Hi Kevin,
I am in agreement with Gary in that it is my understanding that labels that are attached to product that falls within the scope of the legislation have in them selves to comply with the legislation.
We considered labels to be high risk items. This stance was primarily based upon the pigments, lead and chromates used in the inks in particular the red, yellow and oranges and the pantones that may use a combination of these inks or pigments.
In the case of subcontracted labels we always establish and specify the ink to be used in terms of the ink manufacturer from whom we have obtained the necessary documentation which in the case of high risk colours is supported by external testing. To date we have not found a non compliant ink such that our confidence in particular suppliers allows us to reduce our testing requirements and accept statements of compliance from particular manufacturers at face value.
With proprietary labels you may have an unknown supply chain. For example it may come from your distributor, but who is supplying them this week, and from what continent, and what type of specification / controls are in place? As such there is deemed to be a greater element of risk which may only be reduced by the use of external testing.
Have we had any failures to-date? No but it is the perceived risk that forms the current strategy which will be modified when sufficient evidence has been accumulated to support an increase or reduction in testing when dealing with a particular supply chain.
This is our selected course in the absence of specific direction from the policing bodies and reflects the level of due diligence expected from a company of our size. However it has been indicated that the smaller the company the lower the amount of due diligence is expected. That said will your customer measure your success by the degree of due diligence you can demonstrate or the amount of rejected product he has had to recover from the market place due to a non-compliant label, cable, finish on a fastener or dot of red paint. But that’s another story..........
