The most popular scheme in the declaration, namely 1D, is a time bomb.
Hello everyone, and indeed the most popular declaration scheme is the 1D scheme, based on its own evidence base. Why is it a time bomb? Let's try to figure it out.
And we will start with the legislation. First of all, let's turn to the regulation on the procedure for applying standard schemes for confirming compliance with the requirements of technical regulations, and we will be interested in what does the 1D scheme include, what procedures does it include? The following procedures:
1) Formation and analysis of technical documentation, directly in this paragraph, it is the applicant who must take all necessary measures to establish the production process, ensure compliance with the manufactured products, form technical documentation and conduct analysis.
2) This is the exercise of production control, and oddly enough, it also falls on the shoulders of the applicant himself. It must ensure that production controls are carried out.
3) This is the testing of samples and products, there are several options, that is, the same applicant has the right to use any laboratories, both voluntary testing and accredited testing laboratories, which means that it is possible to use both production laboratories, and non-accredited laboratories, and an accredited laboratory.
4) Acceptance of the registration of the declaration of conformity. Here again, the applicant makes a declaration and registers.
5) The application of a single sign of treatment, here again, the applicant applies a sign of treatment to their products, in other words, scheme 1D implies that all responsibility lies with the applicant himself, he performs almost all actions and is free to choose how to test his samples.
Now a few words about responsibility, we have a separate video on this subject, if you are interested, you can watch it. But in short, the responsibility is:
1) In the loss of your document
2) A fine of 50 to 300 thousand for legal entities
Let's move on to the next point. The tests are what we will be most interested in, and this is the reason why the 1D scheme is a time bomb. How can you test your products in order to accept the declaration?
There are actually two ways. To put it crudely, we immediately reject accredited laboratories, because this scheme will already be 3D. And we will be interested only in the test reports from the manufacturer itself, and the second option is the test reports in a non-accredited laboratory on the territory of the Russian Federation.
Let's go a little bit on the first point. and yes, indeed, protocols from the manufacturer can be recognized on the territory of the Russian Federation, used as an evidence base for registration of the declaration of conformity, we even have a letter from the Ministry of Industry and Trade on this subject, in which it is written in black and white that this can be done. You can read the letter in front of your eyes if it will be on the link below the video. Well, the second option is to use a non-accredited laboratory on the territory of the Russian Federation, and here are the main problems, why? Here again, we need to refer to the legislation, namely the recommendations of the FCS and the FSA of February 2019, which say that samples should be taken on the basis of either a contract with the certification body, or if the certification body is absent and the applicant registers the declaration himself, then on the basis of a letter from an accredited
Persons, namely an accredited laboratory. In other words, according to the 1D scheme, non-accredited laboratories can be used, but according to the recommendation, only accredited laboratories should be used. Here the main problem arises, but what to do and does the 1D scheme work in principle? Let's go further and try to figure out what ways you can still get your samples and get a 1D declaration, and what can we face in the future? Options for importing samples, there are still 2 of them:
1) You make a letter from a non-accredited laboratory and try to pass through customs with it, here it is a matter of chance, exactly 50/50%, customs may miss and not notice it and then in principle it will be buried all in the archives, the second option is, customs will notice and say,. If you do not have an accredited laboratory, please give another letter and it will send you to an accredited laboratory.
2) For your own needs, formally the sign will be met, you will receive a customs declaration, but if you dig deeper, then of course everything will fall apart and in principle your declaration can be canceled, although formally all the signs will be met, as a result of the problems of the scheme 1D.
It seems that there is such a scheme, but in fact, according to the law, it does not work and you can register declarations under the 1D scheme based on test reports from Russian laboratories only by violating the law in one way or another. In this regard, we have written an appeal to the Federal Accreditation Service and the Federal Customs Service. Rosaccreditation gave the following answer: "I am not me and the horse is not mine", but the recommendations of the FCS and the FSA say that you need a contract with the certification body, or a letter from an accredited laboratory. The Federal Customs Service answered 1 in 1 the same thing, that according to the recommendations, you need a contract or a letter from an accredited person and there are no other options. In the language of one of our famous characters, I want to say: "boring, girls, could come up with something original." It remains to write only to the Eurasian Economic Commission, which we have done in principle, we are waiting for an answer this month, as soon as it turns out, I will definitely bring it to you.
And that's all I have, beware of the gods of certification and may the properly executed documents arrive with you. Subscribe, like and share this video, it is not difficult for you, but it will be useful for someone.
Have a nice day." Bye
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