Compliance and quality glossary: importing without recall risk

Terms A to D

AQL

Acceptable Quality Limit: the accepted quality threshold applied during a sampling inspection, expressed as a percentage of tolerated defects by severity. It serves as the contractual basis for accepting or rejecting a batch after inspection.Read next AQL Levels Explained: 2.5, Sampling, and Worked Examples

Social audit

A check of working conditions in a factory (hours, wages, fire safety, workers' age), separate from product quality control. A social audit report serves as proof of the importer's due diligence and meets the requirements of some European retailers.Read next Factory audit in China: points to check and documents to request

Patent

A title protecting a technical invention (how it works, its mechanism) for a limited period, filed country by country. A patent filed only in France gives no protection against manufacturing and sale in China; a local filing is needed to take action there.Read next Protect your molds, designs and trademark in China

BSCI

One of the most widespread social audit programs among Chinese exporting factories, with scoring by area (labor, safety, environment). Many European retailers require a valid BSCI report before listing a supplier.Read next Factory audit in China: points to check and documents to request

Certificate

A document issued by a laboratory or body certifying that a product or system has been tested or audited against a given standard. A certificate is only valid if it matches exactly the product reference and factory named on it, which should be checked before accepting it.Read next CE Marking on Imports: What It Covers and How to Verify

Food contact

The status of materials and articles intended to come into contact with food (tableware, food packaging), governed by regulation 1935/2004. The importer must hold a declaration of conformity from the supplier and, depending on the material, migration test results.Read next Food contact materials: Regulation (EC) No 1935/2004 for importers

NNN agreement

A non-disclosure, non-use, non-circumvention agreement, designed to be enforceable in China rather than a plain Western-style confidentiality agreement. It protects a project or design shared with a factory before the order and allows legal action before a local court in case of copying.Read next Protect your molds, designs and trademark in China

Counterfeiting

The unauthorized reproduction of a protected trademark, design or patent, which customs can seize as soon as it enters the EU. An importer can be held liable even in good faith if the imported goods turn out to be counterfeit.

Loading inspection

A check carried out while the container is being loaded (carton count, reference, visual condition), the last step before the doors are closed. It prevents quantity discrepancies or last-minute substitutions against the confirmed order.Read next Pre-shipment inspection: the PSI protocol in China

EU declaration of conformity

A document that the manufacturer or importer draws up and signs to state that a product meets all applicable European directives. It must be kept on file and produced to market surveillance authorities in the event of a check.Read next CE Marking on Imports: What It Covers and How to Verify

DEEE

Waste electrical and electronic equipment, governed by directive 2012/19/EU, which requires the entity placing the product on the market to register and to contribute to end-of-life treatment. An electronics importer selling under its own name must register before the first sale.Read next Importing electronics from China: LVD, EMC, RoHS, WEEE

Critical defect

A defect that makes a product dangerous to the user or illegal to sell (injury risk, regulatory non-compliance). Its presence generally triggers automatic rejection of the batch, regardless of the AQL level applied.Read next Quality defects import from China: product families and prevention

Major defect

A defect that compromises the product's use or appearance without endangering the user (a failing function, poor finish). It counts in the AQL calculation and can tip a batch into rejection if the number found exceeds the accepted threshold.Read next Quality defects import from China: product families and prevention

Minor defect

A cosmetic or detail flaw that affects neither use nor safety (a small scratch, a slightly crooked label). It is tolerated in greater numbers than major defects in the AQL calculation.Read next Quality defects import from China: product families and prevention

Filing in China

The local registration of a trademark, design or patent directly with the Chinese administration, independent of any European filing. Without this filing, the importer has no way to take action in China against a third party using the same name or the same visual.Read next Protect your molds, designs and trademark in China

Design

Protection for a product's appearance (shape, patterns, lines), separate from a patent, which protects a technical function. Filing a design in China before production limits the risk that a factory reuses the same visual with another client.Read next Protect your molds, designs and trademark in China

DGCCRF

The French Directorate General for Competition, Consumer Affairs and Fraud Control, the authority that checks the compliance and safety of products on the market, including imported ones. It can request technical documents, take samples and order a recall.Read next GPSR Regulation 2023/988: Importer Obligations

Low Voltage Directive

Directive 2014/35/EU, which covers the electrical safety of equipment operating within a defined voltage range in alternating and direct current. Any electrical device imported within this range must comply before CE marking is affixed.Read next Importing electronics from China: LVD, EMC, RoHS, WEEE

EMC Directive

Directive 2014/30/EU on electromagnetic compatibility, which requires that an electronic device neither disrupts other equipment nor is itself disrupted by common interference. It applies alongside the Low Voltage Directive for most imported electronic products.Read next Importing electronics from China: LVD, EMC, RoHS, WEEE

Radio Equipment Directive

Directive 2014/53/EU, which covers any equipment that transmits or receives radio waves (Bluetooth, Wi-Fi, remote controls). It adds requirements related to radio spectrum use on top of electrical safety and EMC requirements.Read next Importing electronics from China: LVD, EMC, RoHS, WEEE

Terms D to M

Technical file

The full set of documents proving that a product meets the applicable directives (drawings, calculation notes, test reports, list of standards applied). The importer or its authorized representative must be able to provide it to the authorities at short notice, even if they did not draft it themselves.Read next Product technical documentation: what the importer must hold

Customs seizure

The procedure by which customs holds goods suspected of being counterfeit, on their own initiative or at the request of a rights holder registered with them. An importer can have their goods held and then destroyed at their own expense if intellectual property rights were not checked beforehand.Read next Protect your molds, designs and trademark in China

Sampling

A method of checking a reduced, representative number of units from a batch rather than the whole batch, following a standardized table linked to the AQL. The sample size depends on the batch size and the inspection level chosen.Read next AQL Levels Explained: 2.5, Sampling, and Worked Examples

Eco-contribution

A fee paid to an approved eco-organization to fund the collection and recycling of products placed on the market (packaging, textiles, electronics). It is owed by the importer as soon as the product is first placed on the French market, regardless of whether the manufacturer is based abroad.Read next REP: eco-contribution and unique identifier for importers

EN 62115

A harmonized safety standard for electric toys (batteries, motors, heating elements), complementing EN 71, which covers the toy's other aspects. An electric toy must meet both standards to benefit from the presumption of conformity.Read next Importing Toys from China: Directive 2009/48 and Standard EN 71

EN 71

A harmonized standard setting the safety requirements for toys (mechanical properties, flammability, migration of certain chemical elements), linked to directive 2009/48/EC. Compliance, verified by laboratory testing, allows the toy's conformity with the essential requirements to be presumed.Read next Importing Toys from China: Directive 2009/48 and Standard EN 71

Textile labeling

The obligation to state the fiber composition of a textile article using the names and thresholds set by regulation 1007/2011. An approximate or unverified composition exposes the importer, who is responsible for the accuracy of the information even if the factory drafted it.Read next Labelling Textiles Imported from China: Composition, Care, Origin

Manufacturer

Under the European directives, the party that designs a product or has it manufactured under its own name or brand, even if it does not produce it in its own factory. An importer who puts its own brand on a Chinese product becomes the regulatory manufacturer and inherits all the corresponding obligations.Read next CE Marking on Imports: What It Covers and How to Verify

Inspection checklist

The reference document used during inspection, listing the points to check for a given reference (dimensions, colors, functions, packaging). It must be prepared before the inspection from the specification sheet and the golden sample, otherwise the check stays superficial.Read next Quality control China: managing QC during production

Golden sample

A reference sample jointly approved by the buyer and the factory, used as the benchmark to judge the ongoing production and settle a quality dispute. Without a golden sample kept on both sides, a dispute over a batch's conformity rests only on written descriptions.Read next Golden sample: the reference sample that settles disputes

Man-day

The unit used to measure an inspection, billed per inspector per day spent at the factory. The number of man-days required depends on the batch quantity and product complexity, and it directly determines the cost of the inspection.Read next Quality control China: managing QC during production

Unique identifier

A number assigned by the eco-organization to each entity placing products on the market under extended producer responsibility, to be shown on invoices and declarations. Its absence can be penalized and, in practice, blocks access to certain online marketplaces.Read next REP: eco-contribution and unique identifier for importers

Importer

In regulatory terms, the person established in the EU who places a product from a non-EU country on the European market, with its own obligations separate from the manufacturer's (checking the marking, keeping the documentation, reporting any risk). This is the role a company that buys from China occupies by default, unless a third party formally takes it on.Read next CE Marking on Imports: What It Covers and How to Verify

Info-tri

A marking that tells the consumer how to sort packaging or a product at end of life, mandatory in addition to the eco-contribution. It must appear on the product, the packaging or the instructions before the product is placed on the French market.Read next REP: eco-contribution and unique identifier for importers

Pre-shipment inspection

A check carried out once production is finished and the batch is packed, just before pickup for transport, often called PSI. It is the last point where a widespread defect can still be detected and corrected before the goods leave the factory.Read next Pre-shipment inspection: the PSI protocol in China

During production inspection

A check carried out during manufacturing, once a significant share of the batch has already been produced, to catch a systematic defect before it repeats across the rest of the batch. It leaves time to fix a problem without delaying the shipment date.Read next Quality control China: managing QC during production

Initial production check

A check carried out at the very start of production, on raw materials and the first units off the line, to confirm the factory is starting on the right footing. It helps catch a bad batch of material or an incorrect machine setting before it affects the whole order.Read next Quality control China: managing QC during production

ISO 9001

The international quality management system standard, which certifies a factory's organization (procedures, traceability, continuous improvement) rather than a specific product. An ISO 9001-certified factory is not exempt from quality control on the order, but statistically shows fewer process deviations.Read next Factory audit in China: points to check and documents to request

Accredited laboratory

A laboratory whose competence for a given test is recognized by a national accreditation body, a guarantee of reliable results. A test report issued by a laboratory not accredited for the test in question has very limited value in the event of a check.Read next GPSR Regulation 2023/988: Importer Obligations

Authorized representative

A person established in the EU appointed in writing by a non-EU manufacturer to act on its behalf for specific regulatory tasks (keeping the documentation, being the point of contact for the authorities). An authorized representative is not automatically liable like an importer; their mandate strictly defines what it covers.Read next CE Marking on Imports: What It Covers and How to Verify

Terms M to T

CE marking

A marking affixed by the manufacturer or importer to state that a product meets all applicable European directives; it is neither a third-party certification nor a mark of European origin. Affixing it without having gathered the corresponding proof of conformity is an offense, even on a product made in China.Read next CE Marking on Imports: What It Covers and How to Verify

Trademark

A sign that identifies a company's products or services (name, logo), protected only in the territories where it is registered. A trademark registered only in France offers no protection in China, where a third party can legally register it before the importer does.Read next Protect your molds, designs and trademark in China

Mold

Production tooling, often the most expensive investment item of a launch, whose ownership must be spelled out in writing from the order onward. Without an explicit clause, the factory that made and paid for it is deemed to remain its owner, even if the buyer funded part of it through the unit price.Read next Protect your molds, designs and trademark in China

Inspection level

A parameter of the AQL table that sets the sample size drawn for a given batch, with general level II being standard practice. A higher level draws more units and gives a more reliable result, at the cost of a longer inspection time.Read next AQL Levels Explained: 2.5, Sampling, and Worked Examples

Harmonized standard

A European technical standard published in reference to a directive, compliance with which creates a presumption of conformity with that directive's essential requirements. Using an up-to-date harmonized standard simplifies proving conformity compared with building a technical case from scratch.Read next CE Marking on Imports: What It Covers and How to Verify

Notified body

A conformity assessment body designated by a Member State and authorized to act on procedures that require it (certain toys, pressure equipment, radio equipment). Its number must appear next to the CE marking when its involvement is mandatory.Read next CE Marking on Imports: What It Covers and How to Verify

Responsible person

A person established in the EU, generally the manufacturer, its authorized representative or the importer, responsible for ensuring the product remains compliant after it is placed on the market. Their name and address must appear on the product or its packaging.Read next GPSR Regulation 2023/988: Importer Obligations

Presumption of conformity

A legal effect that removes the need to prove point by point compliance with a directive's essential requirements, provided a relevant harmonized standard has been applied and documented. It only holds if the standard used matches the product exactly and is its latest version in force.Read next CE Marking on Imports: What It Covers and How to Verify

First-to-file principle

A rule applied in China under which a trademark, design or patent belongs to whoever files it first on Chinese territory, with no necessary link to prior use elsewhere. It explains why bad-faith third parties sometimes register Western trademarks before their rightful owners do.Read next Protect your molds, designs and trademark in China

Tooling ownership

The legal status of the mold or production tooling, which must be set out in a written contract with the factory specifying who owns it and who may use or move it. Without this clause, switching subcontractors later can run into the factory refusing to hand back tooling it considers its own.Read next Protect your molds, designs and trademark in China

Product recall

A measure by which the entity placing a product on the market withdraws a product already sold to consumers because of an identified risk, distinct from a simple withdrawal from the market before sale. The importer, as the entity placing the product on the market, must be able to organize a recall and report it to the relevant authorities.Read next GPSR Regulation 2023/988: Importer Obligations

Test report

A document issued by a laboratory after testing a sample using a precise method, showing the results obtained against the standard's limits. It must be requested on the actual order sample; an old report or one covering a similar product does not cover the current production.Read next CE Marking on Imports: What It Covers and How to Verify

Inspection report

A written report delivered after a quality inspection, detailing the defects found, their classification, and the accept or reject conclusion against the AQL level applied. It is the reference document in the event of a dispute with the factory over the actual state of the batch at the time of the check.Read next Quality control China: managing QC during production

REACH

Regulation 1907/2006, which governs the registration, evaluation and authorization of chemical substances, with restrictions on certain substances in consumer products (notably phthalates, heavy metals). The importer must be able to demonstrate the absence of, or compliance with the thresholds for, the most closely monitored substances, particularly in textiles, plastics and jewelry.Read next REACH and Regulated Substances: The Importer's Checks

General Product Safety Regulation

Regulation 2023/988, which sets a general safety obligation for any consumer product, even in the absence of a specific sector directive, and requires a responsible person established in the EU. It strengthens traceability and recall management obligations for importers selling online as well as in-store.Read next GPSR Regulation 2023/988: Importer Obligations

REP

Extended producer responsibility: a principle that makes the entity placing a product on the market financially responsible for the end of life of its products or packaging, through membership of an approved eco-organization. An importer selling in France without being registered in the relevant schemes risks sanctions and being blocked on certain online marketplaces.Read next REP: eco-contribution and unique identifier for importers

RoHS

Directive 2011/65/EU, which limits the presence of hazardous substances (lead, mercury, certain phthalates) in electrical and electronic equipment. An electronic product that is not RoHS-compliant cannot legally be placed on the European market, regardless of its CE compliance otherwise.Read next Importing electronics from China: LVD, EMC, RoHS, WEEE

Safety Gate

The European Commission's rapid alert system, which lists dangerous products detected and withdrawn from the market in Member States. Checking that a reference or supplier is not already listed there is a useful habit before placing an order for a sensitive product.Read next GPSR Regulation 2023/988: Importer Obligations

Sedex

A platform for sharing social audit reports between factories and buyers, an alternative or complement to BSCI depending on the target markets. A factory already audited on Sedex avoids redoing a full audit for every new client that asks for one.Read next Factory audit in China: points to check and documents to request

Triman

A mandatory logo indicating that a product or its packaging is subject to a sorting instruction, to be affixed alongside the info-tri on products sold in France. Its absence on a product subject to EPR is a non-conformity independent of the eco-contribution itself.Read next REP: eco-contribution and unique identifier for importers

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