From August 1 to 30, 2024, the State Administration for Market Regulation (SAMR) sought public comments on the Implementation Opinions on Promoting Quality and Safety Traceability of Key Industrial Products (Draft for Comments). This draft document details the implementation of the requirements indicated in the Outline for Building a Great Power of Quality, which calls for the establishment of a quality and safety traceability system for key products. The system aims to strengthen the prevention and control of quality and safety risks throughout the entire production process, improve product quality, and accelerate the construction of a unified national market.

The draft outlines the following goals:

  1. By the end of 2024, quality and safety traceability will be implemented for key industrial products that fall under production license and compulsory certification management, including electric wires and cables, gas appliances, electric bicycles, and cold-rolled ribbed steel bars;
  2. By the end of 2025, quality and safety traceability will be extended to all products under production license and compulsory certification management;
  • By the end of 2027, quality and safety traceability will be implemented for key industrial products that impact personal health, life, and property safety, and are subject to mandatory national standards.

To implement the traceability system, the document mandates the use of four types of traceability codes: product barcodes, IoT identification codes (Ecode), digital identity codes, and CCC certification codes. These codes will serve as carriers of traceability data, allowing production units to assign codes at the source. Each subsequent link in the supply chain, from circulation and sales to end consumers, will recognize and utilize these codes. Through these codes, key quality information of products can be tracked throughout the entire lifecycle of a product, from production and sales to usage.

SAMR will establish unified general requirements for the data and technical solutions needed for quality and safety traceability. These will include specifications for traceability data content, coding methods, and system interface specifications. SAMR also plans to develop a national platform for the quality and safety traceability of key industrial products, which will collect traceability information, provide data support for local regulatory departments to monitor product quality and safety, and offer the public access to traceability information for products.

In terms of the traceability content, manufacturers will be required to provide:

  1. Data on the production unit, including the enterprise’s name, unified social credit code, address, contact information, and business license;
  2. Product information, including product name, type, specifications and models, production date, warranty period, factory number/batch number/serial number, applicable standards, production license number/compulsory certification certificate number, and factory inspection report/type inspection report;
  • Flow information, including sales time, buyer’s name, buyer’s address, and contact information.

To encourage the implementation of the traceability system, the document proposes several measures:

  1. Incorporating the quality and safety traceability requirements for key industrial products into the development and revision of national and sector standards;
  2. Allowing industry associations and social organizations to use quality and safety traceability as an important factor when evaluating the quality, credit and safety levels of enterprises within the industry;
  • Encouraging state-owned enterprises and large entities to consider quality and safety traceability as a significant factor in bidding, procurement, and supplier selection processes.

Overall, this document reflects the Chinese government’s efforts to ensure product quality through traceability systems, which is a crucial step in addressing the current market’s quality inconsistencies. However, the requirement for manufacturers to report detailed traceability data for each product or batch may increase the compliance burden on enterprises. As a result, relevant production and sales companies should take proactive steps to prepare for these upcoming changes.