.

CPSIA:

The Consumer Product Safety Improvement Act of 2008 (CPSIA) was passed by U.S. Congress and signed into law by President Bush on Aug. 14, 2008. CPSIA is designed to allow The U.S. Consumer Products Safety Commission (CPSC) to better regulate the safety of children’s products imported for sale in the U.S. CPSIA standards apply to a young audience of 12 years and under. Each child’s product is reviewed, protocol established and tested by one of our independent testing lab partners to ensure the appropriate CPSIA standards are met.

CA Prop 65:

California law that became effective in 1986. It restricts or prohibits items containing carcinogenic and reproductive harmful chemicals from entering the State of California. General Supply carefully monitors CA Prop 65 settlements to keep apprised of new developments. In addition, our independent testing lab partners distribute periodic newsletters for updates to CA Prop 65 and related topics. We offer testing and compliance protocols for CA Prop 65 upon request.

Social Compliance Audits:

We are partnered with a 3rd party independent audit firm that is capable of performing social compliance audits as required. A thorough audit assesses the following areas: child labor, forced labor, health/safety, freedom of association, discrimination, disciplinary procedures, conditions of the dormitory/canteen, hiring contracts in place, working hours, attendance records, wages, over time compensation, and social insurance system.

C-TPAT:

The Customs-Trade Partnership Against Terrorism is a voluntary supply-chain security program led by U.S. Customs and Border Protection focused on improving the security of private companies’ supply chains with respect to terrorism.

General Supply is committed to be C-TPAT certified. This is a transportation security certification. Companies and their suppliers go through different tiers of certification to ensure goods shipping into the US border are weapons, harmful substances, or potentially hazardous materials free. General Supply only works with C-TPAT certified freight forwarders.

FDA Testing:

The United States Food and Drug Administration is a Federal agency of the Department of Health and Human Services. Generally FDA Testing applies to drink ware and food serving containers. General Supply implemented the required FDA testing for these products and monitors continual compliance. All drink ware and utensils  like food containers, mugs, bottles, cups, plates, and food related products. The specific tests are based on the material or plastic resin code. In addition, General Supply complies with regulations for BPA as outlined below.

Bisphenol A (BPA):

Bisphenol A is an organic synthetic compound with the chemical formula (CH₃)₂C(C₆H₄OH)₂ belonging to the group of diphenylmethane derivatives and bisphenols, with two hydroxyphenyl groups. It is a colorless solid that is soluble in organic solvents, but poorly soluble in water. It is a chemical most often used in plastics. We make every effort to source BPA free drink ware and tableware. If clients notify their distribution points to General Supply, we are more than happy test accordingly for these States.

Lead:

Lead is a pollutant regulated by many laws administered by EPA, including the Toxic Substances Control Act (TSCA), Residential Lead-Based Paint Hazard Reduction Act of 1992 (Title X), Clean Air Act (CAA), Clean Water Act (CWA), Safe Drinking Water Act (SDWA), Resource Conservation and Recovery Act (RCRA), and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) among others.

Regulations

Lead is a hazardous substance that is most commonly found in surface coatings and substrate materials. In the past it was used as a drying agent ingredient in many products and is a very common cause for product recalls. The regulation regarding lead is CFR 1303. The maximum permissible lead amount in most products is 90 PPM (parts per million). Lead testing is accomplished through lab testing by scraping off surface coatings (every color) from products. This includes logos applied with ink, tags with ink, and even clear lacquer coatings. General Supply tests every project for lead to ensure compliance with 16 CFR1303.

In addition to federal lead limits, General Supply is also cognizant of the Texas Childhood Lead Poisoning Prevention Program (TXCLPPP). Please let us know if your product is intended for use in other states.

Phthalates:

Phthalates are a group of chemicals used in hundreds of products, such as toys, vinyl flooring and wall covering, detergents, lubricating oils, food packaging, pharmaceuticals, blood bags and tubing, and personal care products, such as nail polish, hair sprays, aftershave lotions, soaps, shampoos, perfumes and other fragrance preparations.

How phthalates have been used in cosmetics

Historically, the primary phthalates used in cosmetic products have been dibutylphthalate (DBP), used as a plasticizer in products such as nail polishes (to reduce cracking by making them less brittle); dimethylphthalate (DMP), used in hair sprays (to help avoid stiffness by allowing them to form a flexible film on the hair); and diethylphthalate (DEP), used as a solvent and fixative in fragrances. According to FDA’s latest survey of cosmetics, conducted in 2010, however, DBP and DMP are now used rarely. DEP is the only phthalate still commonly used in cosmetics.

Currently it seem that there are no federal regulations for phthalates with respect to items for use by adults, however, they are banned in children’s toys/child care articles. The CPSIA has set a maximum limit of 0.10%. Phthalates are referenced in section 108 of the CPSIA. General Supply tests for the chemical in all children’s products and where relevant.