C of Cs (Certificate of Comformance) for Private Label Products

[RosieA]

In addition to manufacturing our own products, my company also buys products from a number of foreign suppliers and then resells them under our name.

We go through a qualification process for each part that is outsourced, however, once the item is approved, it ships directly to our warehouses and I never see it, or inspect it again.

Our warehouse inspection is limited to count, configuration or damage.

When I am asked to do a standard cert for these items, I don't know how to handle it. I saw the original product, but haven't had any involvement with them once they were approved. Often these cert requests come after the the shipment so there is no opportunity to order product from the outsource supplier with a cert.

Any thoughts on how to address this?

 

[Hershal]

Re: C of Cs for Private Label products

Your situation is not unique. ISO Guide 65 accredited product certification agencies face a similar if somewhat different situation, in that they allow use of a logo but are not there to see every unit being manufactured. Also, components or systems may be outsourced to other plants that are (hopefully) owned by the same company.

Now, ISO Guide 65 requires the accredited organizations to have policies - including enforcement protocols - regarding use of their mark. So, if you see UL/CSA, or in your area of the country ETL then take heart, they may actually hold the answer.

First, I would require them to sign an agreement (resign the existing if necessary) that includes inspection requirements for use of your name, even though they are a sub-contract manufacturer for you.

Second, develop or contract an inspection body that is accredited to ISO/IEC 17020 (e.g., ITS or similar) as they are under a third party oversight that looks at the QMS and also reviews them in the field in actual inspections, verifying competence.

Now, that may not solve ALL the potential issues, but at the very least will provide liability migration for your employer.

If you need more details, send me a message, otherwise hopefully this helps.

 

[MIREGMGR]

Re: C of Cs for Private Label products

What is your industry, or the standard upon which your quality system is based?

Some industries and quality systems, of course, have explicit requirements for ongoing control of suppliers, and assign to you full responsibility for every unit of whatever you buy in regard to how it affects what you sell or otherwise provide to your customers.

 

[harry]

Re: C of Cs for Private Label products

so there is no opportunity to order product from the outsource supplier with a cert.

Make it a requirement that they supply you a cert with every batch/order irrespective of whether any of your customers request for it!

 

[RosieA]

Re: C of Cs for Private Label products

What is your industry, or the standard upon which your quality system is based?

Some industries and quality systems, of course, have explicit requirements for ongoing control of suppliers, and assign to you full responsibility for every unit of whatever you buy in regard to how it affects what you sell or otherwise provide to your customers.

I'm in the metal working business, not usually sector specific, so we're plain vanilla ISO 9001 and UL/CSA/ETL isn't a requirement.

Harry, I agree on the certs. that was my first thought too. Our Purchasing organization is very spread out and my job now becomes getting this word out to all the purchasing sites.

Hershal, thanks for the insights!

 

[lday38]

Imported Our Company Label products

My company buys product from China, putting their name on it and importing it to our warehouse. The product is small electric appliances like toasters, and food processors. We do have a quality system body in China that audits the finished product but not necessarily the components. Our engineers do the product design and right out the original specification. I dont beleive they have prints for the parts with each component. I get a copy of their audit on the finished product. Is this sufficent to satisfy ISO 9001 requirments? I would say the componenets ( for service or resale) are an issue as there is no cert.
We also assemble one product here in the US. However, the components are from China or another supplier.
Lin

 

[Jim Wynne]

Re: Imported Our Company Label products

My company buys product from China, putting their name on it and importing it to our warehouse. The product is small electric appliances like toasters, and food processors. We do have a quality system body in China that audits the finished product but not necessarily the components. Our engineers do the product design and right out the original specification. I dont beleive they have prints for the parts with each component. I get a copy of their audit on the finished product. Is this sufficent to satisfy ISO 9001 requirments? I would say the componenets ( for service or resale) are an issue as there is no cert.
We also assemble one product here in the US. However, the components are from China or another supplier.
Lin

The question is not whether it's sufficient to satisfy ISO 9001 requirements, but whether it's sufficient to confirm that the products conform to your requirements. Because you're dealing with electric appliances, you should be concerned with whether the products conform to legal and regulatory requirements as well. If your requirements are properly documented and the products consistently satisfy those requirements, there shouldn't be a problem with the standard.

 

[RosieA]

Re: C of Cs for Private Label products

A couple more thoughts to consider:

How much control does your company have on the design? Do you require them to use component suppliers that you have qualified, or are they free to switch component suppliers as they wish? (the latter would be a red flag for me)

Who does the UL/CSA testing, you, or them? If them, do you audit their records to be sure they are keeping up with their qualification?

Are you tracking warranty information, so you know if there is an uptick in field failures?

 

[lday38]

Re: C of Cs for Private Label products

Yes, we track field failures and analize returns. Yes, we statisfy UL requirements and recently have switched over to EL requirements. The supplier thing is a good point.
I am wondering if they could limit the scope of their registration to the assembly plant.
This plant is in Pa. I am wondering who is the registration bodies in that area, how much for audit and registeration
Lin