Compliance Reviews

What are they and do you need to do them?

I’ve spent the last 15 years in this handmade & product safety space, but I’ve always focused on what the laws are and how to just get. them. done., right?

But in the last year or so I’ve been thinking more and more on what other things help a business stay in compliance and have reduced risks. So I’d like to speak more on that kind of thing less ad hoc and more purposefully.

Compliance Reviews

You can think of this like audits or annual performance reviews for your business. Something that you should be doing regularly to make sure everything is still going according to plan.

It’s not required, but, done right, it absolutely can help you keep risks low and stay in front of your consumers in a way that builds their trust and loyalty with you.

The depth of a compliance review is up to you as there isn’t really a set way to do them. Honestly, it depends on your priorities and needs, much like keeping up with your Key Performance Indicators (KPIs) for your emails and socials. You aren’t necessarily tracking every little detail all the time, instead only a few that will help you best see what direction you are heading and where you need to shift to maintain the direction you want. And you might check on different KPIs for different reasons.

Perhaps during the year, you are focused on the number of subscribers and the click through rate (CTR), but during this holiday season, you are more focused on the CTR and the conversions from those clicks. Maybe your focused on email during the year, but socials during holidays.

The information you track can change with your needs, and that is why the Compliance Review can be a little tricky to start. You don’t even know what you want to track, why to track it, or what to do with the information you do track!

So let’s take a look at a few things you can have your eye on.

The first thing you want to do is create a new document to house this information in. Include the basic information about your product such as:

• Business Information

  • Business Name / Brand

  • Manufacturer Identity (including location if more than one is helpful for audits)

• Product Description

  • Product Type & Name of product (ex. Clothing - Peplum Top w/ Puff Shoulder 3/4 sleeve)

  • Identifiers (Model, SKU, Batch, etc.) - include any variants if applicable

  • Picture of Product & any applicable product packaging (not shipping materials)

• Product Details (such as components and materials/fibers)

• Manufacturing Details

  • Choosing product

  • Choosing components & materials

  • Choosing suppliers

  • Frequency of testing or obtaining supplier statements (if applicable)

• Testing & Compliance information

  • Specific sample and sample components (as listed on the test report)

  • Specific tests conducted

  • Date & location of testing

  • Results & concerns from testing

  • Any supplier statements or reports? If yes, who is the supplier, what components/products are you obtaining, what compliance needs are they attesting to, when was the last testing, what testing was conducted, what were the samples tested, etc.?

  • Other regulations followed (such as things not required to have testing)

  • Include links (or other way to connect) to the original reports, statements, and certificate (such as the children’s product certificate)

• Risk Assessment

  • Who is the consumer?

  • How does the consumer *actually* use the product? Be explicit, give clear examples/scenarios.

  • How could the consumer mis-use the product? Be explicit, give clear examples/scenarios.

  • Could the consumer improperly care for the product and if yes, how? Be explicit, give clear examples/scenarios.

  • Is the buyer different from the consumer? If yes, is there a potential for the buyer to give to an unintended consumer? If yes, ask how/why/who.

  • Look to socials, is your buyer/consumer sharing the product? If yes, are they using it/describing it properly? Do you need to add comments such as ‘Aww, so cute! Thanks so much for sharing! As a reminder…’?

  • Does your marketing need adjustments to accomodate for incorrect buying behavior? (buyer purchasing for unintended consumer)

  • Does your marketing or packaging materials need adjustments to accomodate for better proper use and care behavior?

  • Does your marketing or packaging materials need adjustments to encourage a way for you to track? (such as using a hashtag on socials when sharing their purchases or encouraging buyers to subscribe to your email list)

  • Is there potential for components to become an issue? (ex. snaps cracking, fabric quickly becoming threadbare/thinner and loosening a snap, etc.)

• Probability & Severity of Risk

  • For any potential risks, how likely are they to occur?

  • For any potential risks, what kind of risks are they? (suffocation, choking, impact, laceration, chemical, microbial, etc.)

  • For any potential risks, can you adjust the product, marketing, and/or packaging materials to reduce or eliminate these risks? If yes, detail these changes.

  • Should voluntary third-party testing be conducted to assess the identified potential risks? (ex. Testing for small parts on a button-up shirt)

  • Have any issues already occurred? If yes, provide details of each issue that has occurred since your last review. (Also, if yes, make certain you are already reporting these to the CPSC as soon as you are made aware of these issues)

  • Have there been any defects, that is, not related to consumer misuse?

• Proposed Adjustments

  • Detail any and all adjustments you’ve thought of during this assessment.

  • Creating a table of these adjustments so that you can track what has been completed can be helpful.

Another thing you can do to help really fill out this Compliance Review is to have a peer and/or consumer provide some insight. You do not necessarily need to give them your document to fill out, this may be a simple feedback form for quality and/or satisfaction of the marketing/listing descriptions, packaging, and products. Sometimes we are too close to our products, so it’s hard to see the whole picture.

Try to consider the whole product and usage. Start with opening the package, pulling it out, each step to using it, caring for it, storage, etc. One example I saw from the UK guidance was that of a folding chair in terms of scenarios then breaking down the scenario into steps like unfolding the chair, gripping the seat at back corner while unfolding, etc.

I’m not going to sugar coat it. This Compliance Review is not easy to do, but the more you do it, the easier it will get. The more you interact with your buyers and consumers, the more scenarios you will begin to see and think about, even when you aren’t doing a review.

If you need something to help you get started with this audit (I know I did!), this Product Audit & Risk Assessment template will remove that ‘blank screen stare’ so you can jump right into your first Compliance Review.