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Sourcing safe products
If you supply consumer products in Australia, you are legally responsible for product safety.
You are responsible for:
- products that are subject to a mandatory safety standard or ban
- products that don’t have mandatory safety requirements.
What to check when sourcing products
You should source products from manufacturers or suppliers who have a reputation for supplying products that are tested for compliance with any applicable mandatory standards.
When sourcing products, always check that:
- the factory is audited regularly to make sure that proper controls are in place
- raw materials have been tested
- assembly line processes are followed and quality checks are performed
- pre-shipment inspections are carried out with adequate supervision by qualified staff appointed by an independent inspector
- staff training is current and adequate.
Keep up to date about mandatory standards, bans, and recalls by subscribing to product safety emails.
Product safety testing
How testing can help your business
- Minimise the risk of injury and death to consumers
- Meet mandatory standards
- Avoid supplying banned products
- Have a good risk management strategy
- Reduce the chances of a costly recall process
- Reduce the chances of compensation claims against you for supplying defective goods
- Guide your approach to stock development and choices
- Increase customer satisfaction.
Reasons to test your products
When products are designed and developed for supply to consumers, it is generally not enough to have a pre-production sample of the products safety tested without further quality assurance.
If a mandatory standard applies to your products, you may be required to make sure that the products have been tested.
Testing may also establish whether a product falls within a ban and therefore cannot be sold in Australia.
As well as testing for safety, testing may be required to establish whether goods meet the guarantee of acceptable quality or to substantiate a range of other claims such as:
- environmental impacts, emissions or efficiency
- nature and extent of ingredients, components, additives or allergens
- country or place of origin of ingredients or components
- extent of genetic or other technological modification involved in production
- health benefits or impacts.
How to get products tested
To make sure your products comply with product safety laws, you can:
- commission reliable, independent and preferably accredited laboratories to test products and provide test reports
- conduct your own testing, using suitable in-house expertise and facilities
- commission a certification agency to assess products and provide written certification of compliance with safety standards. This allows you to use certification labelling on relevant products
- ask your suppliers for written evidence of safety compliance through third-party product certification or product testing, including copies of test reports, preferably from accredited test bodies or laboratories. You need to be satisfied that the testing meets your obligations.
Using an accredited test laboratory
When commissioning product testing, it may be preferable to use an accredited laboratory. Accredited laboratories are assessed regularly and vigorously by an independent agency.
It is not compulsory for test laboratories to be accredited.
If there is a court case, reports from these laboratories may have more credibility.
The National Association of Testing Authorities (NATA) and its international counterparts provide strict independent assessments of, and accreditation for, competence in testing against specific safety standards.
Checking laboratory accreditation
If a laboratory is accredited to test for one standard or part of a standard, it does not mean they are accredited to test for the whole standard or a different standard.
When checking a test laboratory’s accreditation, ask:
- what the accreditation covers
- what specific standards or parts of standards the laboratory is accredited to test for
- if the accreditation relates directly to the required testing
- for the accreditation reference number
- if the accreditation is current
- if the accreditation is limited and if so, how
- what other relevant details apply.
The National Association of Testing Authorities, Australia (NATA) has a list of NATA-accredited laboratories.
What and when to test
Safety means making sure that products:
- meet the requirements of mandatory standards
- are not covered by bans.
Some mandatory standards refer to sections of a, or to a whole, voluntary standard. These requirements must be met to comply with the mandatory standard.
A laboratory may need multiple samples of a product because:
- tests may damage or destroy a product
- tests may need new samples for each specification
- tests may need a combination of samples
- variations in a product line might require more samples.
Testing should happen at various stages of product development and distribution.
Some mandatory standards require testing before the product is supplied to a consumer.
Initial design testing
Test custom-made, exact models of new or modified products that are intended for the Australian marketplace.
Product sample testing
Test samples of products when they are made, to make sure they are safe.
Ongoing testing
For products that are made regularly you can use an acceptable quality limit (AQL) model.
The more complex the supply chain the more important the follow up processes. See the Australian Standard AS1100.1-2003: Sampling procedures for inspection by attributes—sampling schemes indexed by acceptance quality limit (AQL) for lot-by-lot inspection.
Each product is different and may need different tests and intervals.
Testing after changes to design, material or production
Major product safety legal cases have occurred because manufacturers failed to retest products after making a design, material or production change.
Understanding the test report
When you get a test report back, make sure you read it thoroughly.
If the report relates to a mandatory standard you must check that all requirements of the mandatory standard were tested and passed.
Store report documents in a safe place. Documents should include proof that the laboratory has current and correct experience, expertise and accreditation.
Valid reports
Reports must be accurate and valid. Check that they cover the correct stock and that the tests apply to the relevant Australian mandatory standard.
Conflicting reports
Sometimes there can be conflicting test results, for example if product specifications change or a laboratory is not qualified.
If this happens, discuss it with the laboratory and NATA.
You should not supply any product to the Australian market unless fully confident that test results show compliance with the relevant mandatory standards.
False reports
Sometimes false reports are made by test laboratories.
You should check:
- the report is complete with all its parts
- batch code numbers and delivery dates match what you requested
- the testing regime matches the specifications in the standard and was done with the correct methods
- formatting and spelling
- that the conclusions are reasonable and consistent with test results
- for any other signs of concern.
You should also ask the laboratory to email the reports to you at the same time as they are sent to any other party and to add security features on any documents.
If you are suspicious, ask the laboratory to verify the report’s authenticity. Check its accreditation with the accreditation body.
Product pre-shipment inspections
Make sure the consumer products you purchase for supply are safe and of good quality.
- Ask for a pre-shipment inspection at the factory before the products are shipped.
- Choose a pre-shipment inspection service provider that is reliable.
- Check that your pre-shipment inspector is trained to carry out tests and measurements for your product.
- Confirm with the service provider that their inspections follow established international standards.
- Make sure you understand the information in the inspection report and clarify anything that seems unclear.
- Consider developing a customised inspection protocol that covers points of quality concern.
- Confirm that any problems raised during the inspection are fixed before shipment.
See also
Understand product safety rules
Developing a compliance program
Testing to product standards: Principles for test organisations
Australasian Compliance Institute (ACI)
Joint Accreditation Scheme of Australia and New Zealand (JAS-ANZ)
Australian state and territory agencies:
- Australian Capital Territory - Fair trading and consumer rights
- New South Wales - Fair Trading
- Northern Territory - Consumer Affairs
- Queensland - Office of Fair Trading
- South Australia - Consumer and Business Services
- Tasmania - Consumer, Building and Occupational Services
- Victoria - Consumer Affairs
- Western Australia - Consumer protection.