Has your attitude changed about sourcing from China?
August 22, 2007
The Talk, Page 2...
Survey Results for 08/22/2007:
Has your attitude changed about sourcing from China?
Yes; we'll be more cautious.
No, but we've avoided these imports.
No, but we take extra QC steps already.
Last week, noting the recent hubbub related to recalls and lead-tainted toys, we asked whether it would change window and door industry attitudes about sourcing from China. About 40 percent of respondents said yes, they would be more cautious as a result.
But, the majority of respondents said no. Well, we gave them two reasons to say no, and more than a third said their attitudes hadn’t changed because they’ve avoided sourcing from China altogether. The remaining 20 percent, evidently those from companies that work with Chinese suppliers, indicated no, their attitude hadn’t changed, but they already implemented stepped up quality control efforts to avoid the troubles now facing toy sellers like Mattel.
It would seem that the window and door industry is a fairly cautious group when it comes to such issues. Rich Walker, president and CEO of the American Architectural Manufacturers Association emailed me to point out that—given all the ink on the lack of testing or enforcement for imported toys—it’s worth noting the fact that our industry tackled the lead issue in 2000, when AAMA's Profile Certification Program first instituted plant inspections for lead.
It also stepped up to the plate when it became evident that more imported profiles might be coming to the market. AAMA worked hard to adapt its program to enable international suppliers to enter the U.S. marketplace and compete fairly, while preventing a potential influx of PVC profiles with added lead.
Because AAMA has been proactive on the lead issue, the recent problems with Chinese toys may not create much of a stir within the window and door business, Walker suggests. “Our attitude would not change significantly, as we have honed and strengthened the lead checks and non-compliance penalties in our Profile Certification Program that have been in place for the last seven years,” he reports. “AAMA members, licensees and staff are constantly on guard for lead being added to window and door products in the U.S.”
Walker goes on to note that members of the AAMA certification policy committee spent considerable time in 2004 and 2005 debating, and then incorporating, lead provisions that addressed the complications posed by overseas licensees into its Profile Certification Program. Members were concerned about the risk associated with the prevalent use of, and lack of internal regulations for, lead content in other countries. However, AAMA also knew any provisions it created to address these concerns could not discriminate against country of origin, in accordance with Federal Trade Commission guidelines.
Unannounced plant inspections—designed to assure that the products being manufactured are the same as those tested for compliance—are a key element in a meaningful certification program. “Overseas inspections were a major concern to AAMA,” Walker writes. “The first challenge was to address the concerns over the inspector arriving at a plant in China truly ‘unannounced.’ We evaluated several options, including additional domestic inspections, port of entry inspections, and enlisting China-based inspectors. We worked closely with the U.S representatives of several Chinese licensees to develop a procedure to ensure anonymity when entering the country. With several Chinese plant inspections under our belt, our inspectors report that their identity and itinerary were not disclosed to the plant personnel prior to their arrival.”
The AAMA Profile Certification Program provisions related to lead are that no lead can be added in the manufacturing process and that profiles can have a maximum of 0.02 percent lead content by weight, which exceeds U.S. requirements. Seeing an increased risk of lead in overseas profiles, AAMA added provisions increasing the fine for a second lead content failure. The maximum amount of the fine—which would apply to both domestic and international participants—was raised to $250,000.
Currently, 66 vinyl profile producing plant locations are licensed by AAMA. Fourteen are outside the U.S. and Canada, including one in Korea, two in Germany and 11 in China. “Based on the volume of inquiries and licensee applications from overseas, it seems that overseas companies are very receptive and consider AAMA certification as a requirement for successful entry into the U.S. marketplace,” Walker states.
But are others out there selling products here that may not meet such standards, and perhaps give our industry a black eye like the toy industry has at the moment? “The AAMA product and profile certification programs are voluntary,” Walker responds. “It is impossible to mandate certification of all imported fenestration products and profiles. Some overseas producers may not be familiar with the AAMA program, others forego participation in the program based on economic reasons and some have already determined that their products will not meet the requirements. For overseas manufacturers focused on the lowest product cost, formulations with lead based stabilizers are a significant raw material savings and converting to stabilizers without lead involves considerable time and retooling.”
For companies that are more cautious in looking at Chinese suppliers in the wake of the toy recall, Walker would obviously recommend choosing only those that are certified through the AAMA program when it comes to profiles. But does he have recommendations when it comes to looking at suppliers for other components?
Walker points first to the verified components list, which can be viewed on the AAMA Web site. This program is designed to provide window and door manufacturers with confirmation that certain types of coatings, weatherseals, sealants and hardware meet various performance parameters. “While verification is not as rigorous as certification,” Walker states, “it does provide a measure of assurance of performance for the consumers of these fenestration components.”
And he offers these general words of caution in conclusion. “In the final analysis, it is critical to ensure that the product quality after the first few shipments is not compromised. While many components imported from overseas are of excellent quality, there are a multitude of cases where the product was ‘cheapened’ and resulting quality unacceptable,” Walker writes. “One suggestion is to spell out performance and quality requirements for the length of the contract. The enforceability of contract terms is a separate issue. It is also important to have a second supplier qualified and ready to step in if the primary supplier falters.”