The RAPEX-China programme highlights traceability problems for unsafe products
The RAPEX-China programme has been operational since September 2006 and extends arrangements that have been in place in Europe for many years. The RAPEX system is used by member states to alert other member states about dangerous products that have been found on the marketplace which are likely to also be available in other European countries.
On October 25, 2010 the latest RAPEX contact points meeting was held in Brussels to review the RAPEX-China arrangements (which strive to create closer links with our Chinese counterparts). Member states now liaise much more closely with the Chinese authorities regarding Chinese products which have been found to be unsafe in Europe.
The figures show that 5,203 notifications have been stored in RAPEX-China, with 1,324 notifications investigated. It is clear that only 30 per cent of reported cases are investigated and that there is an uneven number of investigated and reported cases.
The biggest challenge by far in respect of this work is in relation to traceability. Where there is insufficient information on a product to identify the manufacturer then it makes follow-up action almost impossible. In 23 per cent of all reported cases, the responsible manufacturer/exporter could not be found.
This is a common problem for trading standards officers in the UK. Time and again, they find items for sale (especially toys) on the market place which they test and find to be unsafe. The lack of any identification marks on the product means that the only action they can take is locally - they can remove the products from sale in their area but are unable to effectively address the national/international position because they cannot properly identify the manufacturer.
Alternatively, some UK distributors will operate out of a Post Office box which makes locating them difficult. Even if they are successfully located, missing manufacturer information will again make tracing the product back to source almost impossible, especially if it has passed through a series of agents before arriving in Europe (as is common).
There are a number of other considerations here: certainly in the UK there are limited resources to allow authorities to investigate this aspect in detail and if information is not available there is very little that can be done to deal with unsafe products. Just as problematic is when information provided on the product or in attached documents is false - which often happens.
On the Chinese side, while official procedures are in place, if products are manufactured and exported outside these procedures then transactions cannot be traced. Other problems include: manufacturers and exporters not keeping copies of documents (contracts, invoices, shipping documents etc.); changing their addresses; and in many cases closing their businesses due to the economic downturn.
Products identified at the meeting in October 2010 included puffer balls, washing machines, extension sockets and novelty lighters.
Philip Le Shirley, Product Safety Adviser for RoSPA