A technician reworking electronic goods

How Product Reworks Save Money

How Product Reworks Save Money


When a product is recalled or pulled from sale due to a defect, it’s all too easy to look at the item’s face value and arrive at the conclusion that scrapping it will be cheaper than fixing it.

But in a lot of cases, that’s just plain wrong. When you consider the full, big-picture costs involved in scrapping products, you might change your mind.

A technician reworking electronic goods

What costs can be saved by a product rework?

The entire, end-to-end cost of scrapping a product includes everything from the cost of mineral extraction all the way through to environmentally safe scrapping, with every process along the way consuming labour, resources and energy.

Materials: First, there’s the material cost. When defective products are repaired, the product’s life is extended and maximum value can be gained from the raw materials that it’s composed of. By eliminating the need for making a replacement item, material costs are saved.

Energy: Every new product that is manufactured requires energy across the entire process, from assembly through packaging to transportation. All of those costs are saved when reworking takes place.

Labour: In the vast majority of cases, a product rework involves substantially less labour than that required to make a whole new item. This is especially true when defects are minor and can be fixed quickly.

Disposal: Waste management costs are also saved by reworking. Handling, transport and disposal all add to the cost of scrapping a product.

Take the example of a defective electrical product like a blender or a vacuum cleaner. If a faulty component can be replaced during a rework, not only are all the costs of making a new item saved (materials, energy and labour), but the escalating cost of e-waste disposal as well.

The indirect benefits of reworking

Sustainability is a watchword for all companies as environmental concerns and regulatory demands increase. More and more, brands are scrutinised by customers for their attitude towards sustainability.

When products are reworked, no new resources are needed for manufacturing which decreases the environmental footprint of the product. Manufacturing waste and waste management in general is also reduced, decreasing the greenhousing effect and wider environmental impacts of garbage disposal.

In summary, reworking is more often than not vastly more beneficial to a company than disposal, reducing an array of different costs associated with the product lifecycle, whilst improving a company’s environmental stewardship profile.

BWES has maintained a specific business unit for 10 years dedicated to the 3 key tasks of rework, refurbishment, and sustainable scrapping. If you would like advice on reworking and product recalls, please contact us.


This communication (including any attachment) has been prepared by BWES and is based on the available information at the time of publication and is believed to be true and accurate. The information contained in this communication should be used as a guide only and may cease to apply if applicable regulation or the product’s design or application is altered. BWES does not take responsibility for any Injury, Loss for damage suffered by any party’s interpretation or decisions made by any party on the information provided in this communication.


A person holds a walkie talkie inside a blurred room

ACMA Warn of Cheap Walkie Talkie Non-Compliance

ACMA Warn of Cheap Walkie Talkie Non-Compliance

ACMA, the Australian Communications and Media Authority are warning importers, retailers and consumers to beware of cheap 2-way radios from overseas.

This commonly used and popular product is easily bought online, but a recent spate of problems has triggered this warning from the authority.

A person holds a walkie talkie inside a blurred room

Reserved frequency breaches

The issue stems from the pre-programmed frequencies that the radios are supplied with. Users in Australia are not allowed to operate on certain frequencies which are permanently reserved for emergency and other critical services.

Before an Australian supplier can sell a walkie talkie, the device must meet:

  • technical performance standards
  • labelling and record keeping requirements in the Radiocommunications Equipment (General) Rules 2021 and Radiocommunications (Electromagnetic Compatibility) Standard 2017).

Compliant devices should be labelled with the Regulatory Compliance Mark (RCM).

ACMA states that the penalties for using or supplying a non-compliant 2-way radio device are serious. You could receive fines of over $400,000 and possibly up to 2 years in prison.

If you are in any doubt about the compliance with Australian standards of any device you may be importing or manufacturing, please seek expert advice.


This communication (including any attachment) has been prepared by BWES and is based on the available information at the time of publication and is believed to be true and accurate. The information contained in this communication should be used as a guide only and may cease to apply if applicable regulation or the product’s design or application is altered. BWES does not take responsibility for any Injury, Loss for damage suffered by any party’s interpretation or decisions made by any party on the information provided in this communication.


Air Freshener Products

New Fragrance Chemical Added to the AICIS Inventory

New Fragrance Chemical Added to the AICIS Inventory With Defined Scope of Assessment


The Australian government recently added a new chemical to the AICIS inventory. The chemical is 2H-Pyran, 3-heptyltetrahydro- (CAS number 854737-09-0).

Used primarily as a fragrance component in air fresheners, as well as fine fragrances and other cosmetic and household products, the chemical was added on 2 January 2024 following the issue of a new assessment certificate.

This means that from 2 January, the chemical and any finished products for sale which contain it must now be declared and registered on the AICIS inventory and comply with certain % limits.

The Australian government Department of Health regularly assesses and adds chemicals to the inventory in order to manage the risk to human health and the environment from chemicals of all kinds. Inventory listings are also frequently reclassified based on new information.

The AICIS inventory is available online. If you need any assistance regarding AICIS registration and product declarations please contact us.

Air Freshener Products

This communication (including any attachment) has been prepared by BWES and is based on the available information at the time of publication and is believed to be true and accurate. The information contained in this communication should be used as a guide only and may cease to apply if applicable regulation or the product’s design or application is altered. BWES does not take responsibility for any Injury, Loss for damage suffered by any party’s interpretation or decisions made by any party on the information provided in this communication.


A group of banned products in shipping cartons

Australia Product Bans

Australia Product Bans

What will lead to a product being completely banned from sale by ACCC?

A group of banned products in shipping cartons

One of the leading priorities of the Australian Competition and Consumer Commission (ACCC) is to protect the Australian public from dangerous products. If there’s any risk that a product might cause injury, illness or death, it’s likely that the product will be banned.

In some cases, a ban can be overcome. If a product is re-engineered to address any safety issues, then following re-approval, and with the correct compliance certification, it could be made available for sale.

Liability

Importantly, the liability for banned product breaches lies with the supplier. This could mean the importer, distributor or retailer, or all of the above. The penalties for breaches are substantial. Not only will the supplier be required to stop supplying the product, but the goods will also have to be removed from all retail outlets and retrieved from consumers and the entire supply chain. Depending on the seriousness of the breach, fines of up to $50,000,000 can be levied to the offending company.

HOW TO AVOID ACCIDENTAL BREACHES

Anyone supplying products to Australian customers can avoid making inadvertent breaches by following a few straightforward steps:

  • Implement a product compliance system: this will mean your company can be certain that its products meet mandatory Australian standards.
  • If you’re an online retailer, block non-compliant products from being shipped to Australian customers.
  • Subscribe to Product Safety Australia’s email alerts to stay ahead of the latest developments.

If you have any doubts about the compliance status of any of your current product portfolio, the quickest and most certain way to avoid any issues may be to seek expert advice.

Some products that are currently banned in Australia include:

  • Candles with lead wicks (can lead to lead poisoning)
  • Children’s items containing DEHP (toxicity)
  • Small, high powered magnets (risk of internal injury)
  • Toothpaste containing DEG (toxicity)


This communication (including any attachment) has been prepared by BWES and is based on the available information at the time of publication and is believed to be true and accurate. The information contained in this communication should be used as a guide only and may cease to apply if applicable regulation or the product’s design or application is altered. BWES does not take responsibility for any Injury, Loss for damage suffered by any party’s interpretation or decisions made by any party on the information provided in this communication.


Remote Control Fob With Button Battery

Major Companies Pay Penalties For Button Battery Breaches

Major Companies Pay Penalties For Button Battery Breaches


Remote Control Fob With Button Battery

The ACCC issued infringement notices to three major companies in December, for failing to meet the mandatory standards for button batteries.

Several infringements were issued to Mechatronics Group (IMG) relating to replacement car key remotes. The notices were concerned with a failure to include safety warning labels. Infringements were also issued to Repco and Supercheap Auto, who supplied the Mechatronics products to consumers.

This follows on the heels of Tesla being required to pay a large penalty in regard to its own key fob remote control devices, in this case for a failure to conduct the necessary safety tests.

In addition to the fines issued by ACCC, Mechatronics have been required to recall 45 different types of remote control.

New mandatory standards for button battery safety came into effect in June 2022, specifically to deal with the serious risk to small children of swallowing the batteries.

The New Standards

The new standards impact:

  • Manufactures & suppliers that sell button batteries or package button batteries
  • Manufactures that use button batteries in the assembly of their finished products
  • Suppliers and retailers that sell products containing button batteries, including accessories, i.e., remote control devices.
  • Companies that repair, or replace products containing button batteries

“Car key remotes and fobs are everyday household items that are tempting toys for young children, and frequently within their reach. These types of products must have explicit and clearly visible warnings,” ACCC Acting Chair Catriona Lowe said.

“Button batteries are incredibly dangerous for young children. All businesses, including manufacturers, importers, distributors and retailers, involved in the supply chain for button batteries or products powered by them must comply with the mandatory safety and information standards to help keep Australian children safe,” Ms Lowe continued.

If your company is uncertain about its product compliance in relation to the button battery standards, we recommend seeking expert advice as soon as possible.


This communication (including any attachment) has been prepared by BWES and is based on the available information at the time of publication and is believed to be true and accurate. The information contained in this communication should be used as a guide only and may cease to apply if applicable regulation or the product’s design or application is altered. BWES does not take responsibility for any Injury, Loss for damage suffered by any party’s interpretation or decisions made by any party on the information provided in this communication.


Apparel On Racks At A Factory

BWES Strengthens Team With AICIS and Apparel Expert

BWES Strengthens Team With AICIS and Apparel Expert


Maria Velez, Product Compliance Officer

Compliance Risk Analyst Maria Velez has joined the team at BWES Compliance and Consulting as a Product Compliance Officer.

A 7-year stint with TJX Australia equipped her with broad spectrum product compliance expertise, with an emphasis on AICIS and Apparel products.

An innovator in compliance, Maria has developed tools that enable the checking of chemical products against AICIS inventory and ulterior categorisation.

In addition, Maria brings a high level of experience in ACCC regulatory compliance and a law degree which equips her for dealing with Australian Consumer Law (ACL) issues.

The full spectrum of Maria’s category skills include:

  • Health and Beauty
  • Home Décor involving chemicals such as Diffusers, candles and room sprays
  • Food, especially confectionery
  • All kinds of toys with emphasis on button battery compliance, aquatic toys, inflatables for kids under
  • 36 months, and portable pools
  • Apparel (with the upcoming change in 2024)
  • Programmes for Social Compliance and avoiding modern slavery.

Maria commented:

“With the constantly changing legislation in Australia, I want to offer the peace of mind that you seek when bringing products to market and help build the reputation of your brand and cement the loyalty of your customers.”


This communication (including any attachment) has been prepared by BWES and is based on the available information at the time of publication and is believed to be true and accurate. The information contained in this communication should be used as a guide only and may cease to apply if applicable regulation or the product’s design or application is altered. BWES does not take responsibility for any Injury, Loss for damage suffered by any party’s interpretation or decisions made by any party on the information provided in this communication.


A cardboard factory being painted green

ACCC Puts an End to Greenwashing

ACCC Puts an End to Greenwashing


Misleading environmental claims by Australian companies are now a top government priority.

During 2022, the ACCC (Australian Competition and Consumer Commission) completed a broad internet sweep of Australian company websites. The startling discovery they made was that 57% of those companies were making misleading environmental claims.

A cardboard factory being painted green

ACCC Chair Gina Cass-Gottlieb said, “As consumers become more environmentally conscious, businesses need to be honest and transparent when making environmental or sustainability claims, so consumers are not being misled.”

“False or misleading claims can undermine consumer trust in all green claims, particularly when consumers are often paying higher prices based on these claims.”

“Similarly, businesses that are taking genuine steps to adopt sustainable practices are put at a competitive disadvantage by businesses that engage in ‘greenwashing’ without incurring the same costs.”

In order to deal with the surprisingly large number of businesses which were seen to have been providing misleading information to customers, the ACCC has made ‘consumer, product safety, fair trading and competition concerns in relation to environmental claims and sustainability’ a top priority for 2023-2024.

A new draft guidance document now sets out good practice measures in the form of eight practical principles for businesses to apply when making environmental claims. At the same time, the document makes companies aware of their obligations in this area with regard to Australian Consumer Law.

Public consultation on the draft guidance recently closed which means we can now expect the definitive guidance to be backed by ACCC’s robust enforcement strategy.

If you would like advice and guidance on any area of product compliance in relation to environmental claims, please contact us.


This communication (including any attachment) has been prepared by BWES and is based on the available information at the time of publication and is believed to be true and accurate. The information contained in this communication should be used as a guide only and may cease to apply if applicable regulation or the product’s design or application is altered. BWES does not take responsibility for any Injury, Loss for damage suffered by any party’s interpretation or decisions made by any party on the information provided in this communication.


Geoffrey Booth BWES Director pictured in a group of IEC delegates

BWES Director Helps Set New Standards With IEC

BWES Director Helps Set New Standards With IEC


As the appointed chair of an IEC (International Electrotechnical Commission) subcommittee, BWES director Geoffrey Booth recently met up with other IEC experts in Venice for one of two face-to-face group meetings this year.

Geoffrey Booth BWES Director pictured in a group of IEC delegates

The November session contributed to IEC Advisory Groups, Maintenance Teams, Working Groups, Ad-Hoc Working Groups and Sub committees as they form the standards for the future safety and efficacy of electrical products around the world.

During the 5-day session which commenced 13 November, the group reviewed 213 main committee documents and 119 green documents.

As a result, the IEC will soon be able to publish the team’s agreed modifications and new standards for electrical products. In addition, it has been agreed that Australia will harmonise the local AS/NZS standards with these new IEC requirements within 6 to 12 months of publication.

With the contribution of more than 20,000 global experts, IEC is the independent, global organisation that develops and publishes state of the art international standards for electrical and electronic products and related services, used by companies and government policy makers all over the world.


This communication (including any attachment) has been prepared by BWES and is based on the available information at the time of publication and is believed to be true and accurate. The information contained in this communication should be used as a guide only and may cease to apply if applicable regulation or the product’s design or application is altered. BWES does not take responsibility for any Injury, Loss for damage suffered by any party’s interpretation or decisions made by any party on the information provided in this communication.


People working on a factory production line

Company quality standards blindsided by e-commerce behaviour

Company quality standards blindsided by e-commerce behaviour


When defective products are returned by a dissatisfied consumer, there are three immediate effects:

  1. The retailer makes an expensive chargeback to the supplier.
  2. The brand’s reputation takes a hit.
  3. The returned good must now be reworked and re-supplied, or else disposed of.

This combination adds up to a significant cost for a company, especially where hundreds or even thousands of defective products are returned.

People working on a factory production line

AQL

AQL (Acceptable Quality Limit) determines the threshold for defects in product manufacturing, with the margin of acceptability varying between low priced goods and premium brands.

On average, lower priced brands set an AQL of around 2.5% for major defects and 4.0% for minor ones. The ISO Consumer Risk Index says that up to 10% of those orders will contain 17.5% of units with defects. Quality brands, with a tighter AQL of 1.0% to 1.5%, can still expect to have a fairly high 9.5% of defective units.

THE E-COMMERCE VARIABLE

Although this has been the acceptable ‘norm’ for decades, e-commerce adds a new dimension to the numbers above.

When a customer receives a defective item at their home, they are presented with the hassle of having to make a return. Consumer research has shown that most of the time when this occurs, the customer doesn’t bother to order a replacement. However, if they do, and they receive a faulty good a second time, it’s usually a permanent goodbye to that brand.

Additionally, research has confirmed that for every complaint received, another 25 customers will not bother to complain, which can mask significant long-term negative sentiment about a brand.

TIGHTENING STANDARDS

The solution to reducing the cost of returns and preserving a brand’s reputation is to revisit those AQLs. Using Tightened Level III sampling levels (instead of the industry standard Normal Level II) will increase pre-shipment inspections by 50%.

In addition, a Factory Capability Audit will determine true proficiency and highlight any areas for improvement. This often helps to persuade factory owners to up their game and no longer turn a blind eye to passing along defects in the production chain.

BWES Compliance and Consulting can help companies of all kinds to reduce product defects and their resulting costs, with dedicated expert resources located in Australia, Hong Kong and China.


This communication (including any attachment) has been prepared by BWES and is based on the available information at the time of publication and is believed to be true and accurate. The information contained in this communication should be used as a guide only and may cease to apply if applicable regulation or the product’s design or application is altered. BWES does not take responsibility for any Injury, Loss for damage suffered by any party’s interpretation or decisions made by any party on the information provided in this communication.


Organic Product Extraction For Cosmetics

Organic and natural cosmetics - why you might still need to register your product with AICIS

Organic and natural cosmetics

Why you might still need to register your product with AICIS


Consumer preferences for cosmetics and soaps containing natural ingredients has resulted in a huge choice of products on the shelf labelled as natural, organic, herbal or pure.

AICIS is the Australian government scheme that monitors and registers imported or manufactured chemical ingredients. Products with naturally occurring ingredients and which don’t have any other chemicals added, do not have to be registered with AICIS. However, the term ‘naturally occurring’ can be deceptive…

Organic Product Extraction For Cosmetics

What is and isn't naturally occurring?

In Australia, naturally occurring chemicals are defined by AICIS as:

  • an unprocessed chemical that is found in nature, such as chemicals from plants, micro-organisms, animals, the earth and the sea
  • a chemical that is found in nature and extracted using a process that does not change its chemical composition

However, extracting naturally occurring chemicals and aroma compounds for use in cosmetics is very often done in a way that changes the chemical composition of the original ingredient. Argan oil for example is commonly extracted using a solvent. Steam distillation is another process that’s commonly used.

The use of these processes, as well as fermentation and microwave extraction means that the extracted material no longer meets the legal definition of naturally occurring.

Therefore any product with ingredients extracted in this way are regulated by AICIS. That means you must register your business with AICIS before you can import or manufacture it.

On the other hand, if your product contains only ingredients that have been extracted using processes that don’t cause a chemical change, such as:

  • Filtration, centrifugation, sedimentation, cold pressing or sieving.
  • Extraction by dissolution in water
  • Flotation
  • Heating to remove uncombined water.

Then your product is unregulated and you do not have to register with AICIS.

For absolute certainty as to whether your product should or should not be registered, it might be quicker and easier to get your product to market by seeking some expert advice.


This communication (including any attachment) has been prepared by BWES and is based on the available information at the time of publication and is believed to be true and accurate. The information contained in this communication should be used as a guide only and may cease to apply if applicable regulation or the product’s design or application is altered. BWES does not take responsibility for any Injury, Loss for damage suffered by any party’s interpretation or decisions made by any party on the information provided in this communication.