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Ensuring Internationally Traded Goods are SAFE
Carlos CorreiaVice-President & General ManagerGlobal High-Tech IndustryUnderwriters Laboratories (UL)
International Customs Conference
EU-China Modern Customs :: Building bridges to facilitate legitimate trade while protecting citizens
September 1-2, 2010 – Shanghai, China @ World Expo (v1.0b)
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ensuring internationally traded goods are SAFE
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Underwriters Laboratories
Working for a Safer World Since 1894
Underwriters Laboratoriesbegan in the 19th century andenters the 21st century withthe same purpose…
to help make the world saferin the places where peoplelive and work
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Underwriters Laboratories
Working for a Safer World Since 1894
20,000,000,000 UL Marks on products annually
1,500,000,000 safety messages reach consumers
570,088 follow-up inspection visits
84,994 product evaluations
66,149 manufacturers of UL certified products
19,597 product types evaluated by UL
6,921 UL employees worldwide
1,420 published safety standards
120 inspection centers worldwide
102 countries with UL customers
68 lab facilities worldwide
Data as of 31st December 2009
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Underwriters Laboratories
serving a Global Market
UnderwritersLaboratories
North America• United States - Northbrook - Camas - Melville - Research TP - Santa Clara• Canada
Latin America• Argentina• Brazil• Mexico
Europe• Germany• Finland• France• Denmark• Italy• Netherlands• Poland• Spain• Sweden• Switzerland• United Kingdom
Asia Pacific• China• Taiwan• Hong Kong• India• Japan• South Korea• Singapore• Malaysia• Thailand• Australia• New Zealand
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Underwriters Laboratories
UL-CCIC Company Ltd ::
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UL-CCIC Beijing BranchChina Market Access Agency Services (CCC, etc)
UL-CCIC Chongqing branchQRS
UL-CCIC Suzhou Laboratory
UL-CCIC Guangzhou Laboratory
UL-CCIC ShanghaiChina Headquarters and Shanghai Branch
Hong Kong
Taiwan
Hong Kong
Taiwan
UL Guangzhou Rep. OfficeFUS and Label services
UL Nanjing Office
1,500 staff celebrating 30th anniversary 1,500 staff celebrating 30th anniversary of cooperation with CCIC* in Oct. 2010of cooperation with CCIC* in Oct. 2010
* CCIC :: China Certification & Inspection Group ::
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ensuring internationally traded goods are SAFE
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everyone wants Safe Products…
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everyone wants a Safety System that delivers…
…and evolves to improve detected weaknesses and overcome new challenges
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basic elements of a Safety System simplified for Electric & Electronic products
legal framework
standards
pre-market testing & certification• components pre-qualification• end-product verification• re-evaluation of modified products or components
post-market factory surveillance• factory pre-qualification• ongoing product inspection at factory
post-market trade surveillance• ‘blind-shopping’ & verification• customs control & anti-counterfeiting• regulatory cooperation
technical competence ( of the parties involved )
Europe China Unites States
mandatory mandatory mandatory
consensus based consensus based consensus based
SDoC ::
mostly self-declared by manufacturers
independent 3rd party bodies
(appointed by CNCA)
independent 3rd party bodies
(NRTLs accredited by OSHA)
???
not required to manufacturers in SDoC
independent 3rd party bodies
independent 3rd party bodies
governmentalbodies
governmental bodies
governmental bodies
???
not required tomanufacturers in SDoC
accreditation & qualification
accreditation & qualification
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Europe (and the world) has evolved…
…from: …to:
• single market of 12 countries • EEA market of 30 countries
• no European identifiers • three European symbols:▪ ▪ € ▪ ▪
• creation of a larger EU market» internal trade • competing on a globalized market
» global trade
• in-house design & production» localized production • outsourced world
» global design & supply-chains
• product diversification • product specialization
• manufacturing • design, brands & distribution
• conformity assessment,perceived as a “trade barrier” • conformity assessment,
perceived as a “fair trade catalyst”
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...the European Safety System needs to catch-up...
EU safety
E&E industry risks
(1) 2007 Rapex Report
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an highly simplified European Product Safety system does not workin an increasingly complex Global Electric & Electronic industry
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…and Consumers clearly know it
Just under half of Europeans think that(1):
•some non-food products are unsafe (48%)
while similar percentages either think that:
•all products are safe (17%)or•a significant number of products are unsafe (18%)
The absolute majority (75%)of European citizens haveheard in the last 12 monthsof non-food products being recalled from the market
(1) EC Special Eurobarometer 298 | Oct.02008
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ensuring internationally traded goods are SAFE
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simplified product supply chain
█ “traditional” player; █ “new” player; █ “new” role
complexity of the products’ Supply Chain
the High-Tech products’ supply chain is becoming more & more complex ::•new “power” players(EMS, ODM, eRetailers)•highly decentralized(design, procurement, manufacturing)•low cost & economies of scaledriving efficiencies•shorten product life-cycleincreasing the pace of innovation
source :: Wall Street Journal, 18 May 2009, Clarity Is Missing Link in Supply Chain
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what manufacturers are saying…
regulatory, environmental and industry requirements are more stringent and grew in both complexity and quantity
companies struggle to keep up with the complex and changing compliance environment in particular to understand applicable regulations and managing multiple sources of specifications, standards and product data.
as a result the burden to manage product compliance in particular increase in development cost and lack of focus on innovation.
* source :: Aberdeen Group – the Product Compliance Benchmark Report[ % of responses view factor as major challenge ]
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a reliable 3rd party conformity assessment body, like Underwriters Laboratories, prevents unsafe products to reach the places where people live and work
what are we seeing…
Underwriters Laboratories researched the failure rates for first time product submittals and found these failure rates vary by product type from 14% to 45%, averaging 28%(1)
during our regular factory inspections, UL evaluates the products being manufacturedto check compliance with specification originally tested & certified, on average10% of the inspections detect non-compliant products(1)
it is easy to imagine honest reasons why products fail to comply with technical requirements, particularly when one deals with complex products and supply-chains ::
• failure or inappropriate specs of components and subassemblies• legitimate misunderstanding of requirements in standards & regulations• lack of technical means or safety engineering knowledge to test and
evaluate compliance of components, sub-assemblies and end-products• manufacturers & suppliers do not know how to bring products into compliance
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(1) 2007 UL data
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globalization of tradeunder complex supply chains
the risk of unsafe products escalates !!!and the costs of (non) compliance can increase considerably ::
• manufacturers need to invest in “safety engineering knowledge” and “testing capability” to evaluate their products and the ones of their suppliers & subcontractors
• larger companies often develop functions to manage “design”, “compliance”, “suppliers & distributors control” and “procurement”, to deal with their extended and complex design, production, subcontracting & distributing networks
• smaller companies often don’t have such means, knowledge or technical capabilities, and rely on other (smaller) companies, that relied on others, that relied on others… creating an “ad-hoc trust-me compliance system”
• in either case everyone in the product supply-chain carries the crippling costs of “cascading liabilities”
• reputable firms are more likely do the right thing and incur the costs of honest action, putting them at a competitive disadvantage to those who would cheat the system, effectively imposing an “honesty penalty”
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ensuring internationally traded goods are SAFE
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illegal trade ::unfortunately it happens
Legitimate Cord Wire ► SAFE
Counterfeited Cord Wire ► UNSAFE ! 39% encountered Counterfeit incidents ::
•Original Components Manufacturers•Circuit Board Assemblers•Distributors•Prime/Sub Contractors
(1) US DoC OTE, Counterfeit Electronics Survey, 2009 Nov., 387 organizations, figs: VII-1, VII-8
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UL’s product safety ::anti-counterfeiting program
enforcement
partnershipeducation
3rd party assessment• testing & certification• component traceability• factory surveillance
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3rd party assessment ::UL product safety process
Recognized Components◄ certification mark
ongoing productinspection at factoryFUS
simplified version of the process
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a UL Listing Marking appearing on a product consists of four required elements ::
•UL in a circle Mark•Word "Listed"•Product name or company name/file number•Issue/serial number or alphanumeric control number
certain Product categories requireholographic UL Marks…
…that can be purchased on authorized labelcenters only and have unique control features
UL mark ::control elements
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UL's anti-counterfeiting program ::enforcement • education • partnership
enforcement UL's enforcement strategy relies heavily on the involvement and support of the law enforcement agencies that can seize products, lay criminal charges and ultimately prosecute counterfeiters. The foundation of our partnerships with law enforcement agencies is UL's zero tolerance policy for counterfeiters.
education UL training program includes ::•product authentication training for various law enforcement and/or jurisdictional authority personnel. Sessions include training on the four-element UL Mark and holographic labels.•for a broader audience and focuses on the potential hazards of products bearing counterfeit UL Marks and the costs of counterfeiting to society as a whole.•assistance to UL clients that may be experiencing problems or need help building internal anti-counterfeiting programs.
partnership The final and perhaps most important pillar of UL's anti-counterfeiting strategy rests upon the strong partnerships we have developed with police and customs agencies, governmental bodies, industry organizations, jurisdictional authorities, other intellectual property rights holders, and UL clients.The core of UL's anti-counterfeiting program is based upon the network of partners that we have developed over almost 15 years of combating counterfeiting.
US Department of Homeland Security• U.S. Customs and Border Protection• U.S. Immigration and Customs Enforcement
US Department of Justice• Federal Bureau of investigation
INTERPOL• International Criminal Police Organization• Intellectual Property Crime Action Group
Royal Canadian Mounted Police • Canadian Anti-Counterfeiting Network
CAEFI - QBPC• Quality Brands Protection Committee
NEMA (National Electrical Manufacturers Association) • US Chamber of Commerce CACP • International AntiCounterfeiting Coalition • …and many other partners…
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ensuring internationally traded goods are SAFE
summarysummary
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an “ideal” Safety System model
Consensus Standards
3rd party Pre-marketAssessment & Certification•components pre-qualification•end-product verification•re-evaluation of modifiedproducts or components
3rd party Factory Surveillance•factory pre-qualification•ongoing product inspection at factory
3rd party Post-market Surveillance•‘blind-shopping’ & verification•anti-counterfeiting•regulatory cooperation
Accreditation & Qualified staff
Third-party Certificationis a proactive system working to preventinjury and property loss. It is analogous
to preventative medicine.
SDoC - Suppliers Declarationis analogous to ignoring the treatment
of a disease and then havinginvasive surgery to cure it.
trade requires a Safety System that delivers ::compliance • coherence • confidence
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operating on a increasinglycomplex supply chain requires a preventative system for public safety
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2010 InternationalLaw Enforcement IP Crime Conference
The 2010 International Law Enforcement Intellectual Property (IP) Crime Conference co-hosted by INTERPOL and Hong Kong Customs in partnership with Underwriters Laboratories will be held in Hong Kong, China from 19-21 October 2010.
The fourth annual International Law Enforcement IP Crime Conference, and the first to be held in SE Asia, will build on the success of the past three conferences.
The focus of the 2010 IP Crime Conference is "Working Together to Break Organized Crime.“
Underwriters Laboratories is a very proud partner and we are therefore delighted to continue to support INTERPOL and this year's co-host Hong Kong Customs as we work together to present the 2010 IP Crime Conference
http://www.ul.com/global/eng/pages/offerings/services/programs/anticounterfeitingoperations/conference/
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Carlos [email protected] | +81 90 2230 1306www.UL.com