A packager who changes their process in a way that renders the description of their e-marking system inaccurate will no longer hold recognition for the modified process. The recognition must be adjusted to align with the modified process.
Changes can be reported by manually indicating them on a copy of the existing recognition and sending a scan of the document to e-merk@nmi.nl. Changes in filling lines and/or measuring instruments can also be indicated in this manner or through a dedicated form.
NMi will provide a quotation, and once signed and paid, an appointment will be scheduled for a visit to conduct a preliminary recognition or re-evaluation (see below).
A visit is necessary for several reasons. Firstly, the components of an e-marking system are interconnected, so even seemingly minor changes can result in an entirely different system. Secondly, assessment criteria may change, and certain components of a recognized e-marking system may require recognition under different conditions. Lastly, the e-marking system does not follow a cycle of annual surveillances and regular re-evaluations where changes would typically be considered. Over 5 years old:
If the recognition is over 5 years old, the recognition of the new process follows the same procedure as the recognition of a new system.
Not over 5 years old:
If the recognition is not older than 5 years, NMi conducts a re-evaluation. This involves examining whether the changes align with the existing e-marking system and whether the packager is fulfilling their agreed-upon obligations.
Based on this assessment, advice is provided regarding the renewed definitive recognition of the e-marking system. In some cases, it may be necessary to issue a new preliminary recognition and conduct another evaluation.