What is product compliance?
Explaining product compliance
Product conformity varies widely from one product to another. It may depend on checks carried out before the product is placed on the market, but also during production. A product necessarily has a nomenclature, i.e. an architecture that makes it possible, step by step, to reach the single substance which, in turn, can be regulated. The ‘conformity’ aspect of a product ultimately comes from the conformity of the substances that make it up, but also sometimes from the uses, sectors of use, etc.
The first question you need to ask yourself is a simple one: what are the substances that make up or will make up my product? This involves describing the nomenclature of a product, listing the sub-parts and any lower levels until a list of substances is compiled, identified by their CAS number, their EC number and their name. This information is necessary and can be obtained from the supplier of the said part, who will in turn ask his supplier for the information, etc., going back up the supply chain to the substance producer.
The product's compliance therefore depends on the substances it contains, which may be found on regulatory lists, with varying degrees of impact on the product.
The fact that a substance is covered by a regulation does not necessarily mean that the product is non-compliant. Taking Annex XVII of the REACH Regulation as an example, it is sufficient to comply with the restrictions given in the substance datasheet for the product to remain compliant. However, failure to comply with these restrictions may result in a marketing ban.
In order for a product to be compliant, it is therefore necessary to ensure that it complies with the relevant regulations. The current difficulty of collecting all the information required for a product to be compliant, due to the constant increase in the number of regulations coming into force and the complexity of the products manufactured and placed on the market, means that a substantial database needs to be built up and regularly updated in order to meet regulatory obligations.
