Consumer Electronics, Regulatory Affairs
The EBA has repeatedly drawn the attention of state authorities to the need to amend Governmental Resolution №1184 on the form, description, and rules for applying the national conformity mark of compliance with technical regulations (Mark). In particular, the EBA focused on two key points that need to be addressed.
1) Paragraph 3 of the Resolution №1184 provides that the Mark may be flat or embossed and is made in two contrasting colors. At the same time, such editing makes it impossible to apply the embossing labeling method, because in case of it the Mark reflects the color of the product on which it was applied and is therefore performed in one color.
2) Paragraph 4 of the Resolution №1184 stipulates that in the event of a reduction or increase in the size of the Mark, the proportions of its shape must be observed. At the same time, due to various technological features and methods of applying the Mark, there may be a slight deformation of the shape of the Mark.
As a result, due to the existence of cases of insignificant deformation of the Mark or application of the embossing method for the relief image of the Mark, there were regular cases of application of fines and / or restrictive measures to business entities due to non-compliance of the Mark with established legislation requirements.
Therefore, the EBA held several meetings and addressed official letters to relevant Governmental agencies with a request to facilitate the development of a resolution on amendments to the Resolution №1184 aimed to solve the abovementioned problems.
The EBA is grateful to the Ministry of Economic Development, Trade and Agriculture of Ukraine for developing and publishing the relevant draft resolution for public discussion and looks forward to furthering constructive cooperation with a view to its adoption as soon as possible.
If you need additional information, please contact Viktoriia.Kulykova@eba.com.ua, Manager of the EBA Consumer Electronics Committee.