The Standards and Quality team regularly assists companies in preparing for inspections and sees the same gaps year after year. This article provides a specific list of things that need to be in order before the inspector arrives, as well as typical mistakes that can be corrected in advance.
What exactly does the State Consumer Protection Service check and on what basis?
Inspectors operate within the framework of the Law “On State Market Surveillance and Control of Non-Food Products” and the Law “On Basic Principles and Requirements for Food Safety and Quality.” Depending on the type of product, the inspection may concern compliance with technical regulations, the availability of permits, correct labeling, or compliance with sanitary standards.
The main focus is on documentary evidence of safety and quality. The inspector has the right to request any document confirming that the products comply with the established requirements: from laboratory test reports to technical production specifications. It is important to understand that the inspection is not only an inspection of the production site, but above all, work with documents.
Basic set of documents: what every manufacturer should have
The first step in preparation is to check that all mandatory documents are available and up to date. For most manufacturers, the basic package includes several key items.
Certificate or declaration of conformity. Depending on the product category, the manufacturer must have a valid document confirming that the conformity assessment procedure has been completed. If your products are subject to mandatory certification, make sure that the certificate is not expired and covers the exact range of products that you actually manufacture. An expired document is equivalent to no document at all from the inspector’s point of view.
Declaration of conformity. For products subject to technical regulations, the manufacturer independently draws up a declaration of conformity. Common mistakes include referring to an outdated version of the standard, not having the signature of the responsible person, or the product description not matching the actual nomenclature. Each of these mistakes can be grounds for a comment.
Technical specifications (TS). If products are not manufactured in accordance with national standards (DSTU), they must be manufactured in accordance with technical specifications. The development of TS is not a formality, but a full-fledged regulatory document that defines product requirements, quality control methods, and labeling rules. The absence of TS or their inconsistency with the actual characteristics of the product is one of the most frequent comments made by inspectors during inspections.
Sanitary and epidemiological conclusion. For certain categories of goods — food products, children’s goods, detergents, certain building materials — a sanitary and epidemiological conclusion is mandatory. This document is issued for a specific period, after which it must be reissued. Check the validity period of each certificate separately — they may expire at different times.
Test reports. Each certificate or declaration is based on the results of laboratory tests. The inspector may request the original reports. They must be issued by an accredited laboratory and correspond to the specific product for which the relevant document is issued. Please note: reports from laboratories without valid NAAS accreditation are not legally valid.
Industry-specific features: additional requirements depending on the product
In addition to the basic package, inspectors pay attention to specific requirements depending on the industry. Ignoring these requirements is a common cause of violations.
For food producers, compliance with HACCP principles and the availability of a complete set of safety system documentation are key. Food certification involves checking not only the product itself, but also the conditions of production, storage, and transportation. The inspector will pay close attention to temperature control logs, records of incoming raw material inspections, batch traceability documentation, and product recall procedures.
Manufacturers of electrical appliances and equipment face requirements for electrical safety and electromagnetic compatibility. Certification of household appliances includes confirmation of compliance with technical regulations for low-voltage equipment. Ensure that the markings on the product fully match the information in the certificate, and that the operating instructions in Ukrainian comply with the applicable requirements for content and format.
Separate technical regulations apply to manufacturers of building materials. Certification of building products requires a declaration of performance and appropriate labeling. Test reports must confirm the declared strength, fire resistance, thermal conductivity, or other characteristics specified in the declaration.
Checklist: 10 points to check before verification
This list will help you organize your preparations. We recommend going through each item two to three weeks before the expected inspection.
- Check the validity dates of all certificates and declarations of conformity. An expired document is an automatic violation.
- Compare the product range in the documents with the actual range. A new item that is not included in the certificate is formally released without confirmation.
- Ensure that the technical specifications are registered and correspond to the current product characteristics. If you have changed the composition or technology, the technical specifications need to be updated.
- Check the labeling on each item: make sure it has a compliance mark, info about the manufacturer, date of manufacture, expiration date, or warranty period.
- Prepare the original test reports and ensure that the laboratory that issued them has valid accreditation.
- Gather all sanitary and epidemiological reports in one place and check their validity.
- Review the incoming inspection logs for raw materials and finished products—the entries must be filled in without any gaps.
- Check the availability and relevance of operating or application instructions for each product item.
- Organize the documentation folder: create separate folders for each product group with a complete set of documents.
- Appoint a responsible person who will accompany the inspector and knows where each document is located.
Typical errors recorded by inspectors
In our experience, manufacturers often make the same mistakes—and it’s not a lack of budget, but basic inattention to detail.
Discrepancy between documents and actual products. The company expanded its product range, added a new model, or changed the composition, but did not update the declaration of conformity and did not make changes to the technical specifications. Formally, this means that some of the products are manufactured without confirmation of conformity, which is grounds for orders and penalties.
Incomplete labeling. There is no mark of conformity with technical regulations, no designation of technical specifications or standards, and no manufacturer contact information in Ukrainian. For products requiring certification, correct labeling is as mandatory as the certificate itself.
Chaotic storage of documentation. When an inspector requests a specific report and the person responsible spends twenty minutes searching for it in the filing cabinets, this is not a direct violation of the law. However, it creates a negative impression, increases the duration of the inspection, and raises the likelihood that the inspector will want to check everything in as much detail as possible.
When documents need to be updated in advance
Pay special attention to situations where documents are still formally valid but actually require updating or revision.
If the technical regulations referred to in your declaration have been updated, check whether your document complies with the current version. If you have changed your raw material supplier or moved production to another site, this may be grounds for retesting. If the technical specifications were developed several years ago, compare them with the current standards to which they refer. National standards are regularly updated, and technical specifications must reflect these changes.
A separate issue concerns manufacturers who operate simultaneously in the domestic market and for export. Having CE certification for export does not exempt a company from complying with Ukrainian requirements, and vice versa. These are two parallel sets of documentation, each of which must be up to date and complete.
What to do if you discover a gap on the eve of an inspection
If during self-checking you find that some documents are expired or missing, don’t panic, but don’t delay either. The processing time depends on the type of document.
The preparation of a declaration of conformity with current test reports takes from one to several working days. Obtaining a sanitary and epidemiological conclusion takes significantly longer—from two weeks. Therefore, it is critically important to conduct internal audits of documentation regularly, rather than just a week before a scheduled inspection.
Standards and Quality helps manufacturers conduct preliminary audits of documentation, identify gaps, and quickly prepare all necessary documents. If you are unsure about the completeness of your package, please contact us for advice. We work with all categories of products: from foodstuffs to household appliances and industrial equipment.
Preparing for an inspection by the State Service for Food Safety and Consumer Protection is not a one-off event before the inspector arrives, but part of a systematic quality management system at the enterprise. A manufacturer who keeps their documentation in order at all times spends a minimum of time and effort on preparation and passes the inspection without any comments.
