Compliance should now be firmly on the top of the agenda for any retailer selling sunglasses following consumer group Which?'s damning report
The recent investigation (18th August 2011) by consumer group Which? revealed that several high street retailers were potentially flouting European standards when it came to selling sunglasses.
Which? magazine, who tested 21 pairs of sunglasses from seven high street shops, found 15 pairs failed key laboratory tests and breached standards required to meet the Personal Protective Equipment Directive for the European Union.
With the results set to be investigated by the Trading Standards Office, now more than ever, buyers need to ensure they are insisting suppliers adhere to the directive. While some of the failures could be debated based on differing interpretations of one particular clause of the standard, many were serious failures with potential to cause significant damage to the wearer's eye health and wellbeing.
According to Tim Downes, CEO of Fabris Lane, these findings should concern retailers who rely on foreign manufactures to test for compliance. "As we've seen with the recent coverage in the national papers following Which?'s report, retailers who don't place importance on compliance are not only putting their customer's health at risk, they are also running the risk of damaging their brand's image.
"As the media and consumer's attention turns to those retailers flouting standards, the ability to ensure compliance should be a top priority for buyers when sourcing an eyewear supplier."
Fabris Lane, who manufacture 40% of the UK's sunglasses, use a UKAS approved test laboratory to ensure compliance with the European Directive and can provide technical file details, EU declarations of conformity and Test Certificates under their UKAS accreditation for all products they release to the market.
To help buyers navigate what can be a confusing subject, Fabris Lane's Supplier and Test Laboratory Manager, Rob Pickett, has compiled the following guide on what compliance means and what retailers need to test for.
Compliance, what does it mean?
Under European legislation sunglasses are covered by the European Personal Protective Equipment Directive 89/686/EEC and subsequent relevant amendments. In order to place a product sold as a sunglass into the European market it must be CE marked to indicate compliance with the directive.
What is the CE mark?
The CE mark indicates that the sunglass meets the requirements of the PPE directive and that it has been tested to the relevant European standards. Furthermore any sunglass with a CE mark must have a technical file, which must be made available to the National controlling authority (e.g. Trading Standards in the UK) if demanded. Failure to conform with these requirements will result in the sunglass having to be removed from the market and the European importer or manufacturer being subject to potential prosecution.
With such responsibility lying with the retailer, it's essential that they are confident in their eyewear supplier's ability to address any concerns the Trading Standards might have. In some cases the interpretation of certain clauses might vary, but what's important, is that the supplier can support their interpretation and prove due diligence has been shown. This can often mean the difference between a product remaining on shelf or being pulled at the request of Trading Standards.
What key requirements do sunglasses have to meet to be compliant?
Below is a table which simplifies the key requirements sunglasses need to meet to be considered compliant.
| Area for testing | Minimum requirement sunglasses must meet | What it means for consumers |
|---|---|---|
| UV Protection | Minimal ultra violet light lens transmittance across the UVA and UVB bandwidth of 280nm to 380nm wavelength | UV protection in lenses ensures harmful UV radiation is absorbed by the lens before reaching the eye. Should UV radiation reach the eye it can cause premature aging resulting in cataracts and Age Related Macular Degeneration, it can also cause burning which can be linked to snow blindness |
| Uniformity of lenses | For sunglass lenses the relative difference between the luminous transmittance value of the lenses at the optical centres for the right and left eyes must not exceed 20% relative to the higher value | If one lens is darker than the other this can lead to eye strain and fatigue, particularly common when driving and can lead to headaches and migraines |
| Colour Fidelity | The visual attenuation due to the lenses must not reduce signal light transmission below specified limits for red, yellow, blue and green signal lights. | If lenses don't meet the Standard's tolerances, then the wearer can have difficulty identifying colours particularly red, making driving dangerous as the wearer is unable to see traffic lights, signals and signs properly |
| Darkness of Lenses | The luminous transmittance of any sun glare filter for general use is attributed to one of five categories. Category 0 = 100% to 80% transmittance, 1= 80% to 43%, 2=43% to 18%, 3= 18% to 8% and 4= 8% to 3%. | If lenses transmit below 8% of light (category 4) they are too dark for safe driving and similar safety critical uses |
| Astigmatic, Spherical and Prismatic Powers of the Lenses | Optical powers of the lenses creating shape change, size variance and positional shift must be negligible within a 10mm radius of the optical centres for the right and left eyes | Failure to meet standards creates optical distortions (with the potential for accidents) resulting in eye strain and fatigue causing headaches and migraines |
| Mechanical properties of the sunglasses | Frames and lenses must meet defined finish, robustness and endurance requirements that ensure minimum levels of product quality, strength and resistance to damage | Poor design, incorrectly specified materials, poor quality components and badly assembled product put the wearer at risk e.g. fragments of lens entering the eye |
For more information on how to ensure your sunglasses range is compliant, contact Fabris Lane www.fabrislane.co.uk or call 0845 878 7187
