G/TBT/W/570  
 
29 November 2018  
(18-7546) 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 EUR OPEAN UNION TO THE COMMITTEE ON TECHNICAL BARRIERS T O TRADE  
14 AND 15  NOVEMBER  2018 
The following communication, dated 22  November 2018, 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 a nd would like to reiterate its concerns, as already done during the 
previous meetings of the TBT Committee. The EU would also like to refer to its previous statements 
in the TBT Committee on this issue.  
2.  The notified draft further extended the scope of the  existing Bureau of Indian Standards (BIS) 
mandatory certification system to 3 new steel products, such as stainless steel plates, sheets and 
strips.  
3.  Once again, the EU is concerned that these measures constitute an unnecessary technical barrier 
to trade a nd discriminate against foreign producers that have to conduct double testing to access 
the Indian market. The requirement for re -testing by BIS authorised laboratories of the covered 
steel products, which have already been tested against the relevant inte rnational 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 o f India, and therefore international standards are insufficient.  
5.  However, in the EU's view 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, those inter national 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 Indian standards), and thus not require local testing in India for all types of 
steel products.  
- stop conducting factory inspections in the EU steel m ills 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).  G/TBT/W/570  
 
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  6.  The EU would also like to ask India to apply the  certification only with reference to stainless steel 
grades. There 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 many 
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 Indi a 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, 16 more steel products have been brought under the Quality Control Order. Since 
only 180 days were given for the implementation of the order, and recalling the same concerns 
previously highlighted also relate to the new products, the EU would like to ask India to grant more 
time for the implementation of the Order for these new covered steel products.  
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