Tuesday, September 20, 2011

Large Scale Exporters doubts on barcode dt.21.9.2011

We would like to understand which of the following case we should consider for compliance:
Case 1 - All goods manufactured on and after 1st October should carry the label following GS1 guidelines OR
Case 2 - All Shippers / Pallets packed on and after 1st October should carry the label following GS1 guidelines OR
Case 3 - All Shippers / Pallets dispatched from factory on and after 1st October should carry the label following GS1 guidelines OR
Case 4 - All Shippers / Pallets reached customs on and after 1st October should carry the label following GS1 guidelines

Forwarding letter of Pharmexcil for Merchant Exporter Representation


Shri J.S.Deepak, IAS
Joint Secretary
Dept. of Commerce
Ministry of Commerce & Industry
New Delhi
 Dear Sir, I am herewith forwarding the representation(copy enclosed) received from one of our member (merchant exporter) and we request you to kindly attend to their representation on Barcode issue. Several merchant exporters are likely to face this issue. At present, there are about 1300 merchant exporters with Pharmexcil. As the date of implementation is nearing, they are apprehending total loss of their export business. For your attention and kind consideration. Thanking you, Yours faithfully, Dr.P.V.AppajiExecutive Director CC: Shri Rajeev Kher, IAS,Additional Secretary, Department of Commerce,Ministry of Commerce & Industry,Govt. of India.       Ms.Mridul Jain,Director,Department of Commerce,Ministry of Commerce & Industry, Govt. of India
       Shri Smitesh Shah,Chairman,Pharmexcil
       Shri N.R.Munjal,Vice Chairman, Pharmexcil
       Shri Devang Shah,COA Member,Pharmexcil representing Merchant Exporters

Copy of Representation:
The Jt. DGFT                                                                                                       September 14, 2011

Dear Sir,

Ref : Barcoding – Tracing & Tracking of Pharma Export Consignments

We as Merchant Exporters  would like to have clarification on some points in the Captioned matter.

As you are aware, the new system proposed to be introduced from 1.10.2011 ,vide Public Notice No. 59(RE-2010)/2009-2014   is primarily applicable to Pharmaceutical  manufacturers.

Indeed, as Merchant Exporters, we also get certain products manufactured , through Supporting manufacturers, wherein the new system would be followed by us as well through the supporting manufacturers. However, quite often, we also buy goods from local markets (through dealers/authorized agents/ retailers/etc..). Many of those Goods DO NOT have Barcodes since the local law does not require them. It is with reference to such local packs that this letter deals.

1)      Having bought such goods from traders, we / our suppliers  do not have any locus standi to tamper with the pack so as to put the Barcodes. Further, there is no local rule requiring such Barcoding.

2)      While exporting goods, many a times, we have to pack 8 to 10 products in one shipper since each item is of very small quantity & size so that sending them separately would mean very small shippers in big numbers. There is a threat of pilferage / Loss. So having packed multiple items in one bigger Shipper, how can one bar code that Shipper ?

In the foregoing circumstances, it is requested that until the time Barcode rule is locally made applicable, Merchant exporters be permitted to export the local packs even if they do not bear the Barcodes. Indeed, there is a very good system in place for easy tracing & tracking of local packs since , as per law, those packs inter alia  carry the following :

Batch No., Mfg. dt., Expiry date, manufacturers name & address & Mfg. Licence Nos.

Further, all the Pharma consignments are checked by the office of Asst. Drug Controller both at the Air as well as Sea Ports. There ,therefore, is adequate control in place over such exports.

Should you not still be convinced, we request you to grant us personal hearing.

Thanking You,
Yours Sincerely,
Kamlesh Shah
M/s M.T.Madon Exports