text | Xu Feng
National III upgrade has entered the middle and late stages of implementation. Diesel engine companies' national III products have been launched one after another, and the supporting facilities of host companies have gradually been complete. After passing the stage of product research and development, appraisal application has become a particularly important link.
In August 2015, the Agricultural Machinery Testing and Appraisal Headquarters issued the "Notice on Changes in Ministerial Promotion and Appraisal Information Related to Upgrade Agricultural Diesel Engine Emission Standards", clarifying the issue of product information changes involved in upgrading from National II emissions to National III emissions; with the determination of the step-by-step implementation of the upgrade of National III upgrades, the Ministry of Agriculture issued the "Notice on Doing a Good Job in Current Work on Promotion and Appraisal of Agricultural Machinery", which determined the principle of independent change.
Both documents put forward basic principles and explanations for the appraisal application and information changes of the National III product. So in actual operation, which information changes need to be re-appraised, which can be changed directly, and what issues should be paid attention to in the application for appraisal?
In response to the above problems, this article starts with the sorting of relevant legal standard documents for emission upgrades, analyzes the difference between emission upgrades and emission information disclosure, and needs to reapply for identification information changes and precautions. Finally, it discusses the relationship between promotion appraisal and machine purchase subsidy qualifications, and puts forward ideas for the establishment of inspection and testing institutions of agricultural machinery enterprises.
Since the release and implementation of "Emission Limits and Measurement Methods for Diesel Engine Exhaust Pollutants for Non-road Mobile Machinery" (China's Third and Fourth Stages)" (GB20891-2014), "National Second to National III" has always been a hot topic in the agricultural machinery industry. Everyone has been confused and at a loss about the issues related to National III emission technology, policies, etc. to the orderly advancement of the National III emission industry in the agricultural machinery industry, which is closely related to the release and implementation of multiple documents of relevant departments. These documents and policies are basically carried out in the direction of scientific implementation, based on reality, streamlining administration and delegating power, making convenience for the people, and improving efficiency. The correct understanding and grasp of these technical policy documents is an important task for agricultural machinery manufacturers to do a good job in the disclosure of national III emission standards and non-road mobile machinery emission information for agricultural machinery manufacturers. The author has done some technical analysis and discussion on the relevant requirements.
1. Compilation of relevant legal standard documents
organizes relevant legal and policy documents involving the upgrading of agricultural diesel engine emission standards and the disclosure of emission information of non-road mobile machinery in the agricultural machinery industry. It can be divided into three aspects:
1. Laws and regulations (parts)
1) "Atmospheric Pollution Prevention and Control Law of the People's Republic of China" (Chairman Order No. 31) (hereinafter referred to as the "Atmospheric Law") is issued on August 29, 2015. The main aspects of agricultural machinery will be implemented from January 1, 2016: Non-road mobile machinery (including agricultural machinery) production enterprises shall conduct emission inspections on newly produced non-road mobile machinery. Only after passing the inspection can it be sold out of the factory. Inspection information should be made public to the public. and relevant penalties for violation of regulations.
2. Relevant standards and documents issued by the Ministry of Environmental Protection (partial)
2) "Emission limits and measurement methods for diesel engine exhaust gas for non-road mobile machinery" (China's third and fourth stages)" (GB20891-2014). Release on May 16, 2014 and implemented on October 1, 2014. The standards stipulate the emission limits and measurement methods of exhaust pollutants of diesel engines for non-road mobile machinery, as well as the type approval, production consistency detection and durability requirements of diesel engines, and the implementation time of emissions.
3) "Announcement on Implementing the National Third Stage of Exhaust Pollutant Emission Standards for Diesel Engines for Non-road Mobile Machinery" (Announcement of the Ministry of Environmental Protection No. 5, 2016) was issued and implemented on January 14, 2016. The implementation of the National III emission standards for agricultural machinery will be postponed to December 1, 2016, and the implementation time of agricultural diesel engines will remain unchanged.
4) "Announcement on Cancelling the Approval of the Application and Testing Agency for the Emission Pollution of Newly Produced Motor Vehicles" (Announcement of the Ministry of Environmental Protection No. 30, 2016) was issued and implemented on April 11, 2016. The approval of the emission pollution declaration and testing agency for newly produced motor vehicles ( includes agricultural diesel engines ) is cancelled, and the qualification conditions of the motor vehicle emission inspection agency, the specific requirements and responsibilities for conducting emission testing are stipulated.
5) "Guidelines for Information Disclosure", in December 2015, the Ministry of Environmental Protection held an information disclosure work meeting, introducing the work flow, disclosure content, technical requirements, etc. of the disclosure of environmental emission information for non-road mobile engines and non-road mobile machinery. Including production consistency information, information disclosure content, etc. The conference courseware can be downloaded on the motor vehicle environmental protection network.
3. The Ministry of Agriculture issued relevant documents (partial)
6) "Notice on Issuing the Review Regulations on the Acceptance of Ministerial Promotion and Appraisal and Information Change" (Agricultural Machinery Clinic [2015] No. 63) (hereinafter referred to as Document No. 63) was issued and implemented on May 6, 2015. The information changes, acceptance and review, and grasp of final documents during the valid period of the promotion and appraisal of the ministerial level were clarified. The situation of changes in agricultural machinery product information involving the upgrade of diesel engine emission standards that obtain the ministerial promotion and appraisal certificate.
7) "Notice on Changes in Ministerial Promotion and Appraisal Information Related to Upgrade Emission Standards of Agricultural Diesel Engines" (Agricultural Machinery Critics [2015] No. 95) (hereinafter referred to as Document No. 95) was issued and implemented on August 10, 2015. The scope, declaration requirements, time limit requirements and review requirements for changes in the ministerial promotion and appraisal information of agricultural diesel engines, agricultural tractors, and other agricultural machinery involving the emissions of the second and third countries are clarified.
Due to the upgrade of diesel engine emission standards, the diesel engine structure needs to be greatly improved. Compared with the requirements of Agricultural Machinery Clinic [2015] No. 95, the requirements for changes in air intake mode, outer contour size and net mass are relaxed. See Table 1 for details.
Diesel engine emission standards have greatly changed in the diesel engine structure and the changes in the entire machine parameters caused by this. Compared with the requirements of the Agricultural Machinery Critics [2015] Document No. 95, the requirements for the air intake method, calibration power, and silencer cavity size and weight of the entire machine are relatively wide.
8) "Notice of the General Office of the Ministry of Agriculture on Doing a Good Job in the Current Work on Promotion and Appraisal of Agricultural Machinery" (Nongbanji [2016] No. 6) (hereinafter referred to as Document No. 6) was issued and implemented on March 29, 2016. Among them, "Clarify the principle of changing certificate information after emission standards upgrade" further clarifies the declaration and review requirements for promotion and identification of information changes involving diesel engine emission standards upgrade.
2. Diesel engine emission standards upgrade and non-road mobile machinery emission information disclosure
It is understood that many agricultural machinery enterprises have the disclosure of information on the National III emission standards and light emissions, and they even do not know what the disclosure of emission information is. Some people confuse diesel engine emissions and non-road mobile machinery emission information disclosure, but this is not the case.
National III emissions in the agricultural machinery industry mainly refer to the production and sale of diesel engines and the diesel engines that are equipped with the main engine must pass the third phase of emission type approval of China, which is a requirement of the national mandatory standard GB20891-2014. The main target is non-road mobile diesel engines.
emission information disclosure is a requirement of the Atmospheric Law. If information disclosure is not carried out as required, or the emissions do not meet the requirements, the penalties and consequences are serious. From the perspective of the agricultural machinery industry, the main targets are not only diesel engines for non-road mobile machinery, but also gasoline engines for non-road mobile machinery and all non-road mobile machinery equipped with diesel engines or small ignition engines.
"Atmospheric Law" "Article 51 Motor vehicles, ships and non-road mobile machinery shall not emit air pollutants beyond the standard. It is prohibited to produce, import or sell motor vehicles, ships and non-road mobile machinery that emit air pollutants exceeding the standard.
Article 52 Motor vehicles and non-road mobile machinery production enterprises shall conduct emission inspections on newly produced motor vehicles and non-road mobile machinery. Only if the inspection is passed can be sold out of the factory. Inspection information shall be made public to the public.
Article 109 If motor vehicles and non-road mobile machinery that violate the provisions of this Law and produce motor vehicles and non-road mobile machinery that exceed the pollutant emission standards, the environmental protection department of the people's government at or above the provincial level shall order the correction, confiscate the illegal income, and impose a fine of not less than one times but not more than three times the value of the goods.”
Emission information disclosure refers to the disclosure of relevant environmental protection information by the manufacturer on the designated public platform or vehicle-mounted documents of the non-road mobile machinery and diesel engines. The disclosure of information of the non-road mobile machinery mainly includes: 1) basic information of the manufacturer; 2) pollution control technology information (pollution control technology content, production consistency and in-use compliance related information); 3) emission inspection information (approval, enterprise self-inspection, vehicle model status information, inspection conditions, inspection results); 4) enterprise information disclosure work plan (time/location/family/source machine of the declaration and inspection plan); 5) recall related information; 6) vehicle-mounted documents ( Statement, labels), etc. According to the standard requirements, diesel engines installed on non-road mobile machinery should meet the following characteristics of the diesel engine type approval: the intake pressure drop should not exceed the pressure drop specified by the diesel engine approved by the type. The exhaust pressure should not exceed the back pressure specified by the diesel engine approved by the type.
diesel engine National III emission and emission information disclosure have obvious differences in the source, main objects and main content, see Table 2. The emission information disclosure in the table is based on the "relevant detection method standards", which refers to the non-road mobile machinery (agricultural machinery) emission detection method standards, but has not been issued yet (there are relevant standards in the automobile industry, GB 17691-2005 "Emission Limits and Measurement Methods for Vehicle Pressure-ignition, Gas Fuel Ignition Engines and Vehicle Emission Pollutants Emissions"), relevant departments also need to speed up the formulation of emission detection method standards for Non-road Mobile Machinery (Agricultural Machinery) .
3. Analysis of the promotion and identification information of the People's Republic of China 2nd and the People's Republic of China 31. No. 6 of the document
Rural Office Machinery [2016] stipulates that "agricultural diesel engines, tractors and other agricultural machinery, product information changes caused by the upgrading of agricultural diesel engine emission standards to China's third stage, Enterprises can change independently within the scope of changes allowed in the current relevant regulations, without reporting changes and filing. "It is a revision of some contents of Document No. 95, which is to further streamline administration and delegate power, improve efficiency, and increase the autonomy of enterprises. However, independent changes must meet two prerequisites: one is that it does not involve changes in the information of the promotion and appraisal certificate, but it is only a change in product information, and the other is that it is only a change caused by the emission upgrade of the National 2 liters of National 3. If not, it must be implemented in accordance with the requirements of Document No. 63. If the counterweight, steering system, and braking system of the wheeled tractor have changed, and the change must be applied to the original issuing authority. Some changes must be conducted with relevant testing and a report must be issued. Another situation is that products whose scope of the change does not clearly define the changes caused by the upgrading of the National 2 liters of National 3 emission standards will change and the engine parameters are in line with the If the requirements are met (refer to other self-propelled agricultural machinery), there is no need to declare it. It is only necessary to change it independently, such as self-propelled sprayer, self-propelled air-feeding sprayer, cotton harvester and other self-propelled agricultural machinery.
2. Change of agricultural diesel engine model
Diesel engine model change
Diesel engine National 2nd and National 3rd product model change:
1. Most diesel engines approved by the original form of diesel engine manufacturers are implementing the technical route of the National 2nd. After the promotion of the National 3rd, the product structure and technical route have changed greatly, which is equivalent to redeveloping a new diesel engine product. For the model approval of the Ministry of Environmental Protection, it is not a simple renewal, but a new model is re-tested and approved according to the emission requirements. , so the type approval certificate of National III is a brand new model.
Second, only some enterprises' diesel engines could meet the requirements of National III, but there was no National III emission type approval at that time. After this promotion to National III, the same product can still meet the requirements of National III. The product structure and model are exactly the same as the original one. If the product model of the type approval certificate has not changed, there is no need to apply for the replacement of the Ministry-level promotion and appraisal certificate for agricultural diesel engines.
For enterprises whose diesel engine model changes, the company must apply to the issuing agency to confirm the application materials for the product information change submitted by the applicant company. The appraisal department uses document review and evaluation methods to confirm whether the product information applied for changes meets the change requirements. All projects can only be confirmed after passing the review.After review and confirmation, a change review and confirmation report for the application company during the validity period of the promotion and appraisal product can be used together with the changed promotion and appraisal certificate and the original report.
3. The situation of tractors adding engines or changing engine companies
6 document only clarifies the way of declaration and review, but the scope of changes to the relevant documents stipulated have not changed. Annex 2 of Document No. 95 stipulates that "the name of the manufacturer is allowed to change, but the equipped engine must be for the promotion and appraisal certificate to be valid for the product, and has passed the third phase of China's emission confirmation. The number of supporting engines shall not be more than the number of supporting engines in the original inspection report." This is a difficult point for many agricultural tractor companies. If the number of engines filled in the product specification confirmation form during the previous promotion and appraisal is small, it will be limited when the National III changes. There are two restrictions:
, one is the limitation of choosing a diesel engine manufacturer. If the engine manufacturer is not replaced, you can choose the National III diesel engine that has not passed the promotion and identification. If the engine manufacturer is replaced, the product must be the National III diesel engine that has obtained the promotion and appraisal certificate. However, as of the end of April, there are no National III diesel engines that have obtained the promotion and appraisal certificate. Even if there are one after another, the number will not be much. For many companies, there is really little room for choosing a diesel engine.
The second is the limit on the number of supporting diesel engines. There are different understandings that the number of supporting engines must not be more than the number of supporting engines in the original inspection report. Since Document No. 6 has clearly allowed enterprises to make changes independently, there is no need to apply for it again. There is no time limit for this change, nor the number of changes. Then the enterprise may understand this during the validity period of the promotion and appraisal certificate. For example, the enterprise has equipped a model A diesel engine during this period, and has independently changed it after a period of time and has a model B diesel engine. However, the number of supporting engines during the same period is not allowed to exceed the number of engines in the original inspection report.
4. Issues to pay attention to when applying for the Ministry-level promotion and appraisal of agricultural machinery
1. You need to provide a type approval certificate or check the Motor Vehicle Environmental Protection Network. Document No.
95 mentioned that "From April 1, 2016, the ministerial promotion and appraisal application for other agricultural machinery supporting China's second-stage emission diesel engines will no longer be accepted." From this, it can be seen that in addition to wheel tractors, crawler tractors, handheld tractors and diesel engine products that must provide type approval certificates when applying for the Ministry-level promotion and appraisal, other self-provisioned (diesel engine) mobile agricultural machinery that does not make any provisions for the Ministry-level promotion and appraisal will also need to provide a type approval certificate for the National III emission diesel engine after April 1, 2016. This is different from the original promotion appraisal application requirements. When applying for promotion and appraisal of agricultural machinery manufacturers, the application materials must be filled in the diesel engine approved by the National III emission type, and the type approval certificate of the supporting engine must be provided together. If there is no type approval certificate, you can also enter the engine model on the motor vehicle environmental protection network to confirm whether it has passed the National III emission type approval.
2. The relationship between rated net power and calibrated power
type approval certificate part 2 The test report information and model parameters (see the attachment page) contains the "rated net power/speed" value of diesel engines, but the agricultural machinery product specification confirmation table that applies for promotion and identification is generally called "calibration power". The "Notice of Jiangxi Province on Standardizing the Marking and Marking of Supporting Engines for Subsidized Products for Agricultural Machinery Purchase Subsidized Products" (Gan Agricultural Machinery General [2016] No. 7 stipulates: "The engine nameplate includes at least the following marked contents: manufacturer, product model, calibration power (12-hour calibration power) , factory number and manufacturing year ” So what is the relationship between the rated net power and the calibrated power? The standard
GB20891-2014 stipulates:
"net power" refers to the power measured on the diesel engine test bench according to the net power measurement method specified in GB/T17692-1999 under the test conditions specified in this standard, under the test conditions specified in this standard; "rated net power" refers to the net power marked by the manufacturer when the diesel engine is approved for the diesel engine model.However, the "calibration power" on the whole agricultural machinery refers to the power that can be continuously exerted stably. The calibration power of the tractor refers to the 12h power value that can be emitted under certain environmental conditions by the diesel engine for tractors with the same accessories as when installed on the whole machine. GB/T 24646-2009 "Tractor Calibration Power Test Method" stipulates the relevant requirements for calibration power testing. The calibration power of a diesel engine is different under different speeds, exhaust volumes, accessories, etc., and may vary greatly, depending on a balance between the economy and power of the diesel engine, but the manufacturer should indicate the state of the power measured.
Some people believe that the rated net power emitted by diesel engines is measured under test conditions without accessories (fans, cooling pumps, etc.). Therefore, the power consumed by accessories is small, so the rated net power is generally greater than the calibration power. Some people also believe that through equivalent calculation methods, the power consumed by accessories such as fans and cooling pumps on the bench during the test has been deducted. There is still controversy in the industry about this.
"Rated Net Power" and "Calibrated Power" definitions, detection methods and accessories provided are different. However, the rated net power value is a standard value that has been verified by environmentally friendly type approval and is a reference for diesel engine power, so the calibration power value can also be simply used (the power value is the same, the speed should also be the same). For calibration power less than or equal to the rated net power, it is OK from the emission perspective. Generally speaking, the smaller the power, the smaller the power (the power value per liter of displacement), the better the emission indicator. When applying for promotion and appraisal, enterprises must carefully check whether the corresponding information on the engine's product model, company name, calibration power, speed and type approval certificate on the product specification confirmation table are consistent.
3. Products equipped with small-power diesel engines (single-cylinder diesel engines)
For the National III emissions of a single-cylinder diesel engine, it is necessary to increase the oil pump and oil nozzle injection pressure based on the National II emission technology route, and adopt new technologies such as post-processing and electronic control technology. It is necessary to conduct national III emission durability bench tests for more than 750 hours. The technical difficulty is relatively high, the test time is long and the cost is relatively high. Even through National III emissions, the cost of a single-cylinder diesel engine using in-machine purification and aftertreatment measures is 250 yuan to 400 yuan, an increase of about 15%; if the electronically controlled single-body pump technology is 800 yuan, an increase of more than 30%.
Currently, gasoline engine emission standards are still in compliance with GB 26133-2010 "Emission Limits and Measurement Methods for Exhaust Pollutants for Small Ignition Engines for Non-road Mobile Machinery (China's First and Second Phases)", and the implementation of National III emissions has not yet begun. At present, the ministry-level promotion and identification products with small power products such as micro-tillers, rural management machines, tillers and rice transplanters can be equipped with both diesel engines or gasoline engines as their own power. For these products, it is recommended that the supporting power of gasoline engines be appropriately added, and timely application for promotion and identification and subsidy archives are made to prepare for market changes after the implementation of the National III emission standards for diesel engines.
Currently, Document No. 63 allows some products to be declared, promoted and approved, the fuel type of the supporting engine in the finalization document will change. The original diesel engine in the established model document will be equipped with a diesel engine, and the new declaration, promotion and identification can be changed to a gasoline engine. Some companies reported that diesel engines have better power performance than gasoline engines. If the newly applied product is changed to a supporting gasoline engine, the calibration power needs to be increased accordingly, which is also allowed in Document No. 63. The company has even developed new products, changing the original supporting diesel or gasoline engines to motor-driven, such as the electric micro-tillers, electric rice transplanters, wireless remote-controlled electric plant protection machinery, etc. that are currently on the market. This is a bold attempt for products with relatively small loads and low power performance requirements. Electricity is a clean capacity, and electric agricultural machinery has better emission reduction effects, which is consistent with the current strong promotion of new energy vehicles by the country. However, whether the appraisal outline is applicable to the appraisal of electric agricultural machinery products needs further research, because some indicators in the outline cannot be evaluated.
4. Promotion and identification outline
Some people mistakenly believe that after the diesel engine emission standards are upgraded, the original identification outline is not applicable to the identification of the national agricultural machinery products, so the promotion and identification outline needs to be revised.In fact, this revision of the promotion and appraisal outline is because the new "Implementation Measures for the Promotion and Appraisal of Agricultural Machinery" was implemented from January 1, 2016. The appraisal content and related requirements have undergone major changes, and the original appraisal outline should also be adjusted and revised accordingly. This has nothing to do with the upgrade of diesel engine emission standards, because the promotion and identification is to evaluate the consistency inspection of the entire machine and the performance, safety, reliability, applicability, etc., and has little to do with the upgrade of diesel engine emission standards.
5. Discussion on violating environmental protection regulations and qualifications for agricultural machinery purchase subsidies
Agricultural machinery purchase subsidies are an important part of the national policy of strengthening agriculture, benefiting farmers and enriching farmers, and are based on the "Agricultural Mechanization Promotion Law of the People's Republic of China". The author checked the relevant documents and did not directly find any related clauses related to the subsidy qualifications for violations of environmental protection laws and regulations. It should be noted that the qualifications of subsidized products stipulated in the "Guiding Opinions on Implementation of Agricultural Machinery Purchase Subsidies from 2015 to 2017" are the minimum conditions. To obtain subsidies, you must not violate the regulations of relevant departments and subsidy policy regulations. And relevant basis can be found in other relevant laws and regulations.
Article 15 of the "Agricultural Mechanization Promotion Law of the People's Republic of China" stipulates that "the production and sale of agricultural machinery products that do not meet the mandatory requirements of national technical specifications are prohibited." The mandatory technical specifications here are understood to include the GB20891-2014 standard.
Before 2015, subsidized equipment must be products that have been included in the national support promotion catalog or the provincial support promotion catalog. The "Regulations on the Management of Catalogs of Agricultural Machinery Products Supported by the State" (Agricultural Machinery Development [2005] No. 7) stipulates that "relevant laws and regulations" will be disqualified from the "Catalogue". The laws and regulations here are understood to include the "Atmosphere Law".
Article 56 of the Atmospheric Law stipulates that "the environmental protection department shall, together with transportation, housing and urban-rural construction, agricultural administration and other relevant departments, supervise and inspect the atmospheric pollutant emissions of non-road mobile machinery. If the emissions are not qualified, they shall not be used." Is it understandable here that the environmental protection department and the agricultural administrative department (agricultural mechanization department) supervise and inspect the atmospheric pollutant emissions of non-road mobile machinery (agricultural machinery) .
The seven situations stipulated in Article 27 of the "Measures for the Test and Appraisal of Agricultural Machinery" where the promotion and appraisal certificates should be revoked are not directly related to the National III emissions or the "Atmospheric Law". However, violating relevant environmental protection regulations also faces the risk of being withdrawn, and there are two reasons. is the promotion and identification outline "Wheel and Crawler Tractor" (DG/T001-2011). The supporting diesel engine must provide corresponding type approval certificates. It can be understood that the supporting diesel engines that have not passed the National III emission type approval do not meet the qualification requirements for the promotion and appraisal application, and the qualification for the promotion and appraisal certificate does not exist. second is 95 document clearly stipulates that "From April 1, 2016, agricultural machinery products that have passed the ministerial promotion and appraisal and are within the valid period, and diesel engines that have not passed the third phase of China's emission type approval will not be allowed to use the promotion and appraisal certificate." Since the Ministry of Environmental Protection postponed the implementation of the National III emissions of agricultural machinery products to December 1, 2016, it can be understood that after December 1, 2016, if the supporting diesel engines of agricultural machinery products fail to pass the National III emission type approval when using the promotion and appraisal certificate, they may face the revocation of the promotion and appraisal certificate. After the promotion and appraisal certificate is cancelled by the original issuing agency in accordance with the "Guiding Opinions on Implementation of Agricultural Machinery Purchase Subsidies in 2015-2017", its subsidy qualification will be automatically cancelled.
The qualification for product subsidy for agricultural machinery production and distribution enterprises or the qualification for product subsidy for distribution subsidy products are suspended or cancelled, and the disputes and economic losses arising shall be borne by the illegal agricultural machinery production or distribution enterprises.
Article 58 of the Atmospheric Law stipulates that "the state establishes a recall system for environmental protection of motor vehicles and non-road mobile machinery. If production and import enterprises know that the air pollutants emitted by motor vehicles and non-road mobile machinery exceed the standards and are defective in design and production or do not meet the prescribed environmental protection durability requirements, they shall recall; if they are not recalled, the quality supervision department of the State Council, in conjunction with the environmental protection department of the State Council, shall order them to recall."If before the recall, if the subsidy funds for agricultural machinery purchase have been generated, then these treasury funds may be recovered, and the disputes and economic losses caused will be borne by the illegal agricultural machinery production or distribution companies.
6. The idea of establishing inspection and testing institutions for agricultural machinery enterprises
diesel engines National III emission type approval, information disclosure of the Atmospheric Law, agricultural machinery promotion and appraisal, and its own product test and shaping are all very extensive. Agricultural machinery enterprises not only bear a large amount of inspection costs every year, but it is understood that some large enterprises have millions of inspection fees per year, but also face the inability to find a suitable institution to undertake the inspection tasks. Even if the inspection agencies are willing to undertake the inspection tasks, due to the long queues of many tasks, it delays the production and sales of products. To affect the long-term development plan of enterprises.
The country has increasingly high requirements for product quality and environmental protection, but there is indeed a need for inspection and testing institutions that cannot meet the growing demand for inspection and testing business. With the relaxation of inspection and testing institutions, enterprises can also establish independent third-party inspection and testing institutions or corporate laboratories approved by laboratories in accordance with relevant laws and regulations. Some enterprises are confused about whether to establish a separate inspection and laboratory or enterprise laboratories. Here we can sort out the requirements of relevant departments and documents for testing institutions and enterprise laboratories.
1. Feasibility analysis of the establishment of inspection and testing institutions
"Product Quality Law of the People's Republic of China" stipulates:
"Article 19 Product quality inspection institutions must have corresponding testing conditions and capabilities, and can only undertake product quality inspection work after passing the assessment by the product quality supervision department of the people's government at or above the provincial level or its authorized departments. Article 20 Social intermediary institutions engaged in product quality inspection and certification must be established in accordance with the law and shall not have affiliation or other interest relationships with administrative agencies and other state agencies. "
"Several Opinions of the National Accreditation and Supervision Commission on Implementing the Management Measures for Qualification Certification of Inspection and Testing Institutions" (Guo Jingshi [2015] No. 49) stipulates:
"About the access conditions for the subject of inspection and testing institutions
Any legal person and other organization established in accordance with the law, whose business scope or business scope registered and registered in accordance with the law includes inspection and testing, and can engage in independent and impartial work, can apply for qualification certification of inspection and testing institutions. Other organizations include: corporate legal person branches that have obtained the "Business License" issued by the industrial and commercial administrative organs in accordance with the law, special general partnerships, private non-enterprise units (legal persons) registered by the civil affairs department, and other institutions that comply with the provisions of laws and regulations.
The inspection and testing institutions within the production enterprises are not within the scope of the qualification certification of the inspection and testing institutions. Inspection and testing institutions with legal person qualifications established by manufacturing enterprises can apply for inspection and testing institutions qualification certification, and shall comply with relevant professional regulations on objective, independent, fair, open, honest and trustworthy in the inspection and testing institutions. "
It can be seen that agricultural machinery enterprises can also establish independent third-party inspection institutions in accordance with the law. They are not affiliated with any government department or public institution, and after passing the assessment by relevant departments, they will independently undertake product quality inspection tasks in accordance with the law.
2. Requirements for inspection and testing institutions in the environmental protection department
From the current environmental protection requirements, there are two main aspects involved in the agricultural machinery industry. First, diesel engine emissions must meet the requirements of GB20891-2014 China's third stage, and small ignition engines must meet GB 26133-2010 China's second phase requirements; second, non-road mobile machinery (non-road mobile machinery equipped with diesel engines or small ignition engines) and non-road mobile machinery engines (non-road mobile machinery diesel engines or small ignition engines) must perform emission detection in accordance with the requirements of the "Atmospheric Law" and information disclosure. Both aspects require a large amount of testing, and the testing agency undertakes the main work.
The Ministry of Environmental Protection issued an announcement "Announcement on the Cancellation of Approval of the Detection Agency for Emission Pollution of Newly Produced Motor Vehicles" (Announcement of Ministry of Environmental Protection 2016 No. 30) stipulates that the declaration and testing agency for Emission Pollution of Newly Produced Motor Vehicles will no longer be approved. Repeal the relevant measures and the catalog of already published testing agencies will be revoked.Among them: "3. Motor vehicle emission inspection agencies shall pass metrological certification in accordance with the law, use motor vehicle emission inspection equipment that has been certified in accordance with the law, conduct emission inspections on motor vehicles in accordance with the regulations formulated by the environmental protection department of the State Council, and connect with the environmental protection department to realize real-time sharing of inspection data. Motor vehicle emission inspection agencies and their persons in charge are responsible for the authenticity and accuracy of inspection data." (This is also the provision of Article 54 of the "Atmospheric Law")
The author believes that the impact of the issuance of this document is no less than the previous postponement of the implementation of the National III emission standards by agricultural machinery. Under the approval mechanism of the testing agency, the existing emission detection agencies cannot meet the requirements of a large number of engine emission tests and a large number of inspections in information disclosure statements. The environmental protection department will follow the trend and cancel the approval of testing agencies to achieve marketization. After the testing is liberalized, manufacturing enterprises will have more autonomy and can effectively solve the current tight emission testing tasks. For agricultural machinery enterprises, first, testing institutions have been relaxed, and the approval and approval of Guosen III diesel engines will be accelerated, so it is easier to find an engine suitable for your product. Second, the "Atmospheric Law" now stipulates that the whole agricultural machinery must also conduct self-public declarations on emission testing. Now that the testing institutions have been relaxed, it will be relatively easy to find inspection institutions for the whole machine emission testing in the future. There are currently no emission detection method standards for non-road mobile machinery (agricultural machinery), and relevant departments need to speed up the formulation of emission detection method standards for agricultural machinery as a whole.
The prerequisite for the inspection agency here is to pass qualification certification (measurement certification), and must also meet other relevant requirements of the environmental protection department.
3. Requirements for inspection institutions and enterprise laboratories for promotion and appraisal
From the application requirements for promotion and appraisal, agricultural machinery enterprises can involve two aspects of inspection and testing institutions: one is the standardized certification documents, and the other is the testing for promotion and appraisal.
Article 7 of the "Implementation Measures for the Promotion and Appraisal of Agricultural Machinery" stipulates that "(IV) Product appraisal certificates issued by other units in accordance with the regulations of relevant departments; (V) Type test reports issued by Qualified product quality inspection institutions or labs of of enterprises approved by labs." It can be used as one of the proof documents for the proof of shape.
"Implementation Measures for the Promotion and Appraisal of Agricultural Machinery" Article 16 stipulates: "If an agricultural machinery appraisal agency independently completes the promotion and appraisal task, the institution shall issue an agricultural machinery promotion and appraisal report. If cooperates with a qualified product quality inspection agency , the appraisal agency shall issue an agricultural machinery promotion and appraisal report.
"Rules for the Writing Outline of Agricultural Machinery Promotion and Appraisal" (TZ 1-2016) (Announcement No. 2367 of the Ministry of Agriculture of the People's Republic of China) stipulates "6.9.4 Reliability Evaluation You can accept the reliability test report completed by the qualified product quality inspection agency in accordance with the production test method stipulated by the national standards and industry standards of the relevant products. ”
"Notice of the Fujian Provincial Department of Agriculture on the Reform of Agricultural Machinery Promotion and Appraisal" (Fujian Agricultural Machinery [2016] No. 76) stipulates that "the enterprise applying for agricultural machinery promotion and appraisal is entrusted by the enterprise applying for agricultural machinery promotion and appraisal to conduct inspections and issue inspection reports in accordance with the requirements of the agricultural machinery promotion and appraisal outline. This inspection report can be used as the basis for issuing agricultural machinery promotion and appraisal certificates. "
The above-mentioned "product quality inspection agency" is the prerequisite for the inspection agency that passes qualification certification (measurement certification), and of course it also needs to meet other relevant requirements.
To sum up, whether from the requirements of environmental protection departments or promotion and appraisal for inspection and testing agencies, establishing an independent third-party inspection agency that passes qualification certification (measurement certification) is more widely used and plays a greater role than that of the laboratory. However, the hardware and other conditions of establishing an inspection agency that passes qualification certification are higher and more difficult than that of the enterprise laboratories. Agricultural machinery enterprises should rationally choose (such as large agricultural machinery production companies that have products such as diesel engines, tractors and harvesting machinery) based on their own situation and do not blindly follow the trend.
Environmental protection is an important part of the construction of ecological civilization in the construction of a "five-in-one", which shows the importance of actively promoting the upgrading of agricultural machinery emissions and the disclosure of emission information.Due to the limited technical level of the author, this article is limited to a superficial understanding and superficial understanding of some content, and is not thorough enough to understand and analyze deeper technical issues. This article is just a way to attract attention. All agricultural machinery production enterprises are the primary responsible entities for environmental protection. They should strengthen relevant laws, regulations, standards, documents, policies, etc. for careful research and study, grasp relevant key points, not only can they stick to the bottom line and ignore the red line, but they can also take the lead in the supply-side reform and structural adjustment of the agricultural machinery industry and agricultural mechanization industry.
(Note: This article only represents the author Xu Feng's views. It is based on the effective technical analysis and discussion of existing document materials. If the relevant documents are revised and replaced, some of the views in this article also need to be adjusted.)
Editor: Duan Yunhong
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