G/TBT/W/494  
 
19 April 2018  
(18-2436) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
 INDIA — THE STAINLESS STEEL PRODUCTS  (QUALITY CONTROL) OR DER, 2015  
STATEMENT BY THE EUR OPEAN UNION TO THE C OMMITTEE ON TECHNICA L BARRIERS TO TRADE  
21 AND 22 MARCH 2018  
The following communication, dated 16 April 2018, is being circulated at the request of the 
delegation of the European Union . 
 
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1.  The E uropean Union has provided written comments on the draft Stainless Steel Products 
(Quality Control) Order, 2015 on 23 October 2015 and would li ke once more to reiterate its 
concerns , as already done during the previous  meetings of the TBT Committee.  We also would like 
to refer to EU's previous statements in the TBT Committee on this issue.  
2.  The notified draft further extends the scope of the exis ting Bureau of Indian Standards (BIS) 
mandatory certification system to 3 new steel products, such as stainless steel plates, sheets and 
strips.  
3.  The EU is concerned that these measures constitute an unnecessary technical barrier to trade 
and discriminate a gainst foreign producers that have to conduct double testing to access Indian 
market. Requirement for re -testing by BIS authorised laboratories of the covered steel products, 
which have been already tested against the relevant international standards, crea tes non -tariff 
barrier to trade.  
4.  The EU takes note of India's explanations expressed at the previous TBT Committees that the 
BIS standards are required in order to take into account manufacturing practices of India and 
therefore international standards ar e insufficient.  
5.  However, the EU views 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 and safety and quality standards recogn ised around the world. The EU ask 
the Indian authorities to confirm whether these standards were equivalent to the relevant 
international standards. If that is the case, those international standards should be referred to in 
the text as well. Given that th e intermediate  product is a  low risk product and that the EU 
producers comply with international requirements and specifications , the EU would like to once 
more ask  India to: 
6.  - accept the tests carried out in foreign accredited laboratories attesting compliance with ISO 
standards (or India standards) , and thus not requiring local testing in India for all types of steel 
products.  
7.  - stop conduct ing factory inspections in the EU steel 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).  G/TBT/W/494  
 
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  8.  The EU would also like to ask India to a pply the c ertification 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.  
 
 
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