Shortly before Christmas, ECOHouse was contacted by one of our customers, who had received invoices for product certificates from one of their suppliers. The product certificates were issued by a large, international test laboratory and were supposed to be renewed every year.

We allowed ourselves to raise three big, luminous question marks and dug ourselves into the case that turned out to be about a 400% home-knitted do-it-yourselves-certficate.

The case is this:

One company, as an example, manufactures coffee cups in ceramics. They have their ceramics and glazes tested at a test laboratory and may then, in good conscience, issue a so-called conformity assessment for products made from the tested materials. That is to say: one should not have tested every product one manufactures from the same material and under reasonably comparable conditions for roughly the same end use. On the other hand, the manufacturer (and thus not the test laboratory) can issue a so-called declaration of conformity, which is a statutory document for, in this example, coffee cups and water bottles and all CE-marked products. The declaration of conformity must be forwarded to customers as proof that the product complies with relevant EU legislation and that this can be documented if necessary. The legislation, on the other hand, does not know the concept of certificate.

This means, in other words, that the test laboratory is only in the picture when the company decides to use new materials, or it has been a long time since they have last tested their materials. There are no actual legal requirements for how often to test the same materials, but it goes without saying that some materials should be tested more often than others. For example, plastic is constantly evolving, while ceramics to some extent remains ceramics.

In any case: The legislation has described the system as follows: The manufacturer decides which tests to perform. The test laboratories test and deliver the test report to the manufacturer. The manufacturer issues a declaration of conformity, which is sent to the customers, while the test reports together with other documentation are archived so that the manufacturer can find them out if an authority should wish to see them. And this is done, of course, not for each individual production, but once for a longer period of time, as long as the products are the same in terms of material.

But the test labs have come up with something new: Because many small manufacturers do not know much about legislation and testing, it is the test labs that really decide how the product is tested. And if the manufacturer thinks it’s too much money, the answer is always that all the tests the test labs have chosen are mandatory.

The test laboratories then do not send the test reports to the manufacturer, but instead a home-knitted certificate, which states that this particular product (and thus not all the others that are materially similar) has been tested and has passed a number of tests described in some standards. It has then been decided to give this certificate a validity for one year, and it must therefore be renewed every year – not because the product is tested again, but because the certificate states that it has a validity of one year. And every single production must even have its own certificate.

Let’s just make it clear: Say no thanks to certificates – these are documents that do not exist in law at all. Ask for the test report for the test you paid for. Issue a declaration of conformity and repeat the test when you think there is a reason for it.