From USA-ITA OFF THE CUFF, March 2012 (Volume 3, Issue 3)

In January, USA-ITA met with Kris Wan, Manager of Global Softlines Development Office at SGS, an Associate Member of USA-ITA. SGS provides testing, verification, technical consultancy and inspection for a variety of softlines products. Ms. Wan told us how U.S. companies can successfully export to the rapidly growing China market, and the importance of understanding China’s complex regulations and requirements.

The SGS team at Hong Kong Fashion Week, with Kris Wan in the center.

The SGS team at Hong Kong Fashion Week, with Kris Wan in the center.

Ms. Wan explained that China has a comprehensive system to regulate imports of textile, apparel, and footwear products. First, China has a number of chemical and physical requirements for textile and footwear products, and these requirements are compulsory at the national level in order for products to enter the country. These requirements and standards are specific to product categories, such as children’s rubber shoes, for example. These standards include, but are certainly not limited to:

  • Chemical requirements, with standards pH levels and chemical levels, and restrictions on a number of chemicals such as azo dye, to name a few
  • Performance requirements, such as color fastness and odor
  • Labeling requirements, including fiber content and washing instructions, and sizing labels
  • Product categories

China has a list of restricted substances, including lead and phthalates, as well as arsenic, azo dyes, cadmium, nitrosamines, and a variety of phenols, to name just a few. Restrictions of these substances are usually material and end use dependent. For mandatory standards such as GB 18401-2010 (textile products) and GB 20400-2006 (leather products), there are different requirements for different product categories dependent on the intended end use. For example, infant products should comply with the technical requirement of Category A. For another example, products with direct skin contact should at least comply with Category B technical requirement, while products without direct skin contact should at least comply with Category C technical requirement. For product standards, products are graded as “high class,” “first grade,” or “qualified grade,” to which companies can freely assign and label on hang tags. However, the product MUST fulfill all technical requirements associated with that grading. (While companies are free to assign their products a grade, if the grade is found to be false due to non-compliance, the Chinese government will notify the public.)

In comparison, the U.S. Consumer Product Safety Improvement Act (CPSIA) covers restrictions on substances in consumer products and bans lead, as well as phthalates in children’s products. These regulations are not product specific. The U.S. also has a federal law on textile labeling, but again, it is not product specific.

China also has a stringent surveillance system for monitoring product standards. This surveillance occurs at the country and province levels, at the port of entry, and even on the shop floors. Different Chinese authorities and their associated agencies will inspect products at the port for compliance with the regulations, monitor products via random selection at stores. If the authority finds products to be non-compliant, the products may be refused entry or confiscated and destroyed at ports and brands will be reported to the public. Sometimes, when the products in stores are found to be non-compliant, the brands will be notified to initiate follow up actions, which are usually product recall or re-work, within a given time-frame. The public is also informed on the results of product surveillance exercises.

The United States’ Consumer Product Safety Commission (CPSC) adopts a different approach. It allows consumers to report injuries due to consumer products on an internet database, but there is not the same level of surveillance for compliance with the regulations. While some states, such as California, have more complex regulations, the requirements in China are overall more comprehensive.

How, then, can U.S. companies be successful in China? Ms. Wan says, simply, companies must gain an understanding of China and the regulations. Companies should have a team, or a third-party laboratory, that understands Chinese and is dedicated to interpreting and understanding the regulations correctly. “It can be easy if a company sets up a team with knowledge in Chinese retailing requirement, regularly monitors the regulations website and the product recall updates to understand the risk level,” she says. But, a team that can understand these regulations is “critical” to a company’s success in importing to China.

Compliance with the regulations is not only critical to getting your products into the market, but it’s also critical to having a strong brand image in the Chinese market. While generally speaking, the Chinese are not as concerned with companies’ social compliance and eco-friendliness, they are concerned with the brand image, and if a brand is not respected because of non-compliance, sales could suffer.

China is perhaps the fastest-growing market in the world, and companies should want to take advantage of it. While the regulations may be difficult to understand, it’s certainly not impossible to be successful there—but companies must be vigilant.“Hong Kong is a place where East meets West. We find our values in high flexibility, innovation, and service excellence, we can play a role in the world apparel market to support the international brands and retailers entering the China market,” Ms Wan remarked.

For more information on the regulations in China or how SGS can help you understand them, visit We also encourage you to contact Kris Wan at This email address is being protected from spambots. You need JavaScript enabled to view it. or our USA-ITA contact, Katherine Stein, at This email address is being protected from spambots. You need JavaScript enabled to view it. 

About SGS

Headquartered in Switzerland, SGS is the world’s leading inspection, verification, testing and certification company. Founded in 1878, SGS is recognized as the global benchmark in quality and integrity. We operate a network of over 1,250 offices and laboratories around the world with nearly 64,000 employees. 

SGS Global Softlines has an extensive network of over 35 laboratories worldwide, with a strong team of committed professionals in multi-disciplines. We offer high-level expertise in testing, verification, technical consultancy and inspection for a variety of softlines products.