G/TBT/W/623  
 
2 April  2019 
(19-2098) 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 T O TRADE  
6 AND 7  MARCH  2019 
The following communication, dated 2 April  2019, is being circulated at the request of the delegation 
of India. 
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1.  India 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) Order.  
2.  Though in earlier meeting s 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 Members.  
3.  The Stainless -Steel Products (Quality Control) Order aims to ens ure quality and durability of 
stainless steel products intended for critical end -use applications. Many of the steel products are 
used as final products also.  
4.  It is reiterated that the  Order is equally applicable to both domestic and foreign manufacturers .  
5.  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 security. For the 
requirement of testing, the BIS (Conformity Assessme nt) 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 marks certification license. Samples are drawn for testing 
in the inde pendent 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. As regards risk perception from 
health ground is concerned, the entire pipe line for production of water including joints after reverse 
osmosis is required to be made of stainless steel in case of packaged drinking water units.  
6.  So far as the cost of certif ication by BIS is concerned , testing charges for samples are part of 
annual marking fee, for operating the licence. We consider that the BIS cost of certification is 
reasonable as BIS being a non profit making organisation, it needs to meet its administrat ive and 
other costs such as cost of marking samples, cost of testing samples etc.  
7.  On the suggestion that the steel mills with ISO 9001 quality management system in place, should 
be exempt from the requirement of factory inspections , India finds that produc t certification is 
different from QMS certification. The visit to the factory premises and verification and testing in 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 the grade designations, sizes and 
varieties, specified in the standard only, after ensuring that the manufacturer is having the required 
manu facturing and testing facilities for the same. Hence such inspections are essential.  G/TBT/W/623  
 
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  8.  So far as restrictions on dimensions are concerned , dimensions permitted in the Indian standards 
for stainless steel sheet, plate and strip are defined therein, wherein ce rtain dimensions are 
permitted as those standards cover the requirements of stainless steel for manufacture of utensils 
and kitchen appliances. On the other hand, there is no restriction on the dimensions of stainless 
steel covered under IS 6911 as the sai d standard covers the stainless steel requirements for general 
engineering purpose and not for speciality products. Further there are no restrictions on the surface 
finishes in all the three standards for the purpose i.e., IS 5522, IS 6911 and IS 15997.  
9.  Having said so, w e also look forward to discuss any such issues bilaterally in case there is still 
any clarification required by the member concerned.  
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