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On the Importance of Adding Production Date/Inspection Date to CCC Certified Products
Date:2022/4/25  Clicks:1122
In recent years, there have been more and more complaints about CCC products, most of which involve the suspension, cancellation or revocation of CCC certificates for certified products in the field of circulation. According to Article 51 of the Regulations on the Administration of Compulsory Product Certification, such The administrative penalty that the problem may result in will be a severe penalty of 50,000-200,000. How can companies avoid it? This involves the traceability management of products by enterprises.

The consistency emphasized by certified products means that the same type of product has indistinguishable physical features. The only thing that can be easily and quickly identified is the time information of the product, which can distinguish when the production inspection has passed the inspection, can track the materials used, and can correspond to to the factory batch. Companies can embody traceability time information in a variety of ways on products or minimal packaging, such as barcodes, QR codes, product-specific numbers or production dates/lots, inspection dates, and more. For general businesses, printing the production/inspection date is the easiest way.

The product has no production date and no quality inspection date. Does this meet the regulatory requirements? What trouble will it bring to the business?

Article 27 of the "Product Quality Law of the People's Republic of China" must be authentic and meet the following requirements:

Have product quality inspection certificate;
. . . . . .

For products with limited use, the production date and safe use period or expiration date shall be clearly marked in a prominent position;

Therefore, from the perspective of the Product Quality Law, for general industrial products, if there is no service life requirement (limited use), it is not important or illegal whether the production date/inspection date is marked on the product.

However, for CCC certified products, if there is no traceable time information such as production date/inspection qualified date, it may bring a lot of trouble to the enterprise.

Article 51 of the "Regulations on the Administration of Compulsory Product Certification" violates the second paragraph of Article 29 of these regulations (from the date of cancellation or revocation of the certification certificate or during the suspension period of the certification certificate, products that do not meet the certification requirements shall not continue to leave the factory. , sales, import or use in other business activities.) It is stipulated that during the cancellation, revocation or suspension of the certification certificate, products that do not meet the certification requirements continue to leave the factory, sell, import or use in other business activities. Local quality inspection According to Article 67 of the Regulations on Certification and Accreditation (Note: Article 66 of the new version: The products listed in the catalogue have not been certified, and have been shipped, sold, imported or used in other business activities without authorization. Those who use it shall be ordered to make corrections and a fine of not less than 50,000 yuan but not more than 200,000 yuan shall be imposed; if there is any illegal income, the illegal income shall be confiscated.

There are many cases of "products that do not meet the certification requirements". For manufacturers, it is not allowed to leave the factory or sell certified products within the scope of the CCC certificate during the period of certificate suspension or after cancellation or revocation. Because the time of manufacture will not be marked when the products leave the factory, how can the products that have been sold in the circulation field be determined to be satisfactory? This needs to be determined by reasoning based on the traceability time information of the product itself and the valid status of the CCC certificate.

If there is no such time information on the product/package, it is impossible to judge the time of delivery of the product, and it is difficult for manufacturers and sellers to prove that the product was delivered and received in a valid state of the certificate. lead to consumer complaints.

In addition, the product does not have time information, which will bring a lot of trouble to the company in the follow-up disposal of unqualified products. For example, all products can only be removed from the shelves and recalled according to the product model, and cannot be processed according to the time information according to the reasons for the unqualified products. Identification processing, thereby greatly increasing the management cost.

The importance of the traceability time information on certified products is emphasized, and many readers may not understand it. We will use actual cases to elaborate more in the future. Stay tuned.

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