EAC certification for serial production suspend for sometime cause of the Coronavirus infection (COVID-19) situation
Recommendations of the Ministry of Industry and Trade (Minpromtorg) of the Russian Federation and the Ministry of Economic Development of the Russian Federation on temporary measures on the conduction of inspectorial control, sampling and other planned work, taking into account the difficult epidemiological situation associated with the spread of new Coronavirus infection (COVID-19)
Due to the difficult epidemiological situation associated with the spread of the new Coronavirus infection (COVID-19) and the detection of new outbreaks of disease in different countries, recommendations have been developed with the purpose of explanation the actions of applicants and certification bodies for products manufactured in countries with disadvantaged epidemiological situation (hereinafter - the List of countries).
According to the law of the Eurasian Economic Union1 and the legislation of the Russian Federation2, in case of certification of a production batch, the certification body makes production audit, subsequent inspectorial control, as well as sampling (carried out including by the testing laboratory (center) on its behalf).
In accordance with paragraph 4.2 “GOST 31815-2012. Interstate standard. Conformity assessment. The procedure for conducting inspectorial control during certification procedures” it is stipulated that the frequency of scheduled inspections is established in technical regulations or in certification rules. In the absence of a limit frequency of inspections in technical regulations or certification rules, the frequency of inspections shall be determined by the certification body.
In accordance with paragraph 4.2.3 “GOST 31814-2012. Interstate standard. Conformity assessment. Sampling general rules for testing products in the course of confirming compliance”, sampling of production batch is carried out at the location of the batch (at the manufacturer’s finished goods warehouse, temporary storage warehouse, customs warehouse or at the recipient’s warehouse for safe storage, in the vehicle’s storage compartment).
Considering the above, due to the limited possibility for experts departure to production place to carry out mandatory production audit and sampling of products (samples) by certification bodies, the Ministry of Industry and Trade of the Russian Federation and the Ministry of Economic Development of the Russian Federation together with the Federal Service for Accreditation recommend to certification bodies and applicants for mandatory certification the following:
1) As for valid certificates of conformity for production batch: to postpone the inspectorial control procedure for up to 6 months in the event that the next scheduled inspectorial control has come or comes within the period associated with the spread of a new Coronavirus infection (COVID-19).
- takes measures to update the quality management system, which provides procedure for postponing the inspectorial control if it is impossible departure to production place to conduct mandatory production audit and sampling (samples) (in terms of subparagraph “з” of paragraph 14.11 of the accreditation criteria approved by Order of the Ministry of Economic Development of the Russian Federation of May 30, 2014 No. 326);
- ensures the presence of the manufacturer’s letter about the invariability of the technical documentation and the manufacturing process of certified products in the case with regard to the certificate of conformity;
- makes appropriate changes to the inspectorial control plan.
The deadline for conducting inspectorial control for such certificates of conformity should not exceed 3 months from the date of exclusion of the country where the products are manufactured from the List of countries.
2) For valid certificates of conformity for production batch, the validity of which expires during the period associated with the spread of the new Coronavirus infection (COVID-19), the certification body that conducted a periodic assessment (inspectorial control) of this certified product may issue a new certificate for batch, taking into account the positive results of the latest periodic evaluation of such certified products.
Inspectorial control on such newly issued certificates should be carried out within a period not exceeding 3 months from the moment of exclusion of the country where the products are manufactured from the List of countries.
The specified paragraph may be applied only to products for which there are no revealed facts of violation of mandatory requirements.
3) As for products put into operation for the first time, as well as products with respect to which the certificate has expired, to apply certification schemes for production batch or for single products, depending on the certification subject.
In this case certification body can take samples at a temporary storage warehouse, customs warehouse, in the vehicle’s storage compartment, or through samples imported into the Russian Federation in compliance with customs procedures and designed for examination (testing) and measurement of samples products.
4) Certification bodies temporarily suspend the provision of services for conducting production audit and sampling in countries from the List of countries to applicants.
5) For the period of the epidemiological situation associated with the spread of the new Coronavirus infection (COVID-19) and the validity of these recommendations, paragraphs 1 and 2 can equally be applied by certification bodies with respect to products manufactured in the Russian Federation with the appropriate consent the applicant.