API is glad to be participating as a sponsor at the 2022 ICPHSO Annual Meeting and Training Symposium. The event will take place on February 14–17, 2022 in Washington, D.C. The four-day Annual Meeting and Training Symposium provides an opportunity for global health and safety professionals to participate in discussions that further enhance the safety of consumer products throughout the world.
Will you also attend the event? Book an appointment to talk to our team!
Visit ICPHSO’s website for more details about the event: https://icphso.org/
The UK has introduced a new tax on plastic packaging that will come into effect on April 1, 2022. Known as the UK Plastic Packaging Tax (PPT), this will affect businesses that manufacture or import plastic packaging, including packaging that already contains goods (such as plastic bottles containing beverages). The tax aims to encourage the use of recycled rather than virgin plastic in packaging (when permitted) and stimulate the increase of recycling and collection of plastic waste.
How will the tax work?
The PPT tax applies to plastic packaging that is manufactured in or imported into the UK, in which the plastic used in the manufacture is less than 30% recycled.
All plastic packaging will be assumed not to meet the recycled content requirement unless companies can prove otherwise.
The tax rate will be £200 per metric tonne of plastic packaging for applicable companies. For example, if a company manufactures 10 tonnes of plastic packaging, and 1 tonne contains less than 30% recycled plastic, the company will need to pay £200.
Who needs to register for the tax?
Any business that manufactures or imports 10 or more tonnes of plastic packaging over a 12-month period needs to register for the PPT tax, even if their packaging contains more than 30% recycled plastic. In such a case, however, the tax won’t need to be paid.
This includes importers of packaging that already contains goods, such as plastic bottles containing beverages. If the packaging you import already contains other goods, the tax only applies to the plastic packaging itself.
Records will need to be kept, even if all the packaging manufactured or imported contains more than 30% recycled plastic.
The online platform for registration and payment will become available when the PPT tax takes effect on April 1, 2022. Read more information about registering for Plastic Packaging Tax.
Please reach out to our experts to learn how API can support your transition to this new packaging tax.
Household goods manufacturing and supply chain operations remain under significant pressure, forcing the speeding up of processes in some cases to meet tight deadlines. An increasing need for agility and flexibility has introduced new risks as well as shortcuts and vulnerabilities that can lead to compliance and regulations violations.
With the pace at which the many complex parts of a supply chain must move to keep up with changes and disruptions, brands and retailers should be working with suppliers that can guarantee reliable outcomes without compromising the integrity of their processes and products. Strong visibility and understanding of the supply chain and adequate supplier mapping are essential steps for avoiding quality and compliance situations that don’t go according to plan.
The most effective way to address these challenges is to map your suppliers by performing factory audits, identifying areas of risk ahead of time and ensuring you work only with the most reliable partners. A factory audit will make certain that your supplier can produce your product to your expected levels of quality without jeopardizing supply chain integrity or compliance in destination markets.
Factory audits also help assess the risks that may be present with a particular supplier and provide direction on how to manage those risks.
The decision to work with a particular supplier will ultimately be up to you, but a factory audit will mean your decision is based on a trusted risk assessment with a presented improvement strategy.
The criteria for selecting the right supplier will naturally vary and depend not only on international requirements and regulations but also on industry best practices and brand values and guidelines. For example, you may request that a supplier apply stricter environmental measures to ensure eco-friendlier processes and reduce their impact on the planet.
Our checklist sample takes you through what a brief assessment of your supplier’s quality systems might look like, and touch on quality management, social, and environmental compliance.
The checklist example covers three main sections and includes some of the more common points when evaluating supplier performance in these areas:
The following guidelines can be followed for each process:
N/A: Process not available or not evaluated.
0 – Major non-conformity: Absence of procedure or proof of significant discrepancies in implementation. Corrective action will be designed for this process.
1 – Minor non-conformity: Incomplete procedure or proof of discrepancies in implementation. Corrective action will be designed for this process.
2 – Acceptable: Procedures are available and implementation is acceptable; however, opportunities for improvement exist. An opportunity for improvement can be designed for this process.
3 – Good: Procedure and implementation are acceptable; no opportunity for improvement identified.
4 – Best practice: Factory has designed and implemented the industry best practice.
Quality Assurance & Technical Assessment
Technical assessments will obtain an objective picture of your supplier’s organization and evaluate their capabilities in the following areas, among others:
Adequate quality management system and framework to achieve acceptable quality levels.
Relevant product knowledge and the ability to produce the products in compliance with international regulations and customer expectations.
Capability to mass-produce on time while maintaining the required levels of quality and safety.
When evaluating a supplier’s capacity, some of the most frequently considered points include:
Quality manual and procedures demonstrate revision control (sign-offs and dates), history of changes.
Product quality yield data, problems and corresponding improvement actions, the status of preventive/corrective/audit results.
Strategic and tactical objectives, goals, action plans, etc.
Analyses of field failures, inspection yields, resource needs, internal audit results, corrective action statuses, etc.
Corrective actions, trend charts, meeting minutes, non-conformance frequency and cost analysis.
Management review meetings and corrective actions.
Investigating training aids and instructions at workstations.
Qualification records, certification history.
Testing records, production quality records, audit records, interview workers to validate training records.
Job descriptions, job skills assessment, training records, training manuals.
Example of a quality audit checklist:
API factory quality audit checklist
What If My Quality Assurance Score Is Below Standard?
Thanks to its manufacturing and product knowledge and experience on the field, API is able to customize its QA solutions based on your specific needs and requirements. API will provide the supplier information on how they can go about improving various things within a factory. This information will be relayed back you, the retailer, where you will gain insight into your potential supplier and their factory operations to ensure compliance across the board.
Social / Health & Safety Assessment
The objective of a social audit is to provide an unbiased image of a supplier organization and practices according to local laws and international standard as well as your internal code of conduct.
Thanks to an adequate assessment of your pool of suppliers, your company can protect its brand image and improve its competitiveness. Managing your social risk should bring associated costs saving and should also foster long-term cooperation with a selected pool of suppliers.
To evaluate your supplier’s ability to meet the expected social, health & safety requirements, some of the more critical areas typically covered by a social audit include:
Checking whether factories operate in compliance with laws specifically related to wages and compensation, working hours, child labor, forced labor, harassment, and abuse.
Examining conditions in production and residential facilities and their consistency with applicable laws and regulations
Reviewing emergency preparedness and response plans as well as monitoring and performance measurements
Evaluating whether all possible precautions are in place to reduce labor and safety risks
The social audit assesses the social systems and structures that your supplier has in place and is normally based on the standards as laid out by the SA8000 and ETI Based Code. As a professional third-party auditing company, API is able to provide their industry expertise and longtime experience to aid you in achieving your social compliance certification. In addition to this analysis, our team will also define a corrective action plan and can also help you in the implementation and follow-up of this list of actions.
Example of social audit checklist:
API factory social audit checklist
Environmental Audit Assessment
It’s not new that supply chains are under increasing scrutiny to ensure environmentally friendly processes. In the context that we are currently living it’s important to verify that your suppliers are aligned with the relevant requirements and regulations to ensure a sustainable supply chain, and that they comply as well with your brand requirements and expectations. The best way to obtain a good level of visibility is by performing and environmental audits assessment to evaluate all relevant criteria and improve the environmental and chemical performance of your suppliers.
In order to evaluate your supplier’s ability to respect the environmental requirements some of the most critical areas usually covered during an environmental audit will cover the below:
Environmental policy statement document
Records of agency/government inspection, procedures for measuring and monitoring environmentally sensitive activities
Record of purchases, waste stream and consumption; inventory control procedures
Records/use of; non-hazardous (RoHS/WEEE compliant) materials in production, biodegradable materials, returnable containers or packaging, recycling program, packaging materials made of recycled materials
API sustainability team can help you assess the environmental and chemical performance of your suppliers with an accurate evaluation and adequate action plan to reduce the impact of your supplier’s processes and ensure that you are in the right path to achieve your sustainability goals and meet your customer’s demands.
Our on-the-ground expertise and our strong presence on the field allow us to have a deep knowledge of the factories processes, challenges and the applicable regulations. We understand your processes, factories and products, and are able to provide bespoke sustainability services that will result in higher levels of efficiency.
Example of environmental audit checklist:
API factory environmental audit checklist
KEY TAKEAWAYS
An adequate factory audit allows you to have a better visibility of your supply chain, starting with the relevant insights of your suppliers’ quality control processes and manufacturing capabilities, social and environmental practices to identify the best performing suppliers and those with the higher risk. This allows you to select your pool of suppliers accordingly and empowers you to strengthen those weaker processes where needed.
An adequate audit checklist will help ensure:
your factory’s quality systems are up to date, organized and well recorded.
confidence in the selection of your supplier based on checklist insights.
confidence in the quality of the product that is manufactured.
confidence that your supplier is actively meeting compliance standards, social and environmental practices.
This approach allows you to build a more collaborative relationship with your supplier, where you supplier has a more invested approach to your brand and its product. It helps to ensure top-class quality systems and a mutually beneficial relationship between supplier and retailer and a better budget allocation to focus where risks are high.
Interested in learning more about how API can help you with our audit solutions?
On September 14, 2021, the new SCIP Dissemination Portal by the European Chemicals Agency (ECHA) went live, giving the public access to information about substances of concern (SVHC) in articles as such or in complex objects (Products). The portal’s launch increases the transparency over chemicals of concern in products and will help track products containing substances of very high concern until they reach the waste stage. It also allows consumers to make more informed purchasing decisions and to choose safer products.
Since January 2021, companies that supply articles containing substances of very high concern (SVHC) on the Candidate List in a concentration above 0.1% weight by weight (w/w) in the EU market have been required to submit information on these articles to the ECHA. The notifications are stored in the SCIP (Substances of Concern in Products) database, and will be publicly available via the portal throughout the entire lifecycle of the products and materials – including the waste stage – contributing to a safer circular economy.
In a recent announcement, the ECHA said that around 6,000 companies across the European Union have already complied with this new obligation, with more than four million relevant article notifications registered in the SCIP database.
Based on the information gathered so far, the most notified product categories include:
Machinery and their parts
Measuring instruments and their parts
Electronic equipment and their parts
Vehicles and their parts
Articles made of rubber
Furniture.
Who needs to submit information?
Companies that supply articles containing substances of very high concern (SVHC) on the Candidate List in a concentration above 0.1% weight by weight (w/w) in the EU market are required to submit, including:
EU producers and assemblers
EU importers
EU distributors of articles and other actors who place articles on the market.
Retailers and other actors that supply articles directly to consumers are not obligated to submit this information to ECHA.
What information needs to be submitted?
Information relevant to the identification of the article;
Name, concentration range, and location of the SVHC; and
Other information on the safe use of the article, particularly if the above information is not sufficient to ensure the proper management of the article as waste.
Do you have any questions about how the new SCIP database requirements affect your business?
Many governments around the world are using legislation to drive responsible business practices and positive impacts on people’s working conditions. These laws require companies to manage their operational impacts on people and the environment and report on their efforts. It’s important to know which of these laws apply to your business and how to comply.
One of the most recent changes in this area is the new Human Rights Due Diligence Law adopted by the German parliament on June 11, 2021.
From 2023, this law will require large companies to conduct supply chain due diligence activities. Companies will need to identify, prevent, and address human rights and environmental abuses within their own and their direct suppliers’ operations, and take actions if they find violations.
The law aims to ensure that social and environmental standards are maintained in large companies’ operations and supply chains to address the following risks:
Forced labor
Child labor
Discrimination
Violations to freedom of association
Unethical employment
Unsafe working conditions
Environmental degradation.
Who does this new law affect?
From 2023: Companies based in Germany with more than 3,000 employees, or German-registered branches of foreign companies with more than 3,000 employees.
From 2024: Companies based in Germany with more than 1,000 employees, or German-registered branches of foreign companies with more than 1,000 employees.
What do the affected companies need to do?
Set up a process to identify, assess, prevent, and remedy human rights and environmental risks and impacts in:
1. Your supply chain 2. Your own operation.
Ensure you provide ways for employees of indirect suppliers to file a complaint alerting the company to any human rights or environmental violations.
Publish an annual report outlining the steps you have taken to identify and address these risks.
How can affected companies prepare for this change?
If this – or any similar law – applies to your business, it’s most important to have a clear internal process to understand and assess your supply chain:
Step 1: Define your scope
Map your suppliers and put in place a preliminary risk analysis to better understand your supply chain and current CSR capabilities.
Step 2: Pre-assess your suppliers’ CSR conditions
Conduct a deeper evaluation to identify your most reliable suppliers, the ones requiring action, and those with zero tolerance issues. You can then prioritize your program and create an action plan.
Step 3: Apply relevant actions based on identified risks and priorities
Deploy an adequate action plan based on the identified issues and their risk levels and implement remediation programs to improve the suppliers’ performance.
Many other countries have enhanced their regulations on human rights, such as:
Australia: Modern Slavery Act 2018
France: Corporate Duty of Vigilance Law
Germany: CSR Directive Implementation Act
India: Business Responsibility and Sustainability Reporting
Italy: Legislative Decree no. 254
United Kingdom: Modern Slavery Act 2015
United States: Transparency in Supply Chains Act 2012 (State of California).
How API can help you prepare for these legislative requirements:
Documentary review
Preliminary risk assessment to help you prioritize issues
Factory audit
Training
COC/manual/audit guidelines creation and review
Program benchmarking services for strategic suppliers.
The kitchen utensils and cookware industry is highly regulated, with strict safety standards to ensure the health and safety of consumers. Chemicals present in what’s known as ‘food contact materials’ are known to potentially migrate and contaminate the food they come into contact with, creating risks for consumer health.
How can consumers therefore be sure that the container in which they are storing their food is safe? Or that the mug they are drinking coffee from is not releasing harmful chemicals? In most countries worldwide, all food contact products must comply with the applicable regulations governing the most common materials used and the product’s intended use.
The rules to follow depend on the material and country. For example, items sold in the EU and the US must comply with regulations such as the EC No. 1935/2004 in the EU or the FDA 21 CFR in the US, which cover the most common materials such as plastics, silicone and rubbers, metals and alloys, ceramics, wood, paper and board, varnishing and end coating, and more. Different criteria will apply if the container is plastic or ceramic, for instance, but also if it is intended to be used for aqueous food such as water or coffee, acidic foods like juice, or alcoholic beverages such as beer or wine, and if the container is designed for a single or repeated use.
Risks can still be identified after the products arrive on the market, even for major brands, which not only put the brand’s image at risk but can also generate additional costs if there are product recalls or fines. Some major brands were the object of product recalls last year, such as a major international furniture and décor brand that recalled a mug from the market which was potentially migrating excessive levels of dibutyl phthalate (DBP).
On top of the chemical risks, kitchen accessories have some associated physical risks related to fatigue, corrosion, and heat resistance as well as thermal hazards. They also must perform according to their expected use; for example, if they are intended to be microwave- or dishwasher-resistant, they will need to handle heat or water without breaking or suffering damage. While this may seem straightforward, physical risks are also frequently identified in the market for kitchenware articles. More common recalls include a heightened risk of injury and burns because of a container breaking under heat exposure or laceration hazards due to product cracks.
Meticulous quality checks and in-depth regulatory knowledge are critical, as well as ensuring you work with the right suppliers and maintain strict controls throughout product development and manufacturing. It is vital to understand each factory’s capacities, the origin of the materials used, and that the design is being precisely followed. To improve overall product quality, a factory audit can help you understand and optimize a factory’s capabilities, including:
Quality management
Product development
Incoming quality control
Production process control
Finished product quality control
Resources management
Stock management
Measuring & testing equipment control
The kitchen utensils and accessories industry is also highly competitive. Numerous brands compete for consumer attention with constant overhauls of their range and, in many cases, a price battle. This adds further considerations to the equation, such as the importance of innovation and fit-for-use to bring products to the market that meet consumer expectations.
In this challenging environment in which supply chains are under pressure and shipping delays put delivery times at risk, ensuring product quality and safety before the end of production is key, so you ‘get it right the first time’.
API’S SPECIALIZED SOLUTIONS FOR KITCHENWARE
API helps brands and retailers ensure the safety, quality, and performance of their kitchenware with our tailor-made solutions. Some of our key areas of support include:
Laboratory testing: Testing according to EU/US or country-based directives to maintain chemical and physical safety as well as testing with specific protocols to ensure performance and fit-for-use.
Product development support: Identification of critical areas and recommendations for adjustment at the design or purchase stage.
Technical Compliance File: Documentary review that attests product compliance according to protocol definitions, from document collection and verification to report issuance.
Factory audits: Factory evaluations that assess factory capabilities to meet production standards and deliver safe products on time.
Dedicated programs: Bespoke programs based on each client’s needs that provide support at every stage of the supply chain.
Interested in learning more about API’s kitchenware solutions?
