eSignature Licitness for Employee Compliance Survey in European Union

How to eSign a document: eSignature licitness for Employee Compliance Survey in European Union

okay so in this one we cover fcm or um full contact materials in the eu which can apply to basically any material that's in in contact with food or beverage could be you know one of these stainless steel water bottles that everyone is carrying around these days um kitchen accessories lunch boxes food packaging wine glasses yeah i think you get to point so the framework regulation it basically applies to all sorts of fcm or food contact materials okay this could be stainless steel plastics coatings ceramics and and not to forget something that's becoming increasingly common which is also composites that's made up on made of two or more materials what it does is that it sets restrictions it limits certain substances sets maximum levels or limits okay it could be lead or cadmium or or or bisphenol a to give an idea but also migration levels because the way that fcm is different compared to say other consumer products okay now for other consumer products we have something called reach in the eu it also sets limits but the difference if you compare a lunchbox to a t-shirt is that you rarely put that t-shirt into a microwave oven okay it's a difference in that sense you heat up the plastic you have your broccoli or whatever inside and you don't want certain substances because it's heated to transfer to migrate into what you will then eat okay or drink or whatever so this is why fcm is is different okay from other products that's the one really unique to the eu so we're looking at both max levels also migration levels now keep in mind that the requirements differ depending on the material i'm going to get to that in a bit okay but if we break down the basics it shouldn't release certain chemicals or heavy metals into the food at levels are harmful to human health and this definition changes okay but that's absolutely lab to keep track of you don't have to keep track of that as as an input or exporter in most cases as long as you work with a lab that is okay it shouldn't it shouldn't change the food composition the taste or the smell okay and okay this is a repeat but yeah i think you get a point so fcm is a bit different compared to consumer product regulations like reach to give an idea okay a big one is the regulation 10 2011 that specifically covers plastics okay keep in mind you need to take this in consideration not only if the entire product is made of plastic like a lunchbox but if there's a single little part somewhere that's that's made of plastic then you need to ensure compliance with that situation like that so a fairly big brand in in the eu not gonna mention them but um they they overlooked this uh in a stainless steel bottle and it turned out that they they there was a plastic part in the lid or something so they they had to urgently make sure that they uh got their act together when it comes came to this regulation so it could apply to lunchboxes as i said sometimes made entirely out of plastic but also like stainless seed bottles that may contain uh plastic parts and lid or something but also obvious products like disposable plastic cutlery uh kitchen utensils and also feeding bottles there are some additional requirements for that another one that is maybe not always like that obvious is also composite materials with delt i think that was last year in 2019 dealt with a customer manufacturing or importing plastic melamine and bamboo composites plates and and drinkware and so on to be specific and they also thought they were exempt because it contained i don't know 50 or 60 bamboo or something but that's not the case all right now the big thing is with with this regulation is that you need to issue a declaration of compliance not to be um mixed up with decoration or conformity which is something you need for the you know ce marking products okay it's a different thing well different but still the same um now the declaration of compliance is a bit more complicated you need the basics like the company name the address the sku the date and also list which fcm regulations that your product is supposed to comply with you also need to provide data that relates to the testing process the lab testing process like the surface area and and you also need to provide information about information sorry about storage should it be like what temperature can it be stored in what time and so on okay um and this is something that can be fairly tricky to get so you're gonna work with your you need to work with your testing company to get uh information at least about the lab testing procedure and also specific substances okay um there are a number of other regulations and rules that apply to specific products and even origins and materials so there's a bpa restriction for plastic infant feeding bottles okay something that applies specifically to recycled materials ceramics active and intelligent materials not even sure what that is and this one is interesting uh products originating or consigned from mainland china or hong kong okay i think that's related to the melamine situation or scandal it went down in i don't know 2008 or something okay so how do you know is regulation applied to your product uh my recommendation is that you reach out to a to a testing company like gma or intertek and you basically give them a breakdown a breakdown of every single component because as i said a plastic lid can change you know which regulation apply even if the rest of the product is made of stainless steel okay so that's that's one thing to consider give them a breakdown a list of components and materials and the way the product should be used and the origin and so on and based on that a testing company like chima or intertek and they say okay we believe that you need to comply with this and this and that regulation and in turn we need to do these tests that's my recommendation now another aspect of the eu fcm regulation is also product traceability that you may need to add a tracking label so that in case of a recall in case it turns out that okay you imported or manufactured a batch of products and you're unlucky resulting in in having a product containing excessive amounts of restricted substances then you need to do a recall a traceability code can help you to identify that specific product based on sku the manufacturing date doesn't have to be one single day but it could be the month and year assuming you only place one order that month production facility and also country code so that way sku uh ef76c and okay i can't really remember what that means i guess i guess we had some sort of idea when we put this together but i think you get the point what matters is that you can you can actually trace that specific product down to a a batch of products and then recall that batch of products instead of say all products sold that year okay fcm lab testing now lab testing is necessary to verify compliance to specifically check the substance levels and also migration levels okay now the data as i said is also needed for the declaration of compliance without lab testing you can't really fill out a declaration of compliance well unless you have your own lab which you know given that you're watching this video i don't think you do so you're probably gonna have to reach out to testing company it could be chima sgs into tech and so on and as i said point four they can also help you assess which regulations may apply to your product because when you go back and you see all these different rules and so on which by the way may be outdated tomorrow or maybe already okay so um you need to work with a testing company that stays up to date and actually qualify to make that assessment whatever you do don't go to your supplier okay um yeah keeps getting um more complex um there's also something called gmp or good manufacturing practice that also applies that's also like part of the eu fcm framework regulation basically gmp requires that there is some sort of like control and documentation during production so not just about passing the test but that materials are pre-selected and procured that the production and quality assurance process is carried out ing to pre-established instructions quality control and verifications system is established utilize good and proper production facilities during the manufacturing process and this is this is pretty vague all i can say is the way that our customers been dealing with this in the past is that they have been sort of creating checklists for their manufacturers to basically fill out okay we um the supplier has checked incoming materials that you have maybe notes in the performer invoice that this and that material has to not contain this or that substance could be another thing and also quality quality control documents which you normally have at least very important problems in china vietnam or india other countries are in asia um but to be honest i haven't really like seen any anything definitive so my take is that the customers that actually do care sorry the companies that actually bother with this and there's a lot of them that don't which i absolutely don't recommend you to do um they have different takes on this because it's pretty open-ended right i would reach out to the national uh market surveillance authorities that cover fcm in your country that's what i would do i would ask them okay what like in practical terms what sort of gmp documentation do you actually expect and maybe you would get something but yeah that's really my only suggestion when it comes to gmp because it is really vague okay and then there's also the symbol you've probably seen this one it's a glass and a fork symbol and at least as of today it's only required if it's not obvious that it's an fcm it's a product that's supposed to be um used in uh you know contact with food or beverage so if it's a mixer well you know it's a mixer we know what a mixer does but maybe it was the first mixer in the in in the world maybe you would need one i think you get my point or if if it actually is a a fork um i think i think we all know how our fork works by now what it's used for so we wouldn't need that but if you come up with i don't know something something new or if it's an exotic design then then you may need it okay all right sorry that's from the template now anyway um i suggest that your next step is to try out our free product compliance information tool which well the way it works is that you input information about your product the product name the category materials usage and so on packaging information and in which country you plan to sell it and based on that the system generates a pdf report with information about labeling lab testing documentation and so on that may apply to your product okay it's not definitive it's not a guarantee but it's a good first step so best of all is also free so go to compliancegate.com free or you can also subscribe