Мнения и предложения по внедрению кодов электронного надзора за предварительно упакованными пищевыми продуктами

Some opinions and suggestions from Zong Qinghou, Chairman and General Manager of Hangzhou Wahaha Group Co., Ltd., regarding the implementation of electronic supervision codes on prepackaged food products.

On December 4, 2007, the website of the General Administration of Quality Supervision, Inspection and Quarantine published the "Notice on Implementing Electronic Supervision of Product Quality in Accordance with the Special Provisions of the State Council on Strengthening the Supervision and Administration of the Safety of Food and Other Products" (Guo Zhi Jian Zhi Lian [2007] No. 582). In that notice, "the General Administration of Quality Supervision, Inspection and Quarantine, the Ministry of Commerce and the State Administration for Industry and Commerce have decided to implement electronic supervision over key products subject to industrial product production licence and compulsory product certification (CCC) management". It requires that "production enterprises of key products must use electronic supervision codes on product packaging before they may leave the factory for sale.

", This measure has a huge impact on prepackaged food producers; in effect, it establishes a new administrative licence and market access condition.

Having carefully studied this notice, together with the documents successively issued by the General Administration of Quality Supervision, Inspection and Quarantine relating to the "Product Quality Electronic Supervision Network" — namely the Implementation Opinions on Code Assignment for the Product Quality Electronic Supervision Network (trial), the Guide to Querying Products Registered with the Product Quality Electronic Supervision Network (trial), the Guiding Opinions on Information Notification Work for Quality Supervision and Law-Enforcement Action against Counterfeiting under the Product Quality Electronic Supervision Network (trial), and the Notice on the Deployment of Work to Advance the Product Quality Electronic Supervision Network in 2008 (Guo Zhi Jian Zhi [2008] No. 83) — and proceeding from the standpoint of genuinely promoting food safety supervision and administration, we put forward the following opinions and suggestions on the necessity and feasibility of implementing electronic supervision codes on prepackaged food products.

I. The "Product Quality Electronic Supervision Network" and food safety supervision and its impact on consumers

1. Whether the "Product Quality Electronic Supervision Network" can genuinely raise the level of food safety supervision in our country is open to question. Its advantages and disadvantages require careful consideration. The product quality information recorded and provided by the "electronic supervision code" mainly includes: enterprise name, product trademark, product brand, shelf life, production date, inspection certificate number, production licence number, compulsory product certification (CCC) certificate number, and so on. All of this information already appears on the labels of prepackaged food, and by reading the label consumers can obtain the relevant information conveniently and quickly.

If supervisory departments need to monitor product flow, sales and so on, they can fully achieve this by checking enterprises' sales records and ledgers; whether it is necessary to build yet another information-provision system that is essentially duplicative is questionable. We suggest that priority should first be given to fully implementing and improving the existing quality management systems, and that the frequent introduction of new supervisory systems should be avoided as far as possible. The differences in production among enterprises in different industries must also be respected, and simplistic one-size-fits-all approaches should be avoided as far as possible.

1. According to the introduction to the "Product Quality Electronic Supervision Network", the function of the network is "to assign a 'supervision code' to every small packaged product that a consumer is able to purchase, and to use the 'supervision code' as an index to record information on the entire life cycle of that product in a database". For certain products, such as automobiles, televisions and refrigerators, supervising small packages may be an effective means of managing product quality. But for prepackaged food, apart from greatly increasing operational difficulty and cost, its genuinely positive significance for food safety supervision is highly questionable. Food production has its own particular characteristics: a single batch may contain tens of thousands or hundreds of thousands of small packages. The safety of one individual retail package (bottle or carton) does not represent the safety of that batch of food. Even if the "code assignment" information on that retail package is correct, it cannot represent the safety of that batch of food. The current food quality and safety management system supervises by production batch, which has been proven effective in practice.
2. The State Council has issued a number of policies and regulations to raise the level of food safety, with the aim of looking after the interests of the broad body of food consumers. The management measure introduced by Document No. 582 has, however, a complex and tangled impact on all the parties concerned. In order to implement this regulation, production enterprises — especially food producers with enormous numbers of small packages — need to invest huge sums of money in equipment modification, the deployment of manpower, the purchase of consumables and the acquisition of an almost astronomical number of electronic supervision codes. For food enterprises whose products have low added value and which are already running on thin margins, this will create enormous cost pressure;

and consumers, besides having to bear part of the costs that production enterprises will inevitably pass on, would also have to pay telephone charges, SMS charges or internet access fees if they wanted to use this supervision system to distinguish whether a product is genuine (rather than whether it is safe). The implementation of the electronic supervision code therefore not only fails to help improve the supervision of product safety, and of food safety in particular, but will instead add fuel to the recent sustained rise in food prices.

1. According to Document Guo Zhi Jian Zhi [2008] No. 83, "in view of the diversity of product packaging and the technical difficulty of code printing, and on the basis of the original principle of assigning one code to one product (abbreviated as one code per item), the code assignment methods are divided into two categories, A and B. Category A is one code per item, while for Category B the level of packaging of each product to which the code is assigned is decided by the enterprise itself". Although 24 categories of food have been included in the Category B code assignment scope, that is, in principle the code may for the time being be applied to the next higher level of bulk packaging (the outer carton), this form of code assignment will not play any positive role in safeguarding the rights and interests of ordinary consumers, because ordinary consumers generally do not buy prepackaged food by the whole carton but for the most part make small occasional purchases; in addition, after many supermarkets and other retail terminals open the cartons and put the small packaged foods inside onto the shelves, the outer packaging cartons are disposed of as rubbish at the same time, so the electronic supervision codes on the outer cartons become useless.

II. Technical difficulties in implementing Document Guo Zhi Jian Zhi Lian [2007] No. 582

The enormous difficulties that food enterprises will face if they implement this regulation are set out in detail below:

1. The text of the regulation provides that in the early stage the 'electronic supervision code' may be applied as a label. In reality, many existing product packages are already printed full-bleed, leaving no space at all for a label to be added; a considerable amount of time is needed to redesign the entire package before implementation is possible. Some small packages may have no room to accommodate an electronic supervision code even after redesign.
2. An enterprise may have as many as several hundred different small packages; implementing this regulation involves changes to package design, ordering, inventory control and much else, and requires a considerable transition period. It is simply impossible to complete within six months of the date of publication, especially in the absence of clear implementing guidelines (local quality and technical supervision bureaus are still unable to guide enterprises in carrying out this work, and it is also unclear when they will be able to do so).
3. Implementation of this regulation involves production enterprises, the packaging printing industry, manufacturers of labelling (printing) equipment, CITIC Guo Jian Information Technology Co., Ltd. and other parties, as well as local quality and technical supervision departments; neither schedule control nor mastery of technical capability can be achieved through the food producer's own efforts alone. A great deal of coordination work across many parties is involved, so it is unreasonable to impose penalty requirements on production enterprises alone.
4. For the vast quantity of packaging materials in all their various forms, the great majority of packaging material printers currently do not have the capability or equipment to pre-print or inkjet-print the electronic supervision code in advance, so food producers would have to inkjet-print this supervision code during production, and every production line would have to purchase and install dedicated variable-code inkjet printing equipment. With hundreds of thousands of food producers across the country and production lines numbering in the millions or even tens of millions, the equipment investment and additional operating costs would be astonishing.
5. There is an extremely wide variety of food products — tens of millions of styles and varieties and consumer units numbering in the billions or tens of billions — which will require hundreds of billions of items of information. We are also deeply concerned about whether the current design of the electronic supervision network system can guarantee timely day-to-day data maintenance and the safe operation of the database. If technical or other factors were to prevent enterprises from entering information and activating barcodes in time, the products concerned could not be launched and sold as planned; or if consumers were unable to query the correct information and wrongly assumed that what they had bought was counterfeit, enterprises would have to expend enormous resources to resolve such troubles. The resulting impact on consumers' normal lives and on social harmony and stability is impossible to estimate.
6. The supply lead times for beverage product packaging are all fairly long, ranging from half a year to two years. The loss rate for packaging materials in general is 1%, while printing losses can reach 10-15%; consequently, for beverage enterprises with large output volumes, the resulting online detection and rejection of invalid and missing electronic supervision codes presents considerable difficulty.
7. Production lines differ enormously between different production enterprises; how can it be guaranteed that all of them will have matching labelling equipment within a short period? If manual labelling were adopted, it would be completely unrealistic for the high-speed production lines of the food industry.
8. Under the provisions of this regulation, the supervision code information that enterprises upload to the electronic supervision network database covers outbound product batch information, quantity, product specifications, wholesaler names, wholesale sales regions and other content, so CITIC Guo Jian would be able to grasp with ease each enterprise's trade secrets such as product varieties, output, distributors and sales regions. As a corporate entity, does the company have such a right, and is its legal basis sufficient? How can it be guaranteed that these secrets will not be used unlawfully? If they are unlawfully disclosed, how will legal liability be borne? These are also questions that every food producer is concerned about and worried about.

On the basis of the above opinions, we believe that if this regulation were implemented for prepackaged food it would consume a great deal of social resources and greatly increase social costs, and would instead add fuel to the recent sustained rise in food prices; it would be detrimental to the building of a conservation-oriented society called for by the Party Central Committee, while failing to achieve the expected effect in promoting product quality and, in particular, the level of prepackaged food safety. The necessity and technical feasibility of implementing the electronic supervision code system in the field of prepackaged food products therefore warrant fresh examination and it should not be pushed through hastily. We earnestly request that the relevant leadership departments of the government give the matter careful consideration, and we suggest that the state take account of the actual circumstances of prepackaged food enterprises and prepackaged food products, and that the food and beverage industry should suspend implementation of the electronic supervision code system.

If implementation must go ahead in the near term, we suggest that pilot programmes be carried out on a broader scale, and that gradual nationwide extension to the food industry be considered only when the technology is fully mature and it can be guaranteed that enterprises' trade secrets are protected, that enterprises' production capacity is not affected, that production costs are not substantially increased, and that the system can genuinely play a major role in ensuring food safety. A simplistic one-size-fits-all approach must absolutely be avoided.

——This article is reprinted from China Packaging Network (pack.cn), original link: http://news.pack.cn/show-362214.html