Twas the night before Christmas and all through the house…
I have everything in place for a wonderful morning of holiday gift-giving and memories to be made.
The stockings were hung by the chimney with care…
So I settle down with a mug of warm cocoa, light the log in the fireplace, and unwind from the hustle and bustle of the holiday.
When out on the lawn there arose such a clatter…
I think, “Uh, oh. What is that noise out there? Kids messing around with my 6-foot inflatable Abominable Snowman? Someone on their way home from a party?”
I sprang from [my recliner] to see what was the matter…
When I part the curtains, I think I am seeing things. Someone is parked in the driveway. It looks like some sort of antique sled and, really, there are animals harnessed to it.
As I drew in my hand, and was turning around, down the chimney St. Nicholas came with a bound…
Whoa! Hold on, this can’t be real. First of all, I have a nice toasty fire roaring in the colonial-sized fireplace. If someone is really coming down the chimney, this isn’t going to turn out so well. Should I call 911 now? Burglars disguised like the Jolly Old Fellow? This is going to be interesting.
He was dressed all in fur, from his head to his foot…
Just then, I see a burly man slide down the chimney as I rub my eyes wondering what is in the hot cocoa I am drinking or if I had watched too many Harry Potter movies recently. As he descends, I see sparks flying when his boots hit the logs. If he hurries, he can make it unscathed, but with all of this magical stuff going on, maybe he has a fireproof suit anyway.
Just then, I awake abruptly. I had nodded asleep and this was all just a bad dream…or was it?
The combination of the comforting setting along with the discussions I had earlier in the week with the Chief Supply Chain Risk Officer at work contributed to the bizarre scenario. But the hallucination got me to think about the regulatory directives from government agencies all around the world.
For instance, the United States Federal Government requires clothing and textiles intended to be used for clothing to have “Normal Flammability” as tested with 16 CFR 1610 (ASTM D 1230 Standard Test Method for Flammability of Apparel Textiles); quite a mouthful of jargon, I know. The means in which testing labs conduct this type of analysis is similar to the way Santa came down the chimney – the fabric is mounted at a 45° angle from ignition source and the rate of burn is measured.
Some exemptions apply:
- Certain hats
- Interlining fabric
- Plain surface fabrics, regardless of fiber content, weighing 2.6 oz/yd2 or more
- Fabric made entirely with these fibers, or blends of these fibers: acrylic, nylon, polyester, modacrylic, olefin, and wool
And of course, there are other confusing aspects of this simple garb. In October 2017, the US Court of International Trade ruled on a case against Rubies Costume Co. regarding the classification of Santa Claus suits under Chapter 95. The Notes to Chapter 95 exclude “fancy dress, of textiles.” The court equated the term “fancy dress” with costumes. The next question was whether the suits were “of textiles.” Essentially, the court held that since the costumes were durable, not flimsy and likely would be used from year to year, they were “of textiles,” and therefore excluded from Chapter 95.
Meeting the Standards
In an effort to increase margins while offering customers more choice, many retailers have turned to lower priced imports. This strategy enables retailers to better manage purchasing costs but often comes with hidden costs - returns, recalls, and—most importantly—the potential loss of consumer confidence. With the abundance of products manufactured overseas, reduced quality control is inevitable. Every day around the world, manufacturers, brands, and retailers turn to expert testing labs with questions. “Can we make it better, faster, more efficient, and maintain the tough regulatory standards mandated by all levels and regions of government? How do we strike the balance between quality, profitability and compliance?”
Knowledgeable retailers know that working with an experienced lab—not just for test execution, but also as an advisory team—provides a higher level of control across the supply chain. In today's highly competitive environment, this type of relationship can offer a unique advantage to balance an efficient supply chain with increased product quality.
To assist retailers in effectively managing their suppliers, Amber Road has built a data bridge through integration to many of the major testing and auditing labs. The third-party companies offer a complete suite of supply chain management services designed to help organizations strengthen their business operations, resulting in:
- Reduced quality problems
- Reduced customer complaints due to lack of quality, safety and usability
- Increased verification of legal requirements and laws
- Increased customer satisfaction through higher product quality, safety and performance
These experts offer a host of global services that inspect and verify product quality and performance for suppliers located around the world, before products are even shipped to the distribution network. This provides retailers with independent third-party verification that the products they sell are compliant not only with global safety requirements, but also with their own performance specifications. Through the integration of technology with Amber Road’s Global Trade Management (GTM) platform, this area of the production process just became simplified.
Almost The End
After the sparks fall and the smoke dissipates I come to realize that it was all just a dream after all. The image of Saint Nicholas making his entrance through the chimney has me wondering what it is that keeps him unharmed in the presence of a large blazing fire. Having been lost in the thought of government regulatory directives for fire and safety, it’s possible to believe that Santa’s suit has in fact been properly tested under 16 CFR Part 1610 for flammability. The manufacturer and importer took the right steps to comply with the standards within regulation. Santa himself, or even one of the many other “Santas” bringing joy to children everywhere are not in danger. That said, I believe now it is time to put out the fire and go to bed.
As I doze off once again, I have a stronger conviction that prevention is better than damage control. I will turn to the experts for help to manage the global supply chain risks for my company by checking and testing for any issues, defects or hazardous chemicals before a product enters the market or before beginning operations. These simple steps—facilitated by technology—help avoid recalls, brand reputation damage, health issues and even fatalities.
Learn more about Amber Road’s Product Testing solution to automate your supply chain processes.
This post was published on December 18, 2017 and updated on December 18, 2017.