Come and find out the differences between the old and the new RGCP!

On May 4, 2021, was published the new Ordinance No. 200 OF APRIL 29, 2021, approving the General Requirements for Product Certification (RGCP).

The new RGCP replaces Ordinance No. 118 and several complementary ones. Inmetro published the new RGCP to update obsolete items and consolidate the various ordinances and amendments to make it more transparent for everyone who needs certification and/or uses the RGCP during their workdays.

After all, what has changed?

We highlighted the main points for you to pay attention to:

 

For batch certifications (model 1b), in addition to the manufacturing batches identification, family identification, and model of the certified product, among others, the identification of the Import Permit number (LI or LPCO) shall be included in the certificate of conformity;

 

Notifications for suspension or cancellation of certification shall be notified exclusively through electronic means, to the email address [email protected], for objects subject to the Object Registration with Inmetro, or to the email [email protected], for objects not subject to the Object Registration with Inmetro. When the notice of suspension or cancellation refers to an object whose Conformity Assessment Requirements have been established by Inmetro, by the delegation of another regulator, the sending of the notice to Inmetro/Dconf shall be accompanied by evidence that the regulatory body was also communicated;

 

The definition for commercial designation was inserted (in the way it is identified in the market, and commercial reference code(s) of the versions, when present on the product and/or packaging;): “ …the commercial designation of the model means how the product will be identified in the market.”;

 

It is explicit in the RGCP that the scopes that do not use RGCP will be gradually adapted as they undergo improvement. Additionally, regardless of whether the scope does not yet cover the RGCP, the requirements related to the items “Certificate Request,” “Issuance of the Certificate,” “Certificate of Conformity,” Activities Performed by OCP accredited by an MLA member of IAF,” “Transfer of Certification,” “Termination of the Certification,” “Conformity Identification Stamp,” “Authorization to Use the Conformity Identification Stamp,” “Responsibility and Obligations,” “Market Surveillance,” “Penalties,” “Complaint,” “Annex B – Certification Repass” – shall already comply with the provisions of this RGCP.

 

All certification processes covered in the situation of these scopes that do not yet follow the RGCP shall be adequate by the OCP from the maintenance or recertification following the publication of this Ordinance, as long as these do not occur in less than six (6) months when they will still meet the conditions defined in the object-specific RAC.

NCC has a large number of scopes, among which the RGCP is the mandatory supplementary ordinance. The scopes that still do not follow the RGCP are in the study phase to also consolidate standards, improve ambiguous sentences, and update obsolete items in technical commissions created by OCPs (Product Certification Body), laboratories, and manufacturers, among others, under approval by Inmetro.

NCC is part of these study groups. We can report the high probability of inclusion in the RACs (Conformity Assessment Requirements), which still do not have the RGCP as a complementary ordinance.

RGCP Items

Some RACs have some specific features of the scope, but we can highlight the main points that all scopes that “follow” RGCP shall meet:

 

Samples shall be sealed by the OCP and sent to the ILAC, EAA, and IAAC member laboratories, not being able to accept tests previously conducted;

Audits shall follow ISO 9001 in the current version; if the manufacturer already has ISO 9001 certification, fewer items will be audited; when the manufacturer does not have ISO 9001 certification, more system items will be audited.

For the product to be certified, documents shall be sent as specified: manual, descriptive memorial, photos of all sides of the product, internal photos, and all front and back internal plates, among other documentation.

Even the certificate of conformity has rules to be followed, such as the mention of the applicant with Corporate Taxpayer’s ID (CNPJ), manufacturer, product name, brand, and characteristics, all meeting precisely one position in the form of a table, among others.

The handling of complaints shall be audited by the OCP in all locations where they occur.

 

It is essential to point out that the RGCP establishes fundamental requirements for the OCP to base itself on and check whether the applicant and the manufacturer can have their certificate active. In this way, it is a guarantee in which all sides win: the OCP, with evidence of what you really need to demand from the manufacturer; the manufacturer/requester, once having the Inmetro stamp brings reliability to your product; the end user, with the security of buying a product that is suitable and approved for use in their environment.

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Material subject to amendment(s) in case of change in the ordinance(s). Published: 07.13.21