Some opinions and suggestions on the implementation of electronic monitoring codes for prepackaged food products

Zong Qinghou, Chairman and General Manager of Hangzhou Wahaha Group Co., Ltd.

On December 4, 2007, the website of the General Administration of Quality Supervision, Inspection and Quarantine of the People's Republic of China issued the “Special Provisions of the State Council on Strengthening the Supervision and Administration of the Safety of Food and Other Products” issued by the National Quality Inspection and Quarantine Association (2007) No. 582. The implementation of electronic product quality supervision notice."


In the notice, "AQSIQ, the Ministry of Commerce, and the State Administration for Industry and Commerce decided to implement electronic supervision on key products that incorporate industrial product production licenses and Compulsory Product Certification (CCC) management." It is required that “key product manufacturers must use electronic monitoring codes on product packaging before they can be sold.” This measure has a huge impact on pre-packaged food production companies. Actually, it sets new administrative licenses and market access conditions. Conscientiously studied this notice, and issued by the General Administration of Quality Supervision, Inspection and Quarantine, "Implementation Opinions on the Implementation of the Product Quality Electronic Supervision Network Enforcement Work" (Provisional), "Product Quality Electronic Supervision Web Access Product Inquiry Guide" "(Trial)" and "Guidelines for Quality Supervision and Anti-Counterfeiting Information Notification of Product Quality Electronic Supervision Network" (Trial), (Quality Inspection No. [2008] No. 83) "On the deployment of product quality electronic supervision network promotion work in 2008 On the basis of the Circular and other documents, the following opinions and suggestions are made on the necessity and feasibility of implementing electronic surveillance codes in pre-packaged food products from the perspective of effectively promoting food safety supervision and management.

I. “Product Quality Electronic Supervision Network” and Food Safety Supervision and Its Impact on Consumers

1. Whether or not the “Product Quality Electronic Supervision Network” can really improve China's food safety supervision level is debatable. Its advantages and disadvantages need careful consideration. "Electronic monitoring code" records and provides product quality information mainly includes: business name, product trademark, product brand, shelf life, production date, inspection certificate number, production license number, mandatory product certification (CCC) certificate number. All of this information is already on the label of pre-packaged foods. By reading the labels, consumers can get relevant information quickly and easily. If the supervisory department needs to monitor the flow of products, sales, etc., it can completely achieve the purpose by checking the company’s sales records, account books, etc., and whether it is necessary to establish a substantially repeatable information provision system. We suggest that we should first consider fully implementing and improving the existing quality management system and try to avoid introducing new supervision systems frequently. And we must respect the differences in production of companies in different industries and try to avoid a simple one-size-fits-all approach.

2. According to the introduction of “Product Quality Electronic Supervision Network”, the function of the network is to “given the unique “supervisory code” for each minimum consumer packaged product that a consumer can purchase, and index the “supervisory code” in the database. Record the entire life cycle of this product." For some products, such as cars, televisions, refrigerators, etc., supervision of the minimum packaging may be an effective means of managing product quality. But for pre-packaged foods, besides greatly increasing the difficulty and cost of operation, its true positive significance for food safety supervision is highly debatable. Because food production has its own characteristics, a batch can have tens or hundreds of thousands of minimum packaging. The safety of an independent sales package (bottle or box) does not represent the safety of the batch of food. Even if the sales package's “encoded” information is correct, it cannot represent the safety of the batch of food. The current food quality and safety management system is supervised according to production batches and has been proven to be effective by practice.

3. The State Council has issued a number of policies and regulations to improve the level of food safety in order to focus on the interests of the food consumers. At present, the management measures introduced in No. 582 have an intricate and complex influence on the relevant parties. In order to implement this regulation, manufacturers, especially those with a large minimum amount of packaging, need to invest huge sums of money for equipment modification, manpower deployment, purchase of consumables, and acquisition of electronic monitoring codes that are almost astronomical. For food companies with small added value and already low profit, it will cause huge cost pressures; in addition to the fact that consumers need to bear some of the costs that are inevitably passed on by production companies, if they want to use the regulatory system to identify product authenticity ( It is not product security). Telephone charges, text messaging fees, or internet fees are also required. Therefore, the implementation of the electronic monitoring code will not only help improve the supervision of product safety, especially food safety, but will also play a role in fueling the recent rising food prices.

4. According to National Quality Inspection Regulation No. [2008] No. 83, “according to the diversity of product packaging and the technical difficulty of the coded printing, based on the principle that a product is given a code (referred to as a product and a code), The coding method is divided into A and B categories. Class A is a product and a code. Class B code assignment is determined by the company on a large-scale packaging basis for each product. Although there are 24 categories of foods that have been included in Class B The scope, that is, in principle, can be temporarily assigned to a large package (outer carton) at the next level. However, this form of coding does not have any positive effect on the protection of ordinary consumer rights, because ordinary consumers generally do not buy whole prepackaged foods in whole boxes, most of which are only sporadic purchases; in addition, many supermarkets and other sales terminals are unboxing. After the small packaged foods in the box are placed on the shelves, the outer packagings are also disposed of as garbage. Therefore, the electronic monitoring code on the outer carton does not work.

Second, the implementation of the quality of the National Quality and Technical Association (2007) 582 of the technical problems

Food companies will face unprecedented difficulties if they implement this regulation, as follows:

1, the provisions of the provisions of 'electronic monitoring code' can be coded in the early stage. In fact, many existing product packagings have been printed in full version, there is no place to paste, and it takes quite a while to redesign the entire package before it can be implemented. Some small packages may not have room to contain electronic surveillance codes even if they are redesigned.

2. There will be as many as hundreds of different minimum packaging companies. The implementation of this regulation will involve changes in packaging design, ordering, inventory control, etc., requiring considerable conversion time, not exceeding six months from the release date. Completion, not to mention the absence of clear guidance on the premise of the premise (local quality and technical supervision can not guide enterprises to carry out this work, and when it can be carried out specifically when it is not clear).

3. The implementation of this regulation involves several parties such as manufacturing enterprises, packaging and printing industry, paste (printing) equipment manufacturers and CITIC Guojian Information Technology Co., Ltd., as well as local quality and technical supervision departments. Whether it is time control or technical ability control, It is not food production companies that can do it alone. Involving a great deal of coordination work in all aspects, it is unreasonable to impose penalties only on production companies.

4, for a large number of various forms of packaging materials, most of the current packaging printers do not have the ability to print or print electronic monitoring code in advance or equipment, require food production companies in the production process of inkjet printing this monitoring code Each production line should purchase and install a special variable code printing equipment. Hundreds of thousands of food production companies in the country, with production lines of millions or even tens of millions, will have amazing equipment investment and additional operating costs.

5. There are many kinds of food products, tens of thousands of kinds of color varieties, hundreds of millions of billions of consumption units, will need hundreds of billions of information, the current electronic supervision network system design can ensure daily We are also deeply concerned about the timely maintenance of data and the safe operation of the database. For example, due to technical or other factors, companies cannot enter information or activate barcodes in time. Related products cannot be marketed as planned; or consumers are unable to find the correct information and mistakenly believe that the purchased products are counterfeit and companies have to spend huge amounts of money. Resources solve these problems. The resulting impact on consumers' normal lives and social harmony and stability is difficult to estimate.

6, the beverage product packaging delivery cycle is longer, ranging from six months to two years. The loss rate of general product packaging materials is 1%, and the printing loss can reach 10-15%. Therefore, for large-beverage beverage companies, the resulting electronic monitoring code waste codes, missing code online detection, and rejection are quite similar. Big difficulty.

7. The production lines of different production companies have great differences. How to ensure that there will be matching stickers in the short term? If manual labeling is used, it is completely unrealistic for high-speed production lines in the food industry.

8. In accordance with the provisions of the regulation, the supervision code information uploaded by the company to the electronic supervision network database covers the batch information, quantity, product specifications, wholesaler name, wholesale sales area, etc. of the outbound product, CITIC Guojian Company will be able to easily grasp Each company's product variety, output, distributors, sales areas and other trade secrets. As a corporate entity, does the company have such rights and is its legal basis sufficient? How to ensure that these secrets are not used illegally? How to bear legal liability if it is illegally leaked? These are also the concerns and concerns of each food production company.

Based on the above opinions, we believe that if this regulation is implemented in pre-packaged foods, it will consume a lot of social resources and greatly increase social costs. Instead, it will contribute to the recent rising food prices, and is not conducive to the Party Central Committee's call for savings. The establishment of a type of society will not achieve the desired effect in promoting product quality, especially the level of prepackaged food safety. Therefore, the implementation of an electronic monitoring code system in the field of prepackaged food products is worth revisiting due to its necessity and technical feasibility. Demonstration should not be promoted in a hurry, and the relevant government departments are urged to consider it carefully. At the same time, it is recommended that the state consider the actual situation of prepackaged food companies and prepackaged food products. The food and beverage industry should suspend the implementation of the electronic monitoring code system. If it is imperative to implement it in the near future, we recommend that pilots be conducted within a larger scope until the technology is fully matured, and that it can ensure the company’s commercial confidentiality, does not affect the production capacity of the company, does not cause a substantial increase in the production cost of the enterprise, and ensures food safety. It can indeed play a big role in such circumstances, and then consider the gradual promotion of the national food industry, do not simply a one-size-fits-all.

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