Taiwan Proposes Inspection/Assessment for Most Apparel, Made-ups, Etc.
According to the Office of Textiles and Apparel (OTEXA), Taiwan's Bureau of Standards, Metrology and Inspection (BSMI) has issued a proposal for comment on its intention to conduct inspections and conformity assessment for most apparel, made-up goods, etc. that are domestically produced or imported, before they can be placed on the market in Taiwan. The proposed date of implementation is January 1, 2012.
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(Note that no comment due date is given.)
Would Affect Apparel, Towels, Bedding, Etc. that Could Directly Contact Skin
In its notification of the proposal to the World Trade Organization (WTO), Taiwan describes the textile products that would be affected as those having the possibility of direct contact with the skin. These include most apparel products, towels, bedding, mattresses, kitchen linens, certain fabrics, etc. The proposal notes that drama costumes and customer-made clothing would not be included. (See notification for complete list of affected Harmonized System/CCCN classification numbers and product descriptions.)
Proposal to Protect Public from Textile Processing Dyes, Finishing Agents, Etc.
Taiwan states that the presence of free formaldehyde, azo colorants and other hazardous chemical substances resulting from the processing of textile products, which usually involves the use of various kinds of dyes, auxiliaries and finishing agents, has been a great concern expressed by the public over the past years. As these hazardous substances are considered to be carcinogenic or toxic to human and in response to the requests of the public, the BSMI intends to regulate the safety of textile products with possible direct contact with skin to protect the health of consumers.
Products Would be Inspected for Formaldehyde, Certain Colorants, Cadmium, Lead, Etc.
Before being imported or placed on the domestic market, the subject products would be inspected for “free formaldehyde, prohibited azo-colorants, cadmium, lead, physical safety requirements, organic tin, and labeling.” The standards for inspection would be “CNS 15290 and Labeling Criteria for Apparel And Garments, Labeling Criteria for Textiles.”
Conformity Would Be Assessed Through “Monitoring Inspection” Procedures
In addition, BSMI is proposing to use its “Monitoring Inspection” (including random sampling) and “Monitoring Inspection of Products from Premises with Registered Management Systems” conformity assessment procedures for these products. In a separate background document, BSMI describes these procedures as follows:
- Monitoring inspection. The Monitoring Inspection Scheme is a simplified batch-by-batch inspection system, based upon a confidence building process. When a number of batches of a certain commodity have successfully passed batch-by-batch inspection, the inspection of that commodity may be conducted in the manner of batch-by-batch verification, randomly selected batch inspection, document examination or monitoring program. However, the inspection mode reverts to batch-by-batch inspection if any noncompliance is found. (BSMI expects that the rate for monitoring inspection (including random inspection) of the affected products would be 2.5% of CIF.)
- Registered management system monitoring inspection. In addition, manufacturers who obtain management system certification from the BSMI and comply with the requirements may issue the monitoring inspection certificate on their own. Alternately, the certificate can be issued by the BSMI once the inspection records have been submitted for approval. This will expedite the procedures for customs clearance and shipping, reduce the inspection workload for authorities and manufacturers and also prevent inferior goods from entering the market. (BSMI expects that the rate for monitoring the subject textile goods under this system would be 2% of CIF.)
(Taiwan’s monitoring inspection procedures document states that an application for inspection must be made to the inspection authority of the entry port upon arrival of the commodities or to the inspection authority located at the manufacturing location before domestically manufactured commodities are shipped out of the production premises. When making the application, an applicant shall complete an application form and provide the following: inspection fees, relevant testing records, production records, other documents as required by related announcements, other documents required for inspection, and a power of attorney if the application for inspection is made by an agent.)
Can Submit Comments Through NIST Website, Provide a Copy to OTEXA
OTEXA recommends that interested parties submit comments through the U.S. National Institute of Standards and Technology (NIST) comment webpage and provide a copy to OTEXA.
BSMI information on Regulatory Product Inspections, updated 01/26/11, available here.