How To Approach Product Compliance in 2018
Losing sleep over tracking down Full Materials Disclosures (FMD’s), and collecting Bill of Materials (BOM’s) from your supply chain?
Without the assistance of a 24/7/365 supplier engagement team, and centralized product data management platform, collecting and analyzing hierarchical product compliance data is extremely challenging – let’s look at alternative paths to getting accurate product compliance data that minimize the FMD burden.
The first thing to look at are the types of documentation that will give you insight into your products. Product level documentation is the obvious, but company level documentation can give you insights into compliance as well.
Company Level Documentation
Certificate of Compliance – COC (Also referred to as Certificate of Conformity)
A COC is a commonly exchanged document that states the products issued to a customer by a supplier meets the required specifications in regards to a particular set of standards and/or regulations.
Manufacturers Contractual Agreement
A manufacturer’s agreement is a standardized agreement that outlines quality and logistics information in regards to the products the supplier provides the customer.
***Other common company level statement documentation include Declarations of Conformity, Declarations of Compliance, Contractual Agreements or Statements of Compliance – many contain the same information, but have different naming conventions.
Company level documentation outlines an “agreement” or “statement” by a supplier, that the products (one, or all) they supply are in accordance with the customer’s compliance requirements – requirements such as all products needing to be compliant with California Prop 65 can be laid out before you start your relationship.
Product Level Documentation
Laboratory Test Report (LTR)
LTRs are results from product testing for a specific purpose. The advantage of an LTR is the chemical composition outline.
Safety Data Sheet (SDS)
SDSs are documents that list information related to the specific details of the product. SDSs include the exact chemical composition and percentage of the ingredient in the product.
Product level documentation contains information about a specific product being supplied to the customer. The advantage of product level documentation is that your able to capture chemical concentration data points, unique to a product, that are critical to understanding and defending a product’s compliance status.
Now, the question becomes – how can you utilize both types of documentation to efficiently collect data and make a determination on a products regulatory status?
Multi-Stage Product Compliance
Multi-stage product compliance is an approach to product compliance that minimizes supplier fatigue and quickly get’s you results using a series of assessments. The assessments gather information at a company level, and then dive deeper into the product(s) affected be the regulation in question.
1. Determine what suppliers are “in-scope” of the regulation(s) in question – this can be accomplished on a company level.
If a supplier does not provide you with products that are regulated (outlined in a COC, for example) you may not need to collect complex product documentation that slows down your due diligence process.
2. Once you’ve done your initial due diligence and have your “in-scope” suppliers in a sandbox, you can then dive deeper. The deeper assessment then goes into the products material make up. As we outlined above, this type of information typically only appears in product level documentation.
Product Compliance Assessments
At Source, we’ve developed a multi-stage product compliance program that utilizes a similar process flow like the one outlined above. We created Product Compliance Assessments for companies quickly identify products with compliance implications for various regulations like California Prop 65, REACH and RoHS.
We’ve found that Product Compliance Assessments decrease supplier reporting fatigue, increase accurate data collection and get our clients real-time product compliance information as it’s uploaded from suppliers. Click here to learn more.