GreenFrog Seoul Blog Episode 119 ·

The reorder was supposed to be identical, but the parts had changed
Managing engineering changes (ECN) at Chinese factories - what factories change without telling you, how buyer-requested changes go wrong, approved samples, BOMs and change request forms, contract clauses, how to catch hidden changes, and a checklist

Hello, this is GreenFrog Seoul.

A company importing small humidifiers sold its first order of 3,000 units without trouble, then reordered 5,000 units from the same factory. About a month after the second batch arrived, reviews saying "it got louder" and "it leaks" started piling up. When the team took apart a unit from each batch side by side, the internal pump came from a different manufacturer, the component layout on the circuit board had changed, and the water tank wall was 0.3 mm thinner.

When they confronted the factory, the answer was: "Performance is exactly the same. We only changed the parts supplier." Performance was not the only problem, though. The Korean KC certification had been tested on the first batch's board and component set, so strictly speaking the changed product was not the product that had been certified. The importer had to stop sales and figure out what to do with the remaining stock.

Factories changing specifications without telling the buyer is very common in China sourcing. Changes the buyer requests can also cause trouble when they are not managed properly. The process for controlling these changes is called engineering change management, built around the ECN (Engineering Change Notice). This post covers what factories commonly change, how a change approval process works, the clauses to put in your contract, and how to catch changes made behind your back.

To a factory, switching a parts supplier is often just a "小改动" (a small change). Saving a few percent on cost is a big win for the factory, and if the buyer never notices, nothing happened. Unless the duty to notify you of changes is written down, the factory has no reason to tell you.

Note This post reflects Chinese OEM/ODM production practice as of October 2026. Which changes require certification retesting depends on the product and the type of certification, so please confirm specific cases with your certification body or test lab.

1. What engineering change management is

Engineering change management is the process that defines, whenever an approved product specification changes, who requests the change, who reviews its impact, who approves it and when it takes effect. Manufacturers usually split it into the change request (ECR, Engineering Change Request) and the change notice (ECN, Engineering Change Notice). Chinese factories call it "工程变更通知" or simply "变更通知".

ItemWhat it isWho issues it
ECR (change request)A request describing what should change and whyEither the buyer or the factory
ECN (change notice)The reviewed and approved change, its effective point, and the new drawing and BOM versionIssued by the factory after approval, signed by the buyer
Approval sheet (承认书)The document in which the buyer approves the spec sheet and sample that define mass productionPrepared by the factory, signed by the buyer

Factories that supply large companies are used to this process, but factories that mainly do small-volume OEM often keep no change history at all. When you work with factories like that, it is more realistic for the buyer to set the forms and require them.


2. What factories most often change without telling you

Most of the changes we actually see in our consultations start with cost cutting or material supply problems.

What changesCommon examplesPossible problems
Raw material gradeVirgin plastic mixed with recycled material, stainless steel 304 swapped for 201Lower durability, rust, food-contact compliance issues
Parts supplierDifferent maker of motors, pumps, batteries or adaptersDifferences in noise and lifespan, mismatch with certification
Electronic parts and PCBChipset replaced by a compatible chip, board layout changedRadio or electrical safety retesting may be needed
Dimensions and thicknessThinner injection-molded walls, ribs left outBreakage, leaks, assembly defects
Surface finishThinner plating, a painting step skippedDiscoloration, peeling
PackagingLower-grade corrugated cartons, less cushioningDamage in transit
Production site and processSome processes outsourced to another factoryInconsistent quality, blind spots in control

We covered color and material drifting from lot to lot in Episode 45, and factories secretly subcontracting in Episode 115.


3. Changes the buyer requests go wrong too

Engineering changes do not only come from the factory side. After the first sales, it is natural to reshape a handle based on customer feedback, move a logo or add a color. The trouble starts when these requests are exchanged as quick chat messages.

You send "gray buttons from the next order" on WeChat, and the factory applies it to the batch already in production, so one container arrives with two colors mixed together. A mold gets modified, but pre-change parts are still in the warehouse and end up mixed in. Many disputes also arise later because nobody agreed who pays for the mold modification and the leftover materials. For mold ownership and modification costs, see Episode 109.

Be especially careful with changes that affect certification If you change a specification that a certification test was based on, such as the board and components of an electronic product, the material of a children's product or the material of a food-contact product, you may need to be certified again. Before approving any change, check whether it affects certification. We covered certification in general in Episode 10 and radio certification in Episode 66.

4. The basic tools of change management

You do not need a complicated system. These four tools are enough to prevent most problems.

A versioned spec sheet and BOM

Give your spec sheet and bill of materials (BOM) a version number and date, and list the manufacturer and model for every part. Write "Motor, XX Co. RS-385, 12V" rather than "1 motor" so you can tell when the supplier changes. We covered how to write spec sheets and BOMs in Episode 59.

Approved sample (golden sample)

Attach a label with signatures and a date to the sample that defines mass production, and have the buyer and the factory each keep one. When a change is approved, make a new approved sample and mark the old one "void" to avoid confusion.

A change request form

If whoever wants a change has to fill in the fields below and submit them, it becomes hard for a factory to say "we told you verbally."

FieldWhat to fill in
Change descriptionSpecification before and after, with drawings or photos side by side
ReasonCost, discontinued material, quality improvement, customer request, etc.
ImpactPerformance, lifespan, certification, packaging, unit price, lead time
Effective pointWhich order, lot or production date the change applies from
Existing stockWhether pre-change parts and finished goods are used up or scrapped
EvidenceNew sample, test reports, part specifications

A change log

Keep every approved change in one table, in date order. If a claim comes up, this table is your evidence of what changed and from when.


5. Clauses for your contract and quality agreement

If you want the factory to notify you of changes, your documents must say the factory is liable when it does not. Put clauses like these into your OEM contract or quality agreement.

For quality agreements in general, see Episode 103.


6. The change approval process step by step

StepWhat to doHow to confirm
RequestReceive it on the change request form; resubmit chat requests on the formRequest number
Impact reviewCheck how performance, certification, price, lead time and packaging changeReview notes
SampleMake a sample to the new spec and test it if neededSample photos, test report
ApprovalSign the new approved sample, update the spec sheet and BOM versionSigned ECN
Effective pointAgree which lot the change starts from and how existing stock is handledPO and production schedule
First production checkInspect the first lot after the change against the new approved sampleInspection report

The last step is the one most often skipped. If you approve a change but never check the first production lot, you may find that only the sample changed while production stayed the same, or that parts you never approved changed along with it.


7. How to catch changes made behind your back

Contract clauses are useless if nobody checks. When a reorder arrives, compare it directly with the previous batch.

The easiest check is weighing. When thickness or material changes, weight changes first, so compare the weight of the finished product and its main parts with the approved sample. Take a few randomly selected units apart and compare the part makers' markings, the board layout and even the number of screws against the approved sample. Also check that the manufacturer and model printed on motor, battery and adapter labels match the BOM.

Simple tests give you a first read on materials. A magnet or a handheld analyzer works for stainless steel, and density or smell can flag problems with plastics.

Adding these items to your pre-shipment inspection checklist costs little extra. We covered inspection procedures in Episode 47 and Episode 100.


8. Sample wording to send to the factory

Factories accept change management rules when you set them with the first order. If you bring them up only after a problem, the factory is likely to say "you never mentioned this before." We recommend sending the wording in Chinese as well.

Sample wording (duty to notify)
If you need to change the approved specification, BOM, parts suppliers or production site, please notify us in writing 30 days before the change takes effect and apply it only after receiving our written approval. We will not accept products changed without approval.

Sample wording (reorder check)
Please produce this reorder exactly to spec sheet version 2.1 and the sample approved in March 2026. Before production starts, please send photos of the labels on the main parts (motor, PCB, battery).

Sample wording (buyer-requested change)
Please apply the button color change starting from PO 2026-018. Produce all earlier orders in the existing color, and send photos of the first units produced after the change. Please first tell us the quantity of remaining parts in the old color and the cost of disposing of them.


9. Three real cases

These are anonymized versions of patterns we often see in consultations. Amounts and timeframes are illustrative.

Case 1 — A different pump and board

This is the humidifier importer from the start of this post. When the factory switched pump suppliers, it also modified the board to suit the new pump. The importer stopped sales and recertified the product for KC with the new specification, losing almost two months of sales in the meantime. After that, it added a prior approval clause to its contract and included a teardown comparison in the inspection for every reorder.

Case 2 — Stainless 304 became 201

This importer brought in stainless steel tumblers. In the third batch, returns came in because some inner liners were rusting, and a composition analysis showed 201-series material. The factory said "the material supplier sent the wrong grade," but the purchase order only stated the material grade and did not require a material certificate. The importer now gets a material certificate and magnet test photos for every lot. For importing food-contact products, see Episode 64.

Case 3 — A color change requested by chat

A camping chair importer asked on WeChat for "khaki frames from now on," and the factory immediately applied it to half of the batch already in production. One container arrived with black and khaki mixed together, and returns followed from customers who received a different color from the one on the product page. The importer now requests every change only in a document that states the effective point by PO number. One page stating when the change applies, instead of a one-line message, would have prevented this.


10. Common mistakes


11. Engineering change management checklist

First order

Change requests

Reorders and inspection


Final thoughts - check "the same product" in writing

Factories usually change specifications because of cost and material supply. That may be a rational choice for the factory, but the returns and certification problems land squarely on the buyer. Rather than relying on the factory's good faith, it is more reliable to build a structure in which changes have to be reported.

You do not need much: a versioned spec sheet and BOM, signed approved samples, a change request form and a prior approval clause in your contract. Add an inspection that compares weights and parts on every reorder, and you can catch changed products before they reach consumers.

There is one thing you can do right now. Open the BOM for the next product you plan to reorder and check whether the manufacturer and model of each main part are listed. If they are not, fill them in first and have the factory confirm them.

GreenFrog Seoul supports you on the ground in China, from organizing spec sheets and BOMs and managing approved samples to designing change approval processes and running teardown comparisons on reorders. If you have already received a changed product, we can start by sorting out the scope of the change and who is responsible. If you are preparing a new order, we can start with the change management clauses to put in your contract.

Is your reorder really the same as your first order?

From spec sheets, BOMs and approved samples to change approval processes and teardown comparisons
we make sure production matches exactly what you approved

Phone   +82 10-9980-9959
Email   deanpark@greenfrogseoul.com
KakaoTalk   pf.kakao.com/_XkfuX
Website   www.startmade.co.kr

Frequently Asked Questions

Can I hold a Chinese factory responsible for changing parts without telling me?
If your contract or quality agreement has a prior written approval clause, it gives you grounds to charge the factory for returns, rework and retesting. Without one, factories often insist that "performance is the same," which makes negotiation hard. Start by securing side-by-side photos of the approved sample and the changed product, along with teardown comparison results.
Do I need to recertify a product if only a component changes?
If the component, board or material that the certification test was based on has changed, you may need to recertify. Even a part with the same performance can require a change notification or retesting if it comes from a different manufacturer. Which changes count depends on the product and the type of certification, so check with the certification body before approving the change.
How should a golden sample be stored?
Attach a label with both parties' signatures and the date to the sample that defines mass production, and have the buyer and the factory each keep one. Without a sample on the buyer's side, it is hard to prove later that the specification changed. When a change is approved, make a new sample and mark the old one void.