When it comes to product safety and compliance, testing is essential – but it’s not the only tool in your toolbox. At QA International, we believe that a well-designed “reasonable testing program” can help brands take control of their supply chain, reduce unnecessary testing costs and build safer, more traceable products.
Before any lab testing begins, we start with a simple question: How well do you really know your factory?
A structured supply chain review is the first step toward developing a strong, evidence-based reasonable testing program. Below are the key areas we assess through our client intake and factory evaluation process.
Factory Relationship & Operational Overview
The first step in developing an effective compliance strategy is understanding the nature of your relationship with the factory. Key factors include the length of your partnership, whether a formal contract exists and the types of products being manufactured.
Don’t Miss A Thing: SUBSCRIBE To PPAI Newslink
It’s also essential to determine what portion of the factory’s production is dedicated to your brand, how production and shipment schedules are structured and who serves as the primary contact within the organization. This foundational knowledge helps define the scope of your responsibility and clarifies the level of influence your brand has within the factory’s operations.
Factory Profile & Capacity
With the partnership defined, the next step is to establish a clear picture of the factory itself. This includes details such as the year it was founded, its ownership structure (whether private, joint venture or government-owned) and a description of its product lines and operations.
RELATED: Solutions Center: Product Testing
Export markets must be identified, along with the share of business going to each region. For your brand specifically, shipment frequency and production volume should be examined closely, as they shape both logistical planning and compliance oversight.
Subcontractors Or Sub-Factories
Subcontracted production introduces significant risk if not properly managed. Determining whether all products are made in a single facility or whether certain components are outsourced is critical. When sub-facilities are used, questions must be asked about ownership, oversight and documentation practices.
Tracking materials across these sites ensures that subcontractors meet the same standards of accountability and compliance as the primary factory. Without this visibility, gaps in quality and compliance can emerge quickly.
Compliance Background & Accreditation
Evaluating a factory’s compliance record is essential to setting realistic expectations for a testing program. This evaluation begins with identifying the countries where products are sold, which dictates applicable regulatory requirements. Certifications, industry awards and relevant documentation should be reviewed carefully to assess credibility.
Just as important is determining the factory’s familiarity with regulations such as CPSIA, REACH and Proposition 65. Previous audit history, along with internal inspection processes, offers further insight into the facility’s compliance culture.
Materials & Component Purchasing
Traceability begins with raw materials. A thorough review of procurement practices provides clarity on where materials and components originate and who is responsible for sourcing them. Understanding whether materials are used exclusively for your products or shared across multiple buyers can reveal potential risks.
It’s equally important to establish whether the factory purchases directly or through intermediaries, and who within the organization oversees procurement. Supplier-provided compliance documentation, along with the frequency of supplier changes, helps determine the reliability of sourcing practices. The ability to audit suppliers further strengthens confidence in the supply chain.
Material Handling, Storage & Inventory Control
Once materials enter the facility, their management becomes a central part of compliance assurance. Strong programs identify who is responsible for incoming inspections, how materials are labeled and tracked and what procedures are in place for verification.
ICYMI: EPR Laws Are Coming For Your Company’s Packaging Data
Proper storage and movement into production, supported by a “first in, first out” system, reduces the likelihood of errors and ensures traceability. Inventory records, including logs and photographs, provide tangible evidence of accountability. This level of visibility minimizes redundant testing and supports more efficient oversight at the batch level.
Not A Replacement For Testing
It’s important to emphasize that this program doesn’t eliminate the need for product testing. Rather, it refines the process by creating a framework of documentation, supplier oversight and operational insight. The reasonable testing program shifts compliance from guesswork to data-driven management.
With greater control over the supply chain, brands gain access to factual, third-party verified information that strengthens traceability and reduces unnecessary testing. The outcome is a more reliable, targeted and cost-effective testing program – one that supports both compliance obligations and operational efficiency.
For the reasonable testing program to succeed, it requires the full cooperation of both brand and factory partners. Factories that proactively support this initiative stand to benefit from reduced testing frequency and improved relationships with buyers. Those that don’t may face increased testing requirements to compensate for lack of transparency.
Corrigan is the vice president of operations at PPAI business services member HQTS-QA International, which specializes in product testing.
