Know Your EN71 from Your Reach

Promotional items imported into the UK do not (as at the time of publication of this article) require any specific documentation to meet government or customs requirements. However, there are a number of certifications which some companies insist on in order that they gain an assurance of the quality of products, the chemical content and the ethical standards of the manufacturer. Gaining accreditations is generally not difficult but it can be time consuming and having products tested by independent laboratories usually costs £500-£750 or so, depending on the tests.

So here is quick guide to the tests and certification in order to help you through the world of promotional gifts and importing.

1. EN71

This is a legal requirement for any product which is to be sold as a toy inside the EU (and likely to be retained by the UK after Brexit). Whilst most argue that a promotional product is not a toy but a promotional giveaway, anything that might be used by children will often come with this certification.

Full details can be found at : https://www.gov.uk/guidance/toy-manufacturers-and-their-responsibilities

In summary, the regulations cover general physical health and safety – sharp edges and choking issues etc. and also the packaging including suffocation risk from plastic bags (EN71 Part1). The flammability of the products (EN71 Part 2). And the most commonly requested tests for chemical content for toxic items such as the phthalate used in PVC, cadmium and other heavy metals used in printing or decoration (EN71 Part 3).

To comply each product should be tested – cost around £500 – for an independent lab to test such as AI, Intertek, BSI or similar.

There is a similar set of rules for the USA the CPSIA – (Consumer Product Safety Improvement Act). Whilst not applicable to Europe Pavilion have been asked about this when dealing with US companies based in Europe since they like to keep their compliance standards common.

2.REACH 

REACH is a set of regulations governing the import of chemicals and cover anyone importing more than a tonne per annum of chemicals. Full details of the Registration, Evaluation, Authorisation & restriction of Chemicals can be found at: hse.gov.uk/reach

So why would the promotional goods industry, be interested in the importation of bulk chemicals? The main reason is that the regulations provide a list of Restricted Items and in particular 49 chemicals known as SVHCs or Substances of Very High Concern. By testing for these and testing the inks used for branding for these substances companies can be assured of the safety and environmental impact of any item. Like EN71, certification is gained by testing having an independent lab run the appropriate tests

We have worked with companies that insist on EN71 and REACH – however since the chemicals tested for in EN71 are covered by REACH we fail to understand why.

3. SA 8000; SMETA (Sedex); and amfori BSCI

3 completely separate audits and standards but looking at the same thing – the ethical standards of the manufacturer. All these audits and certificates cover the issues of child labour, working conditions, anti-slave labour etc. The multitude of standards arises because these were standards written and controlled by various trade bodies across the globe. It is possible for manufacturers to hold multiple certification to the different standards but in Pavilion’s opinion this serves little purpose.

Unlike the EN71 and REACH this is not a certificate for the product but rather an audit and certificate of the factory and sub-contractors. The cost varies depending on the company and is usually around £800 for a couple of days of an auditor’s time – varying from country to country.

Details of the individual standards can be found at

 SA 8000  - www.sa-intl.org/sa8000

SMETA - https://www.sedexglobal.com/products-services/smeta-audit/

Amfori BSCI www.amfori.org/content/amfori-bsci