15.04.2011 - Ausgabe: 2/2011

Test marks – and what is behind them

Playground@Landscape: Mr Tempel, what is actually behind the idea of test marks?
Berthold Tempel: Most products in Germany are not subject to mandatory testing. Almost all product groups have the mandatory CE marking, i.e. the manufacturer’s self-declaration stipulated by the EU, affixed to the packaging. However, this does not indicate that the particular product has actually been tested by an independent and neutral body. Test marks provide additional safety and transparency – for the importer, the market and, of course, for the consumers.

P@L: The CE marking is hence no test mark?
Berthold Tempel: By affixing the CE marking, the manufacturer confirms that the product conforms to the applicable European standards. The consumers have to trust the manufacturer’s self-declaration without actual proof of testing.

P@L: However, if you don’t trust the CE marking 100 per cent, how can you identify safe products?
Berthold Tempel: In Germany, there has been the GS mark since 1977. GS stands for “Geprüfte Sicherheit“ (tested safety). It is a voluntary, private test mark, which is awarded only if certain legal requirements are met. It indicates to the consumer that the product has been tested and certified by a neutral, independent testing institute, like for example TÜV Rheinland, prior to its sale.

P@L: Who is entitled to award the GS mark and what are the test requirements?
Berthold Tempel: GS testing with subsequent certification must be carried out by state-approved and accredited testing institutes only. The German Geräte- und Produktsicherheitsgesetz (GPSG) (Equipment and Product Safety Act) as well as product-specific guidelines and standards form usually the basis, on which these tests are conducted.

P@L: By whom is TÜV Rheinland accredited – does TÜV Rheinland also have to undergo checks, controls and audits itself?
Berthold Tempel: Our work as an impartial testing institute is supervised by a public authority: the ZLS, i.e. the Zentralstelle der Länder für Sicherheitstechnik (Central Office of the Federal States for Safety Technology). This authority conducts audits at regular intervals to check whether we have the necessary knowledge and facilities to be able to carry out reliable, reproducible and neutral product tests.

P@L: Which tests does a product have to undergo to obtain the GS mark?
Berthold Tempel: The emphasis is on the holistic safety inspection of the product. The individual scope of testing and inspection directly depends on the product’s properties, its quality and nature as well as its field of application and intended use. Generally, all safety-relevant aspects of the product are examined carefully by the experts – ranging from mechanical to electrical to chemical safety. Everything that is stipulated by standards, guidelines and acts for the product in question is checked. The requirements partly even go beyond the legal provisions.

P@L: What does “beyond legal requirements” mean?
Berthold Tempel: For some harmful substances – like for example polycyclic aromatic hydrocarbons (PAHs) – there aren’t any legal limits yet. Some PAHs, for instance benzo(a)pyrene, may be carcinogenic to humans. We also know this from cigarette smoke. We have reached an agreement with the ZLS and other testing companies that mandatory tests for these harmful substances have also to be carried out on the basis of a defined guideline value when awarding the GS mark. If the values exceed this guideline value, we don’t award the GS mark.

P@L: Are other aspects checked apart from product properties?
Berthold Tempel: Aside from the product properties, the manufacturing sites are also checked by experts of TÜV Rheinland – wherever in the world the product is manufactured.

P@L: According to which criteria are the inspections performed?
Berthold Tempel: During the inspection of the manufacturing sites, it is checked whether quality assurance measures have been taken in the manufacture of the products. Only if a manufacturer is able to manufacture products of a constant quality throughout the entire production process, can it be ensured that the products are safe. However, if we detect variations in the production that affect the product safety, we don’t award the GS mark.

P@L: What other aspects are checked at the manufacturing sites?
Berthold Tempel: Since 2006, TÜV Rheinland has been a member of the United Nations Global Compact initiative. During our inspections of manufacturing sites, we also check on the basis of the UN guidelines whether adequate occupational health and safety measures have been taken or whether prohibited child labour is used. The UN guidelines serve as minimum requirements that the manufacturers have to meet. If the country where the product is manufactured imposes more stringent requirements, we take these as standards.

P@L: Is the product tested and examined just once?
Berthold Tempel: The holistic approach applies here, too. During the period of validity of the GS mark – which is limited to a maximum of 5 years – the manufacturing sites are again inspected on an annual basis. We also check and take a close look at the tested product more than just once. Our in-house brand monitoring team, for example, time and again performs test purchases to ensure that the products that bear our GS mark haven’t been altered subsequently.

P@L: What exactly does your brand monitoring team do to ensure that products rightly bear the GS mark?
Berthold Tempel: Our employees perform test purchases at department stores or online. There we buy products that bear our GS mark, test these and check whether they still meet the requirements of the GS mark. If a product wrongly bears the GS mark, we inform our accreditor and immediately approach the manufacturer or importer. If the product poses a hazard, we additionally and immediately inform the competent regulatory or supervisory authorities, for example the office of occupational safety and health or the trade supervisory office.

P@L: What are the duties and obligations of manufacturers who have received a GS mark by TÜV Rheinland?
Berthold Tempel: Upon receipt of the GS mark, the manufacturers commit themselves by contract to immediately notifying the testing institute of any alterations to the product – no matter how big or small. Depending on the alterations, further tests and inspections will follow. If the product safety can no longer be guaranteed because of the alterations, the GS mark will be revoked.

P@L: What happens if the inspection and testing standards change?
Berthold Tempel: The staff of TÜV Rheinland actively contribute to the work of various standards committees. As a consequence, we promptly know when standards have changed and are able to inform our customers. In the case of changes to standards, we perform additional tests on the products to ensure that the product meets the new requirements.

P@L: Apart from the GS mark, there are now many other test marks in the market. What are the differences?
Berthold Tempel: As mentioned before, the holistic product testing is the key element of the GS mark. This is not necessarily the case with other test marks. With the latter, the testing scope may vary considerably - to the better or to the worse.

P@L: What does that mean?
Berthold Tempel: If, for example, a test mark stands for chemical property testing only, this means that other safety-relevant mechanical or electrical properties haven’t been checked. These test marks thus allow no conclusions to be drawn about the overall safety of the product. You therefore have to take a closer look.

P@L: Is it admissible to test and certify products to just parts of a standard?
Berthold Tempel: It isn’t absolutely necessary to test products to the entire standard; it is also possible to test to some sections of the standard only and to certify the products afterwards. Furthermore, in most instances these tests don’t include manufacturing site inspections and the test requirements aren’t checked by public authorities. Any testing institute can award such test marks as it doesn’t require accreditation by public authorities.
However, only the GS mark allows conclusions to be drawn about the entire product.

P@L: How do the individual testing institutes carry out their tests? Are there any “black sheep” in the market?
Berthold Tempel: Of course, like in every industry, there are also some black sheep. Some affix test marks to their product – without being authorized. Others have products tested to parts of a standard only and then boast of a certificate of conformity or the like although just an individual sample has been tested and no conclusions can be drawn about series production – to name but a few examples.

P@L: Are there, so to speak, different yardsticks used in the market? In other words: If a testing institute doesn’t award the GS mark, I simply go to another testing institute?
Berthold Tempel: Things are a bit different with a GS certification. Manufacturers are not allowed to submit two applications to different notified bodies at the same time. (For details, please see the ZLS home page, “Questions and Answers”). If, however, a product has failed a test carried out by one testing institute, it is perfectly acceptable to apply for retesting by another testing institute.

The interview was conducted by Thomas R. Müller (Playground@Landscape)