Compliance is one of those topics that may only ever come up after a severe problem has occurred. If 2020 has taught businesses leaders one thing, it is that it is important to manage and mitigate risk proactively. Fortunately, producing fully legally compliant product markings, user manuals and information available at the point of sale POS) can be achieved by considering these factors:
- Considering all relevant audiences: product users, delivery personnel, installation personnel
- Understanding and correctly implementing industry specific legal requirements relevant to the country a product is sold in
- Selecting appropriate means of communication including physical and non-physical media
Ensuring that product related information meets the three criteria listed above and is fully compliant with local requirements can be a challenging task. It requires specific knowledge about constantly changing local laws and regulations. Most importantly, not only the manufacturer of a product, but ultimately the importer or re-seller need to ensure that their products meet all requirements.
To ensure that the artwork of our clients used to create product labels, safety stickers, and POS and assembly instructions is legally compliant we follow this process:
We first analyse the target market and different user groups (different audiences). Products that require expert installation or special handling during transport often require additional safety labelling. It is also important to be aware of different usage scenarios that may apply in different countries. Whereas in some countries the delivery and installation of a product may be carried out directly by a seller or by appointed contractors, other markets may follow a different approach. Safety and compliance communications need to take this into consideration to ensure that relevant information is made available to these different audiences.
As a next step we analyse different risk categories that apply to the specific product types. Those risks can be grouped as follows:
Electrical safety
This category covers death and injury related risks that apply to humans and animals, such as scalding or electric shock. It also covers the protection of property against damage that could be caused, for example, by fire or flooding.
Functional safety
This category applies in cases where the proper use of a product may affect user safety. A sensor controlled vacuum cleaner, for example, requires its sensor to function accurately in order to prevent it from potentially becoming a drop hazard.
Foreseeable misuse of a product
These types of risks are related to how a user can potentially operate a product in an incorrect way. A good example is a kitchen scale that is used to measure the weights of cooking ingredients. A foreseeable misuse is that a user could stand on the scale to measure his or her own weight. Such a high load could potentially damage the scale. It is important to communicate this to the user.
Safety regulations are continually evolving and existing laws and regulations are being updated regularly. Stricter policies aiming to improve user safety result in new safety regulations. One example of a relatively new law is the European Union’s Energy-related Products Directive (ErP) which has established mandatory ecological requirements for energy-related and energy-using products sold within the EU. The directive has come into effect in order to reduce energy emissions within the EU by requiring manufacturers to meet stricter energy consumption standards.
In addition to local laws and regulations, we at Impala also check information according to safety standards. Within the EU, for electrical products, these are provided by CENELEC (the European Committee for Electrotechnical Standardization). CENELEC publishes European harmonised safety standards (EN) that are often localised versions of the international standards (IEC). Each of the EU member states is then given a certain period of time to adopt the EN standard in its local standard. Member states review the EN standards and issue their local version that either precisely follows the EN version, or is implemented with some modifications. These standards are typically published in the local language of the member state. Examples of local standardisation bodies in Europe are DIN (Deutsches Institut für Normung) in Germany or NF (Norme française) in France.
Physical vs non-physical safety communications
Most brands are familiar with physical media used to communicate safety requirements. These include: tags and safety symbols (i.e. stickers on packaging), as well as those printed in manuals, and labels on packaging, blister packs and POS. Digital media such as information on websites, or information distributed via email or pdf files is also important and sellers need to ensure that there is consistency when information is disseminated via these media.
Brands are increasingly aware of the cost of not being compliant. Product recalls are not only very costly, but can also harm a brand’s reputation permanently. We help our clients manage these risks by offering services that go far beyond the scope of traditional testing labs. That is because we focus on an outcome driven solution. Rather than stopping at a point where we determine compliance or non-compliance, our objective is to provide fully compliant deliverables. In practice this means: if we encounter a case where we believe that product artwork is not fully compliant we will investigate the issue, interpret the area of non-compliance within the context of the relevant safety standards, then translate the outcome of this investigation into a specific brief for our copywriters and translators and as a last step hand over to our typesetting and design team that will deliver ‘ready to print’ files to our clients. We thus take over complex project management related tasks that require engineering, legal and copywriting specific expertise.
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