Foreword

Since the European Union’s RoHS / WEEE directive restricted the use of hazardous substances, excessive amounts of heavy metals have been found in products including toys, electronic products, clothing and footwear and other products around the world, resulting in removal from shelves, recalls and fines against companies that break the rules. The introduction of the U.S. CPSIA/HR4040 has put forward higher requirements for quality control of export-oriented companies. Companies are facing a more severe test. How to properly handle companies’ internal quality control has become a critical issue. A series of problems such as cost increase, sharp increase in risk and decline in production efficiency have been plaguing corporate managers. How can companies meet this challenge?

Background of the Act

In 2007, a spate of safety and quality issues concerning toys exported from China triggered a debate among foreign governments, media and consumers over the safety and quality of Chinese products. Especially some U.S. congressmen continuously criticized the quality of Chinese products in public, turned public opinion against China and demanded amendment of the Consumer Product Safety Act. In July 2008, the U.S. Congress, the Senate and the House of Representatives overwhelmingly passed the CPSIA/HR4040 Consumer Product Safety Improvement Act respectively.

On August 14, U.S. President Bush officially signed the Consumer Product Safety Improvement Act CPSIA/HR4040 into law. The Act is the most stringent consumer protection act since the Consumer Product Safety Commission (CPSC) was founded in 1972 and its regulatory scope covers almost all consumer goods.

What will the punishment be for violating CPSIA/HR4040? First, If a company commits any of the following acts, its products will be recalled or banned on the U.S. market: 1. banned hazardous substances in products exceed the limit; 2. proof of compliance of products with mandatory requirements in the Act and other acts cannot be provided; 3. false statements about products and self-justification. Second, penalties: 1.raise the cap on civil penalties for noncompliance to 15 million U.S. dollars; 2; amend the criminal penalty provision to impose a jail term of up to five years on heads of companies that commit a serious offense; 3. add the penalty of confiscation of assets for deliberately breaking the law.

Companies’ Response

Since companies exporting to the United States are currently facing such a big risk, how quality control should be handled within companies?

I. Not take any measures, deem suppliers’ materials as conforming to the requirements simply by dint of their inspection reports, directly put raw materials into production and respond passively (highest risk, almost no testing cost)

II. Require suppliers to provide test reports every time they supply materials. The company also submits samples to an authoritative laboratory for testing and waits for the results, which affects the production and delivery efficiency (high risk, high testing cost, low efficiency)

III. Require suppliers to provide test reports whenever they supply materials. The company submits samples to a laboratory for testing. Meanwhile, establish and improve a large laboratory within the company (low risk, highest input costs, average efficiency)

IV. Require suppliers to provide test reports when they supply materials. The company submits samples to a laboratory for testing, purchase a XRF detector to classify products by means of sifting and make a further submission to the laboratory (lowest risk, low input costs, high efficiency).

Solution, XRF

XRF (X-ray Fluorescence) spectroscopy.  A typical X-ray fluorescence (XRF) instrument is composed of an excitation source (X-ray tube) and a detection system. The X-ray tube generates incident X-rays (primary X-rays) to excite the sample. Every element in the excited sample will emit secondary X-rays, and secondary X-rays emitted by different elements have specific energy characteristics or wavelength characteristics. The detection system measures the energy and number of these secondary X-rays emitted. Instrument software converts information collected into the type and content of various elements in the sample.

With quick and easy operation, stable and reliable detection accuracy and fast and efficient non-destructive analysis, XRF spectrometers have been favored by many companies. Take shoe samples for example, because the CPSC does not accept hybrid testing methods, a shoe sample needs to be broken down into quite a few parts, including outsole, leathering, cloth, eyelet, lace, plastic and trademark, and the number of samples is calculated according to different colors. Consequently, the cost of inspection increases sharply. XRF spectrometers can find out the content of regulated elements in 30 to 90 seconds, allowing companies to judge a product quickly to make corresponding adjustments to production solutions. The efficiency improvement is self-evident

The biggest priority in quality control is to establish a companywide quality management system (from suppliers to customers). According to statistics, more than 90% of the problems of restricted substances exceeding the limits arise from materials supplied by suppliers, so the control of the quality of materials supplied by suppliers is extremely important. It is no doubt very risky for companies to start production simply by dint of providing sample test reports for materials supplied by suppliers. If raw materials delivered by suppliers are resubmitted for testing, the time spent on waiting for the results will significantly reduce production efficiency, seriously affecting the delivery and directly harming the company’s reputation. XRF spectrometers can be used as a testing tool for quality management systems to quickly sift through materials supplied by suppliers, preventing problems from arising at the first stage of production; in the production process, use XRF to test the production line on a regular basis to prevent man-made adulteration or using nonconforming auxiliary materials by mistake, eliminating the possibility of contamination in the production process; before end products are delivered, XRF may also be used to test suspicious locations of products to minimize risks.

Positioning of XRF by U.S. CPSC

How do the U.S. government and the CPSC position XRF? In fact, we face tens of thousands of goods at customs, at docks, in warehouses as well as on shelves every day. Since it is impossible to submit all the goods to laboratories for testing, government departments need quick test methods more than any company. The practice currently employed by customs is: quickly sift through goods by making use of the characteristics of being fast and non-destructive of XRF; after detecting signals emitted by prohibited elements, submit the goods to a laboratory for testing; after determining that prohibited elements in the goods exceed the limits, take a series of punitive measures against the law-breaking company.  The CPSC is gradually improving and establishing the feasibility of the XRF detection method. We believe that XRF detection results will receive official recognition in the United States in the near future.

As a tool for quality control within companies, XRF spectrometers can be divided into the two categories of "desktop" and "handheld". With a compact size, easy operation, portability and a design that entails almost no consumable materials, handheld XRF spectrometers are more popular with many companies.

Niton Profile

Founded in 1987, U.S. company Niton (a wholly owned subsidiary of Thermo Fisher Scientific) is a leader in hand-held X-ray fluorescence technology. Niton’s R & D projects have been receiving strong support from relevant U.S. government departments. It won the "R & D 100 "award that is the most authoritative award and has been known as the "Nobel Prize for product R & D" in the field of science and technology products in the United States in 1995, 2003 and 2008 respectively. According to the latest statistics, sales of Niton so far has exceeded 20,000 units worldwide, including about 6000 units sold on the Chinese market. The U.S. Customs and the customs and commodity inspection authorities of many EU member states now all use Niton’s products for on-site testing of products imported into their countries. Niton''s products have become the standard for detecting instruments for material analysis at industrial sites and are widely used in fields such as spaceflight and aviation, petrochemical engineering, mineral exploration, alloy analysis, environmental analysis and consumer goods manufacturing and in detection corresponding to CPSIA/HR4040, RoHS/WEEE and other acts.

Product Advantages

• The U.S. CPSC and EU member states use the instrument for consumer product safety testing.
• It is so far the only handheld XRF spectrometer in China that has obtained instrument radiation safety exemption (buyers and users need not apply for radiation safety permits) from the Chinese Ministry of Environmental Protection and can save about 20,000 yuan in costs of environmental and safety assessment for customers.
• It is so far the world’s only successfully developed handheld XRF spectrometer that uses a high efficiency 50KV X-ray tube.
• It is currently the only XRF spectrometer with a built-in CCD camera and the small point testing function.