The Osmonds’ #1 song from the ’70s suggests people should be given one more chance, and not judged simply by all the other bad “apples” out there. When it comes to judging fruits, though, apples do produce ethylene, their own gaseous ripening hormone, so it’s true that one bad apple can eventually spoil the whole bunch. And as it relates to promotional products, the selection of a single bad apple could end up spoiling one of your upcoming campaigns, as well.
We have talked here frequently about the importance of a transparent supply chain when it comes to safe and compliant promotional products. If you are sourcing and decorating brand name blank products, it is much easier to track the factory and country of origin. But what of the so-called “untraceable” imported goods in our industry? You may not have thought about it, but you buy untraceable domestic goods for yourself all the time. You buy Washington apples, or Florida oranges, but you don’t know if those apples came from farmer Dan or farmer Pete. You just know they came from somewhere in Washington. Apples from Washington, berries from Michigan, and oranges from Florida are all frequently consolidated from neighborhood farms and, because of that, unfortunately, farmer John may not worry quite as much about the quality of his fruit as his neighbor. Once they are consolidated, who’s going to know?
The same thing is true of the significant numbers of untraceable goods imported to the U.S. from China. Imports from China in some years have accounted for 60 percent of the apple juice sold in the U.S., more than 50 percent of the garlic, and 10 percent of the shrimp, according to the U.S. Department of Agriculture (USDA). “Over the last decade,” say researchers from the Stanford Graduate School of Business, “Chinese firms have exported toys, drywall, infant formula, toothpaste, cold medicines, blood thinners, pet food ingredients, and other products laced with lead, antifreeze, and other poisons.” Product recalls by the U.S. Consumer Product Safety Commission have been as high as 10 percent of China’s monthly toy exports to the U.S., a fact that could affect the promotional products industry. According to the Stanford researchers, “China accounts for a disproportionately large share of imports refused entry to the United States” by the FDA. In 2007, China accounted for 5.8 percent of all U.S. agricultural imports, but 8.6 percent of FDA refusals.
The traditional thinking is that consolidating suppliers is the best way to encourage producers of unbranded goods to improve quality. But the Stanford research dismisses that idea, arguing that having fewer producers would lead to higher prices for consumers. The better option, researchers say, is government intervention, in the form of strong domestic regulations. China does have an FDA-equivalent, but recent history suggests that may not be the best solution. In 2007, the Chinese government actually executed the former head of the State Food and Drug Administration after authorities determined he’d taken bribes in exchange for approving products that had not been tested at all. A risky job, to say the least.
The challenge for product safety in the promotional products industry is one of constant change – new regulations and policies pop up literally daily. According to Joe Cade, vice president and legal counsel for BIC Graphic, and chairman of the QCA Compliance Committee, the number of suppliers with comprehensive compliance programs is relatively small. “We see a core group of 25 to 35 suppliers in our industry who are working very hard to develop and continuously improve their compliance programs. We hope that trend will continue. We have been seeing many states enact their own product safety laws and many more are under consideration. We see this continuing to grow over the next five to 10 years. This poses a challenge because there is very little consistency to follow.”
As a distributor interested in responsible sourcing, Cade offers the following advice, “I would try to develop a general understanding of the product safety laws that apply to the products I buy. There are some excellent resources in the industry that are free for the taking. The testing labs have some very good newsletters that track important developments in the product safety sector. Most importantly, though, I would work with suppliers that have strong compliance programs and who are experienced with addressing the requirements of major companies.”
How about you? Have you found a “bad apple” in the middle of one of your programs? You may want to dig all the way to the bottom of the barrel to make sure that each of the items traces back to a responsible supplier.
Jeff Jacobs has been an expert in building brands and brand stewardship for more than 35 years, working in commercial television, Hollywood film and home video, publishing, and promotional brand merchandise. He’s a staunch advocate of consumer product safety and has a deep passion and belief regarding the issues surrounding compliance and corporate social responsibility. He recently retired as executive director of Quality Certification Alliance, the only non-profit dedicated to helping suppliers provide safe and compliant promotional products. Before that, he was director of brand merchandise for Michelin. As a recovering end-user client, he can’t help but continue to consult Fortune 500 consumer brands on promo product safety when asked. You can also find him working as a volunteer Guardian ad Litem, traveling the world with his lovely wife, or enjoying a cigar at his favorite local cigar shop. Follow Jeff on Twitter, or reach out to him at jacobs.jeffreyp@gmail.com.