G/TBT/W/584  
 
10 December 2018  
(18-7783) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
INDIA — THE STAINLES S STEEL PRODUCTS  
(QUALITY CONTROL) OR DER, 2015  
STATEMENT BY INDIA TO THE COMMITTEE ON TECHNICAL BARRIERS T O TRADE  
14 AND 15  NOVEMBER  2018 
The following communication, dated 7 December 2018 , is being circulated at t he request of the 
delegation of India. 
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1.  I would like to thank the delegation of the European Union for its interest in the matter of India's 
Stainless -Steel Products (Quality Control) Order.  
2.  Though we clarified on the issues raised by the E U in earlier meetings of CTG held in 2017 & 
2018, we 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 said 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. 
The Order is equally applicable to both domestic and foreign manufacturers.  
4.  On the necessity of the measure and requiremen t 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 (Certification) Regulations 1988, 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 
independent laboratories for assessing conformity to the rel evant 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 concerne d, 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.  
5.  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. We 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, cos t of testing samples etc.  
6.  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 product 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 
manufacturing and testing facilities for the same. Hence suc h inspections are essential.  
7.  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 certain 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 G/TBT/W/584  
 
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  steel covered under IS 6911 as the said standard covers the stainless steel requirements for g eneral 
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.  
8.  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.  
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