G/TBT/W/674  
 
23 July 2019  
(19-4886) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
INDIA - THE STAINLES S STEEL PRODUCTS (QU ALITY CONTROL) ORDER , 2015  
STATEMENT BY INDIA  TO THE COMMITTEE ON  TECHNICAL BARRIERS TO TRADE  
20 AND 21 JUNE 2019  
The following communication, dated 22 July 2019, is being circulated at the request of the delegation 
of India. 
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My delegation would like to thank the delegation of the European Union for their continued 
interest in the matter of India 's Stainless -Steel Products (Quality Control) Or der.  
Though in earlier meetings of TBT Committee, my delegation has clarified on the issues raised 
by the EU, my delegation would like to re -iterate the same in brief again, for the information of the 
delegation raising the issue and other committee Membe rs. 
The Stainless -Steel Products (Quality Control) Order aims to ensure quality and durability of 
stainless steel products intended for critical end -use applications. Many of the steel products are 
used as final products also.  
It is reiterated that the Or der is equally applicable to both domestic and foreign manufacturers.  
On the necessity of the measure and requirement of re -testing, it is to reiterate that quality of 
the stainless steel is of utmost importance as it involves public health, safety and se curity. For the 
requirement of testing, the BIS (Conformity Assessment) Regulation 2018, requires evidence of 
conformity of the product to the relevant Indian Standard through testing in a BIS / BIS recognized 
laboratory, for the purpose of granting BIS ma rks certification license. Samples are drawn for testing 
in the independent laboratories for assessing conformity to the relevant standard before granting 
licence. Indian Standards specify method of tests, and the labs recognized by BIS carry out tests as 
per the test methods and requirements defined in Indian Standards. Here, it is again informed that 
BIS Laboratory Recognition Scheme has a provision for recognition of overseas laboratories, details 
of the same are available on BIS LRS document hosted in B IS website. The recognition of the foreign 
laboratories will be carried out on a reciprocal and mutually beneficial basis.  
As regards risk perception from health ground is concerned, the entire pipe line for production of 
water including joints after reve rse osmosis is required to be made of stainless steel in case of 
packaged drinking water units.  
Further regarding exemption to low risk stainless steel products, we had a bilateral meeting with 
the EU delegation and my delegation has sought information fro m the EU to provide list of such 
products, which EU considers low risk with necessary technical justification.  
So far as the cost of certification by BIS is concerned, testing charges for samples are part of 
annual marking fee, for operating the licence. W e consider that the BIS cost of certification is 
reasonable as BIS being a non-profit  making organisation, it needs to meet its administrative and 
other costs such as cost of marking samples, cost of testing samples etc.  G/TBT/W/674  
 
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On the suggestion that the steel mi lls with ISO 9001 quality management system in place, should 
be exempt from the requirement of factory inspections, India finds that product certification is 
different from QMS certification. The visit to the factory premises and verification and testing i n the 
factory, is a part of the BIS Conformity Assessment Scheme. On the other hand, ISO 9001 
certification does not cover factory testing as per Indian Standards. The license is granted or 
inclusion in the existing scope of the license is permitted for th e grade designations, sizes and 
varieties, specified in the standard only, after ensuring that the manufacturer is having the required 
manufacturing and testing facilities for the same. Hence such inspections are essential.  
So far as restrictions on dimens ions are concerned, it is informed that in IS 6911: 2017 which 
is for stainless steel plate, sheet and strip, entire range of dimensions of sheets, plates and strips 
has been covered and dimensional tolerance, other than specified in the standard, are perm itted, if 
agreed between the manufacturer and purchaser. In case of IS 5522 and IS 15997, which is 
specifically for utensils and kitchen appliances, thickness from 0.2 mm to 4 mm is permitted and 
dimensional tolerance for the same is specified in the stand ard. Further there are no restrictions on 
the surface finishes in all the three standards i.e., IS 5522, IS 6911 and IS 15997 as besides the 
surface finishes mentioned in the standard, other finishes may be manufactured, if mutually agreed 
between the purc haser and the manufacturer.  
Having said so, we also look forward to discuss any such issues bilaterally in case there is still 
any clarification required by the member concerned. India would like to update the members that 
as of now, there are 53 products listed under the Stainless Steel Order.  
 
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