Discussion on the Management of Manufacturing License for Loader Products

To standardize the manufacturing licensing work of special mechanical and electrical equipment and ensure the manufacturing quality and safety technical performance of such equipment, the General Administration of Quality Supervision, Inspection and Quarantine of the People's Republic of China promulgated and implemented the "Trial Rules for Manufacturing Licensing of Special Mechanical and Electrical Equipment" on June 17, 2003. These rules clearly include construction machinery products such as loaders, excavators and loaders in the special equipment manufacturing licensing directory. At the same time, the General Administration of Quality Supervision, Inspection and Quarantine of the People's Republic of China requires that as of June 1, 2004, all products included in the special equipment license directory must obtain the corresponding manufacturing license; otherwise, enterprises will not be allowed to produce, sell, use or maintain the products. The implementation of this rule has sparked considerable controversy within the construction machinery industry. There are many complaints, such as whether it is necessary to implement such administrative management for products like loaders, whether the management model is reasonable, whether it will increase the burden on enterprises, and whether it can play the intended role, etc. At present, some enterprises have obtained the manufacturing unit license. Judging from the implementation process and effect, there are still many problems, and the management model and methods still need to be explored.

Loaders and special equipment

There was once controversy over whether loader products should be classified as special equipment. However, from the current relevant national standards and related regulations and rules in our country, it is relatively clear that loaders are classified as special equipment. Article 3.4 of the national standard "Technical Requirements for Safety Inspection of Motor Vehicles within Factories" (GB/T16178-1996) stipulates that large wheeled self-propelled special machinery with a total mass of 5000kg(including 5000kg) or more, equipped with pneumatic tires and capable of self-propelled operation, is classified as factory motor vehicles, and loaders fall into this category of self-propelled special machinery. The "Regulations on Quality Supervision and Safety Inspection of Special Equipment" implemented in 2000 further included motor vehicles within the factory under the management of special equipment. Therefore, loaders should be classified as special equipment. However, in accordance with the original national regulations, special equipment is subject to production license management and safety recognition certificate management. However, the "Product Work Manual for the Implementation of Industrial Product Production License Management" issued by the state does not include loader products. Therefore, loaders are not subject to production license management. Since 1999, the state has implemented safety certification for loader products, but it has not been truly promoted. Few people in the industry regard loaders as special equipment. The "Trial Rules for Manufacturing License of Special Equipment of Mechanical and Electrical Category" has included loader products in the directory of special equipment manufacturing license, and it is a manufacturing unit license accepted by the state. Therefore, before the implementation of the "Trial Rules for the Manufacturing License of Special Equipment for Mechanical and Electrical Products" (before June 17, 2003), although loaders were classified as special equipment, they were not truly included in the regulatory scope of special equipment.

The background of implementing manufacturing licenses for loaders

2.1 Strengthen the management of special equipment

It is extremely necessary for the state to implement special management over equipment involving life safety and with high risks to ensure the quality and safe use of these devices, prevent and reduce accidents, and protect the lives and property of the people. Since the 1950s, China has begun to implement administrative management over boilers, pressure vessels and other equipment, establishing specialized management institutions and systems, and promulgating relevant laws, regulations, systems and standards. With the rapid development of society and economy, the number of special equipment involving life safety and with high risks has increased dramatically, and their application scope has expanded day by day. In addition, with the continuous changes in the national economic system and government management system, the original management system, management methods and coverage of special equipment can no longer meet or adapt to the requirements of modern economic and social development. For this reason, the state has reformed the management of special equipment. Since 2003, it has promulgated and implemented more than ten regulations and systems, including the "Regulations on Safety Supervision of Special Equipment" (State Council Decree No. 373 of 2003) and the "Interim Measures for the Implementation of Administrative Licensing for Special Equipment" (Guo Jian Zhi Guo [2003] No. 172). At present, dozens of regulations, systems and safety technical specifications concerning special equipment are being formulated or have been planned to be formulated. The state will gradually establish a legal, regulatory and safety technical specification system that is suitable for the management of special equipment.

2.2 Build a trade barrier system

With the continuous development of economic globalization and trade liberalization, in international trade, non-tariff barriers mainly composed of technical trade barriers have gradually replaced tariff barriers and become the main obstacle affecting international trade. They are also the main means for many countries (especially developed countries) to carry out trade protection.

After China's accession to the WTO, in accordance with the requirements of WTO rules, tariffs will gradually be reduced or abolished, and a large number of foreign products will enter the market, causing certain impacts and influences on domestic industries and product markets. Meanwhile, our country's products have encountered a large number of technical trade barriers abroad, which has had a significant impact on product exports. According to statistics from the Ministry of Commerce, in 2002, 71% of China's export enterprises and 39% of their export products encountered foreign technical barriers, resulting in a direct economic impact of 17 billion US dollars. With the increase of foreign trade, more and more technical trade barriers will be encountered. Therefore, in order to better deal with technical trade barriers and promote the sound development of international trade, we should do two aspects of work: first, try to break through foreign technical barriers; second, build our own technical barriers and make reasonable and legal use of them. The current production license system, compulsory certification system, administrative licensing system for special equipment, food quality and safety certification system, etc., have become important means for us to carry out trade protection in a reasonable and legal manner. The market access system in our country has also been initially established. One of the purposes is to implement special equipment management for products such as loaders, impose market access restrictions, and build technical trade barriers. The model and conditions for the manufacturing license of loaders

3.1 Manufacturing License Model

According to the "Trial Rules for Manufacturing License of Special Mechanical and Electrical Equipment", there are two ways to obtain manufacturing licenses for special mechanical and electrical equipment: product type testing and manufacturing unit license. The acceptance methods are divided into: national acceptance and provincial acceptance. The licensing model for loader products is a manufacturing unit license accepted by the state. The basic procedures for its manufacturing license are: application, acceptance, type testing, review of manufacturing conditions, examination and issuance of license, and announcement. The application acceptance, examination and issuance of certificates, and announcement shall be handled by the safety inspection institutions of the General Administration of Quality Supervision, Inspection and Quarantine of the People's Republic of China. The type testing and manufacturing condition review shall be conducted by the type testing institutions and review institutions approved by the safety inspection institutions of the General Administration of Quality Supervision, Inspection and Quarantine of the People's Republic of China. At present, there are two institutions qualified to conduct type tests and reviews of loader products: the National Quality Supervision and Inspection Center for Construction Machinery and the National Supervision and Inspection Center for Construction and Urban Construction Machinery.

3.2 Manufacturing License Conditions

The "Trial Rules for Manufacturing License of Special Equipment for Mechanical and Electrical Products" specifically stipulates the basic conditions that manufacturing enterprises of various products should meet for manufacturing licenses, including the enterprise having legal person status, holding a valid business license issued by the administrative department for industry and commerce, registered capital, personnel requirements, production conditions, technical documents, quality management requirements, etc. The basic conditions for the license of the manufacturing unit of the loader manufacturing enterprise are shown in the table below.

Some Views on the manufacturing license of loader products

It should be said that the intention of including loaders in the management of special equipment is good. Strengthen equipment management and enhance the safety technical performance and quality of products; Standardize and enhance industry access and market access conditions; It is necessary to rationally construct trade barriers and so on, but there are areas that need to be explored in terms of specific management models and methods.