Consumer Electronics, Regulatory Affairs, Retail
The EBA welcomes the adoption of Governmental Resolution N195 from 10 March 2021, which amended the Resolution №1184 on the form, description, and rules for applying the national conformity mark of compliance with technical regulations (Mark).
The EBA has repeatedly drawn the attention of state authorities to the need to resolve two key points regarding the rules of application of the Mark. First, paragraph 3 of Resolution №1184 provided that the Mark could be flat or embossed and performed in two contrasting colors. At the same time, such editing made it impossible to apply the embossing labeling method, because in the case of it the Mark reflected the color of the product on which it was applied and therefore was performed in one color. Second, paragraph 4 of Resolution №1184 stipulated that in the event of a reduction or increase in the size of the Mark, the proportions of its shape had to be observed. At the same time, due to various technological features and methods of applying the Mark, e.g. made by “sleeve” technology, 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.
The EBA sent a number of official positions, held several meetings, and actively cooperated with government agencies in order to adopt the necessary changes as soon as possible in order to address the above issues.
Therefore, the EBA is grateful to the Ministry of Economic Development, Trade and Agriculture of Ukraine, and other involved government agencies for adopting Governmental Resolution N195 and looks forward to the further constructive cooperation aimed at improving regulatory requirements and the business environment in Ukraine in general.
If you need additional information, please contact Viktoriia.Kulykova@eba.com.ua, Manager of the EBA Consumer Electronics Committee.