eSignature Licitness for Property Inspection Report in European Union

How to eSign a document: e-signature licitness for Property Inspection Report in European Union

hi my name is Frederick in this video I will explain what CE Marking really is and how you as a importer exporter or manufacturer can well implement C compliance in real life so before we dig into this just want to mention the C e is specifically for the EU so so if you if you plan to sell in the United States or Australia well anywhere there's not the European Union and you don't really have to care about CE Marking so anyhow in this I will explain which products are covered by CE Marking list of CE Marking directives documentation requirements labeling requirements and also the lab testing requirements and an FAQ at the end so what is CE Marking well at its core it's a it's a conformity marking it's a compliance mark the c e mark itself printed on a product it's Cygnus compliance with all EU directives or C directives that apply to that specific product okay now the specific directives and in turn the specific technical safety standards differ depending on the product type because we see the CE mark on so many different products clearly you can't apply the same regulation or safety standard the technical standard - to sunglasses as you do to say electronics okay now which products have to carry the CE mark because the thing is if the product is not well listen a SE C directive it shouldn't carry the CE mark okay there's only specific categories of products it should be seeing marked and if they fall within these when I see mark and directives and they have to be seeing more so if binary it's it's it's 1 or 0 there's there's nothing in between it's never optional okay so electronics pretty much anything with a battery with you know an input voltage anything that's you know power by nicely after and they said after itself anything as electronic must carry to see more the same thing for toys I wear protective equipment that specifically gloves yeah sometimes will work where machinery which often also falls within the scope of electronics and medical devices okay so a few example of see directed I just wanna make a key I'm not covering every single category every single directive this is just to briefly explain what sees amount okay so as you see here we have a range of different directives that apply to different types of products so for electronics you have more than one we have a low voltage directive if that applies enough depends on an input voltage and a few other things RoHS specifically restricts heavy metals EMC as electromagnetic compatibility in electronics and radio equipment directive well anything Wi-Fi any device that's Wi-Fi enabled Bluetooth anything with well rating radio equipment okay so what's interesting is you can see that depending on the features okay depending on the components depending on a power source of an electronic widget different regulations apply okay but something is very common especially when it comes to electronics and machinery and so on is that you find that it's not just one directive that I apply it can be well for an electronic machine that's you know I don't know Wi-Fi enabled from not that rare these days you actually have to apply with this this this this is also the machinery directive okay alright toys as en 71 toy safety directive and then we have the PPE directive for protective equipment as I just mentioned so that's covered sunglasses another eye wear gloves etc work products so different directive applies a different product but they all carry the same CE mark which which is what makes is quite unique all right documentation requirement and this is really the meat of the Seymour procedure because it's not just about printing that CE Marking logo would be release if that was the case now the way it works is that you need to you need to create documentation the first thing you need is a do see a declaration of Conformity okay and you can google that I'm not going to go into detail about what a DLC is about but essentially it's a it's a self issued document where you state that you hereby declare while your company here by this s that your product SKU is confirmed conforming to well one or more of these directives here okay that's pretty much what it's about so you don't have to buy it's not licensed it's not an approval that you get from from a government office you just issue it okay and you show that to the customs authorities you show it to Amazon you show it to to any anyone in may may need it the retailer's to for example you need a user manual that's mandatory you need a technical file I'm gonna get into that in a bit and you need a test report okay I'm gonna cover that too in a bit so I'm going to jump to the technical file so the technical file is the documentation that basically proves that your product is compliant okay so and I will say that this is this is by far the most complex part of the C compliance process but what it often boils down to it really depends on the product okay but what I mean a bare minimum is to have proper design drawings a bill of materials as a component list a list of applied en standards and also EU directives because first you have the e directive the densest these are the Ian standards that the product may comply with okay but it should be clear which in standards you've actually implemented or at least very fine that your product is come you know conforming to so that's needed label photocopies packaging photocopies because labeling requirements as a CE mark itself should be present on on on the product and also the packaging and also use of manual photocopies and a risk assessment and risk assessment is what basically it's a list of things that can go wrong and what you're gonna do if if it comes to that okay so if you're selling power banks well what could go wrong well they can explode shorting cable can melt I mean it can happen despite your best efforts and in that case you should have it should be written down somewhere what's the next action that your company will take okay different different items may need to be added depending on a product okay but these are the very basics at least that's a technical thing okay labeling requirements and the funny thing is a lot of lot of especially small businesses they think that yeah it's really by printing this see mark and then it's done it's not really that simple because clearly a product will not magically become compliant just because you print print and logo right but anyhow the CE mark is similar to it has to be printed on the product also on the packaging and the manual okay for some directives also directive specific information especially when it comes to machinery a medical device and so on but also certain are the categories you have to print warning labels or information about the input voltage or something like that so yeah it really depends on the directive because you don't have an input voltage for sunglasses so clearly you can't have the same labeling requirements for every single product right okay lab testing now what's lab says well lab testing is it's the only way to verify that your product is compliant okay because there's a difference between a product that's made to comply with say the in 71 toy safety directive or low voltage directive okay I mean these things they I mean these directives and the Ian standards the technical standards that are associated with these directives they yeah they have a meaning I mean it's it's there's a difference between a compliant and non-compliant product so a test report essentially proves to yourself but also as I showed with the technical file to the authorities to customers to Amazon that your product is compliant okay so how do you get a lab test report well you have to you have to book lab testing that's the way it works if you're importing products you will find that you can't really get it from your supplier so instead you actually have to book a lab test from a compliance testing company like Intertek or BV or SES or something like that and if you're importing you have to pay for it if your manufacturer that want to sort exporting to the EU well yeah of course you have to pay for it the government the EU government will not cover that cost okay so see compliance process it really boils down to these four steps okay like broadly because in realities is a bit more to do but first you have to confirm which direct is applied to your product and in turn you also have to confirm which Ian's standards are associated with that specific directive okay they provide guidelines and you can apply to your product so if you're designing a product from scratch then you also have to implement these directives into the product design okay that could mean that you know if you're manufacturing or importing toys you need to consider for example physical properties of the product you have to look into regulated substances of the product and things like that but you truly have to understand what your so to speak directive means for your products okay you can't just say okay I'm I need to comply with the in 71 and that's it and the same thing applies if you say you're importing a private-label product you're trying to bring a product from outside the EU into the EU then you have to make an assessment is this product already like is it compliant do I need to adjust something okay because in step 2 you have to order product samples or make for example if you're a factory and have to book third party lab testing okay the thing is that it doesn't matter if if your if your product past the lab that's or not you still have to pay and you know this could be anything from five hundred to two thousand zuv dollars depending on the complexity of the product and a number of directives that apply to your product okay so you don't really want to gamble with that you need to there's no accidental compliance when it comes to these things okay a lot of products are being tested that don't pass these these lab tests okay so once that's done and created label files and use the manual and step four we created DLC and a technical file so the procedure is actually quite straightforward and it also leads to this question how did the authorities check if my product is compliant because if they didn't do anything nobody would bother and the truth is that it's not really black or white enforcement is well I would definitely say that authorities national authorities in the EU defin stepping up compliance enforcement but it still a lot of non compliance compliant products being sold into the EU especially cross-border e-commerce but nonetheless I should definitely mention this because I'm I've seen I've seen a lot of products being pulled from the market so what they primarily do is to look at a DLC and a test report okay so they they can contact you and this could be at the time that Goods enter the country well enter an EU country okay so they can even they can request the DLC enter support at this time but was far more common is that they they keep track of online stores and so on especially online stores these days and they can request a declaration perform it in a test report any time beat a month after you have imported a product into the EU or place it on market if your domestic manufacture or six months later maybe maybe a year okay so it's not just about passing you know a customs check and then you know coast is clear they can come back at any time okay so that's what they look at primarily it's actually quite rare that they go and look at the technical file okay because when the authorities touch that you know it becomes a public document and they understand the sensitivity of that okay but yeah the D you'll see in a test report is what they primarily look at okay the second thing they can they can actually verify your technical technical compliance by ordering products from your online store okay and they do it all the time like you know ghost purchases and they take that to their labs and they verify if your product is is compliant they do that both for the sake of you know research but also for you know protecting the public from non-compliant and thus unsafe products number three at the time of the goods arriving at any EU border and being imported into any member state some authorities actually work directly with the customs to pick products straight from the shipment send it to a lab and thus check your product before it even enters the market that's quite rare but it happens and something that's gonna be stepped up more and more in the future but I would say that in in nine out of ten cases that we get in our email inbox when someone is panicking and sending an email oh this would that happen I got severe compliance issues can you help it's it's about Amazon its it this is a major risk the thing is that Amazon is the kind of gatekeeper okay they are really strict on sellers being required to provide the declaration for formatting and test reports and some sometimes depending on the category they also request additional documentation okay and yeah as I said they're getting really strict so don't try to list anything on Amazon without the right compliance documentation they have compliance experts know exactly what to look for and they won't take your documents just at face value they will check that they will they will cross reference it too and make sure that your test report is authentic valid and valid right and another thing I want to mention is that the way that governments are actually stepping up compliance enforcement these days is that rather than stepping up themselves they're putting more responsibility but liability on well economic operators in the supply chain and Amazon is one their marketplace okay but not just that you also have freight forwarders they start to ask for compliance documentation even fulfillment centers here in Hong Kong so this is just getting started you know it's so much easier for the authorities to just you know put this into legislation and say hey you have to ask for the right documentation because then you have private enterprise I tend to be a bit more efficient and then you know government agencies so this is definitely not gonna be relaxed did this only one direction this will go okay FAQ so I'm also going to cover a few common questions that we get about sea compliance while I'm at it so I'm importing products from overseas am I responsible for ensuring sea compliance and yeah you are definitely the EU authorities in writing and also when you when you speak directly to them they offer refer to the manufacturer that's the part that is responsible now that's partly true if the manufacturer is based in the EU okay now if you're importing a product with your own brand then you are as an importer still legally considered as the manufacturer okay so you are always responsible when you import a product with your brand based on your design any modification now when it comes to buying a product from outside EU from with the manufacturer and okay so to speak then the what they say is that then it's obviously Savannah facture that is responsible now in reality in reality you still as an importer of a other brand product you still have to obtain the dlc the test report the technical file which while if we speak in importing from China that just doesn't exist okay at least not now in 2019 it's extremely rare okay it's it's almost unheard of unless we're talking really big brands like Huawei or so on but they they launch their own products they don't work with the they go straight to market themselves like they build their own distribution systems they don't work with importers but if you go to an average like medium-sized companies Shenzhen or else when in in the locals country in Asia you're not gonna find ready-made compliant documents so in reality you as an importer in a hundred percent of the cases or close to it have to ensure the compliance okay now even if they you know even if they are in theory responsible what happens is that if you import a product and something is wrong and Amazon cracks down or the authorities say okay you can't sell it well you still gonna still you they're gonna be left holding the bag the city you're gonna lose money okay so who crap is a lab testing cost well that's that's also you if you're manufacture obviously you have to cover it if you're an importer well you still have to cover it it can be anything from five hundred us for a product to several thousand tens of thousand dollars if it's something complex like you know medical devices laser devices or something like that okay all right can I use my supplies test report now say that you're an important okay and you find that they have a existing test report well let's say that it's in theory it can in some cases be done if it's valid for the right product if it's well preferably issued even though it's not actually required for products by a accredited reputable test testing comes like into techo SGS and if it's in the same name as I said this is so rare okay and it's not just that especially in electronics for example you have more than one directly applies so to find a supplier that has all the test reports sorted out is it's just extremely extremely rare for that specific product okay so in theory yeah but it's just it's just so rare one thing you should never do is to just go to the I asked hey do you have a test report get some PDF and just you know assume that oh well they said I have a test report I guess I guess I guess I got it covered because it's it's so many cases of importance that I guess you know it's it's like the X funds you want to believe right we won we don't want to make it more difficult than it has to be and then you know they we find this Alibaba supply they send a test report and we just want that to be the thing that we've been looking for but it's it's always more complicated than that okay how their great label files well you can use Photoshop Adobe Illustrator paint it doesn't matter as long as you provide in your specification a copy a photocopy of your well on the see mark because that has to look like the see mark you're not allowed to make any artistic adjustments suit anything like that and you have to specify the position the dimensions which will be printed and engraving and it should also be present in the manual and also on the on the packaging okay but it's up to you especially if you importing products and you have to create a label file to send that to your factory ok cops team working is complicated if you want assistance with implementing compliance for your product regardless of whether you're an importer exporter manufacturer go to compliance gate comm slash help and we will get back to you with a free quotation thank you watching this video