Feasibility Study: Post-manufacturing Traceability System between the PRC and the EU, November 2008
This study, carried out during 2008, focuses on the
commercial, technical, legal and political feasibility of a post-manufacturing
traceability system along the supply chain between the People’s Republic of
China and the European Union. The
traceability system would cover product quality, safety, authenticity,
compliance as well as the manufacturing process, environmental impact and CSR-related
issues. The study highlights the fundamentals needed for such a system to be
launched, operated and sustained over the mid- to long-term.
This feasibility study was funded by the EU-China Trade
Project, Beijing, to investigate possible means to strengthen Europe’s
commercial partnership with the People’s Republic of China while enhancing the
safety level of the products manufactured in China and distributed in Europe.
The study is based on a collection of technical specifications
compiled by a group of internationally recognized experts in quality control,
quality assurance, quality management and high tech marking systems (RFID, QR
code, Data Matrix, bar code). These specifications were used to build a
demonstration model to illustrate the collective knowledge now available on
traceability systems across diverse populations of users and/or stakeholders. The demonstration
model served as a benchmark for interested parties to understand how they could
position themselves if such a system were to be available. The model has played
a useful role in demonstrating what such a system might look like in concrete
terms. It was of particular assistance in making issues clear to the different
target groups which all have distinct and different requirements from a system.
Four main key supply chain players were interviewed: Chinese manufacturers,
international buyers, authorities (including Chinese, EU and Japanese), and
consumer associations. Following feedback from a diverse range of potential
users, the model was adapted so as to accord as closely as possible to the
requirements of all the different parties.
The study results in the
following conclusions :
Technically, the system should be a 3rd party,
international database located in an independent country with hierarchically
differentiated internet access to the data dependent on the user's profile,
with a batch based numbering system based on the EPC standard and where each
and every product should be tagged individually.
Commercially, the marking cost of the products should
not exceed 3% of its FOB value, making both optical and RFID marking
technologies eligible for most products.
Legally and politically, a voluntary approach may eventually
result in such a proliferation of schemes that its purpose would probably be
defeated. The preferred approach would be a harmonised framework agreed between
the EU and the USA requiring individual product tagging.
Following
the drafting of the report the methodology, finding and recommendations were
extensively discussed with a Chinese specialist, nominated by AQSIQ, so as to ensure
a knowledgeable channel reporting directly back to the Chinese government.
Feasibility Study for a Post-manufacturing Traceability System between the PRC and the EU - Final Report