G/TBT/W/635  
 
9 April 2019 
(19-2264) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
INDIA - THE STAINLES S STEEL PRODUCTS (QU ALITY CONTROL) ORDER , 2015  
STATEMENT BY THE EUROPEAN UNION TO THE COMMITTEE ON TECHNICAL BARRIERS T O TRADE  
6 AND 7  MARCH  2019 
The following communication, dated 5 April  2019, is being circulated at the request of the delegation 
of the European Union . 
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1.  The EU has provided written comments on the draft Stainless Steel Products (Quality Control) 
Order, 2015 on 23 October 2015 and would like to reiterate once again  its concerns, previously 
raised in  previous Committee meetings. The EU  would also like to refer to its previous statements 
in the TBT Committee on this issue.  
2.  Since raising this issue in the TBT Committee, the EU discussed this issue with Indian authorit ies 
in our bilateral SPS-TBT Joint Working Group  in January 2019. Unfortunately, no progress was made 
in resolving it.  
3.  Once again, the EU is concerned that these measures constitute an unnecessary technical barrier 
to trade and discriminate against foreig n producers that have to conduct double testing to access 
the Indian market. The r equirement for re -testing by BIS authorised laboratories of the covered 
steel products, which have already been tested against the relevant international standards, creates 
a non-tariff barrier to trade.  
4.  The EU takes note of India' s explanations expressed in  the previous TBT Committees , in 
particular,  that the BIS standards are necessary  in order to take into account the manufacturing 
practices of India , and therefore international standards are insufficient.  
5.  However, in the EU maintains its view that the procedure is disproportionate for low risk products 
and unjustified on health and safety grounds. The EU steel already complies with internationally 
recognised standards , as well as with  safety and quality standards recognised around the world. The 
EU would like to ask the Indian authorities to confirm whether these standards are equivalent to the 
relevant international standards. If that is the case, tho se international standards should be referred 
to in the text as well. Given that the intermediate product is a low risk product and that the EU 
producers comply with international requirements and specifications, the EU would once more like 
to ask India to : 
- accept the tests carried out in foreign accredited laboratories attesting compliance with 
ISO standards (or India n standards), and thus not requir e local testing in India for all 
types of steel products.  
- stop conducting factory inspections in the EU ste el mills having in place quality 
management system as defined in ISO 9001. These inspections are problematic and there 
is a certain lack of clarity as regards the requirements of the Mill Test Certificate (MTC).  
6.  The EU would also like to ask India to apply  the certification only with reference to stainless steel 
grades. T here should be no restrictions on physical dimensions (thickness, width, length, etc.) and 
no restriction on the finishing of the products (finishes, edge conditions, etc.) as there are man y G/TBT/W/635  
 
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  different sizes and finishing for stainless steel products. Furthermore, once the producing mill is 
verified and the product certified, the certification should remain valid in case the product is issued 
to the mill's service centres and then shipped to India to avoid an unnecessary and burdensome 
double certification process.  
7.  In addition, with regard to the Steel and Steel Products (Quality Control) Order, 2999 issued on 
20 June 2018, the EU recall s that the new 3 steel products brought under the Quality  Control Order 
brings the total number of products requiring a certification to 68 . Same concerns previously 
highlighted  also relate to these new covered steel products.  
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