Discussion on the Management of Manufacturing License for Loader Products

4.1 From the perspective of basic conditions

The rules have imposed specific restrictions on the basic conditions for enterprise manufacturing licenses, including registered capital, personnel requirements, production conditions, and technical documents. Whether such restrictions can be effective and reasonable should be considered.

First, the national industrial policies have not imposed investment restrictions on the construction machinery industry such as loaders. Investment is a completely market-oriented behavior. It is worth discussing whether setting these investment restrictions is in line with national policies.

Secondly, at present, the market concentration of loader products is relatively high. The top ten enterprises occupy nearly 96% of the domestic market share. Moreover, the construction machinery market is an industry that is greatly influenced by national macroeconomic policies, especially infrastructure investment and construction. Therefore, it has certain investment risks, and investors will make very cautious decisions. The state only needs to regulate and guide through the market and technology, and there is no need for administrative restrictions.

Thirdly, for a single loader that costs hundreds of thousands or even millions of yuan, many of the conditions set in the rules are rather too low. If an enterprise doesn't even have this level of strength, how can it carry out production and operation? Therefore, the stipulated conditions simply cannot achieve the effect of restricting access, and the current implementation results also prove this point.

Fourth, the technology of medium and small-tonnage loaders is highly mature in China. The degree of specialized component matching is very high, and the social collaborative processing capacity is very strong. It is entirely possible to rely on social resources for matching or collaborative production, or OEM production, and this is also permitted under market conditions.

As long as the product meets the relevant safety technical requirements of the state, it is the enterprise's own business to choose the production method. Why set some conditions (such as production conditions, factory area, process conditions, etc.) to restrict it?

4.2 From a technical perspective

According to the regulations, special equipment subject to manufacturing license must comply with relevant safety technical specifications. The type tests of special equipment should follow the relevant type test procedures and test details. At present, there are no safety technical specifications applicable to loader products, nor are there any type test regulations or test details concerning loaders. Among the basic technical conditions that should be met for manufacturing licenses, nine standards are provided for loader products, including three mandatory standards, two parameter and technical condition standards, and four test method standards. These standards not only cover the contents related to quality and safety performance that need to be focused on in the management of special equipment, but also include requirements unrelated to product safety performance. However, the requirements involving safety, health, consumer rights and sustainable development that should be paid attention to as special equipment are not sufficient. Clearly, it is inappropriate to use them as safety technical specifications for products. It can be said that The manufacturing license for loaders still lacks the necessary technical support, and the current management is merely a formal one.

4.3 From the perspective of product features

Special equipment refers to the equipment recognized by the state, which is prone to accidents due to the equipment itself and external factors, and once an accident occurs, it will cause personal injury or death and significant economic losses. It involves life safety and is highly dangerous. A loader is a type of construction machinery mainly used for loading or short-distance transportation of bulk materials such as loose soil, sand and gravel, and coal. Its operation sites are mainly concentrated in construction sites, ports, docks, freight yards, mines, etc. It is a low-speed motor vehicle that does not travel on roads. Whether it is from the perspective of its working environment, usage characteristics, or the structural features of the product, the potential dangers it may cause cannot be compared with those of road vehicles, elevators, pressure vessels, large-scale amusement facilities and other equipment. The potential dangers are much smaller and easier to control. The manufacturing unit licensing management model conducts comprehensive supervision and management over aspects such as the product design, production and manufacturing scale and conditions, the quality of employees, and the technical performance of products of enterprises. It can be said that this management model is relatively strict. At present, the market access restrictions imposed on products like loaders in foreign countries, including developed ones, are mainly from the perspectives of product safety, health and consumer rights. Therefore, for equipment like loaders that pose little danger to users and the public, there is no need to implement such strict administrative management as for elevators, pressure vessels and other equipment.

Suggestions on Market Access Management for Loaders

From the above analysis, it can be seen that the author believes there are many unreasonable aspects in the manufacturing license management system of loaders. Here, the author puts forward some of his own thoughts.

5.1 Market Access system for EU loader products

The European Union was the first to recognize technical barriers, and the ones it has set up are the strictest. The EU has established a set of standardized and strict market access systems, among which the CE marking system is its main part, covering nearly 80% of the products in the EU market. The main management ideas and operation mode of the EU CE marking system: The European Commission formulates new approach directives that reflect the basic requirements of safety, health, consumer rights and sustainable development. These requirements are mandatory and are the basic conditions that products must meet to enter the market. The formulation of standards specifies and standardizes the basic requirements of the directive. By implementing the standards, manufacturers can ensure that their products comply with the basic requirements of the directive. By conducting a conformity assessment on the product, evaluate whether the product meets the basic requirements. For products that fully meet the requirements, the manufacturer conducts an EC declaration of conformity, stating that the product complies with the basic requirements of the directive. Finally, it is clearly indicated by affixing the "CE" mark. In this way, the product can be placed on the EU market and put into use. At the same time, different operation modes have been stipulated in view of the different structures and application scopes of the products. The market access model for products like loaders: The manufacturer coordinates standards during the product design and manufacturing process to ensure that the product meets the relevant basic requirements stipulated in the directive. Then, the manufacturer conducts self-conformity assessment and self-declaration of conformity. After that, it can affix the CE marking by itself. The entire process is entirely the responsibility of the manufacturer and does not require the participation of any third party. The competent authority only implements management through market supervision.

5.2 Suggestions for Market Access Management of Loader Products

5.2.1 Formulate product safety technical specifications and implement market access from a technical perspective

Based on the characteristics of the product, its application scope, and potential dangers that may exist, formulate targeted safety technical specifications that only cover requirements related to safety, health, consumer rights and sustainable development. These requirements are mandatory. Only when products meet these requirements can they be put on the market and put into use. These requirements can ensure that when the product is structurally reasonable, correctly installed, properly maintained and used for its intended purpose, it does not endanger personal safety and health, the environment or the rights and interests of consumers. In addition, no other technical restrictions should be imposed.

5.2.2 Evaluation and Management Model

The establishment of an evaluation model for whether a product can meet safety technical requirements should be based on self-evaluation by enterprises and the reduction of administrative intervention. Through market supervision, management goals should be achieved. Two models can be adopted: the type test plus announcement system and the market access mark system.

Type testing plus announcement system. Before a product is officially launched on the market and put into use, it must undergo type inspection by a professional type inspection institution recognized by the state. Type tests are type test specifications and test details formulated in accordance with the requirements of safety technical specifications. For products whose test results can fully meet the requirements of safety technical specifications, the manufacturer shall sign a unanimous declaration. Ensure that the safety and technical performance of the products produced in the future are the same as those of the prototypes that have passed the type inspection. Finally, the national administrative department will issue a qualified announcement, and then the products can be put on the market and used.

Marking system. Drawing on the CE marking system of the European Union, the application of the marking is mandatory. Enterprises implement safety technical specifications in the product design and development, production and manufacturing processes, establish necessary technical documents, and then determine whether the products meet the specification requirements through their own prototype inspection and conformity assessment. The enterprises sign a consistency conformity declaration, and finally make and affix the prescribed marks by themselves. After that, the products can be put on the market and put into use. To ensure that the production of future products is consistent with the samples, enterprises should also establish a quality management system.

6. Conclusion

With the continuous deepening of China's market economy and the internationalization of the market, the government's management of product market access should focus on safeguarding public interests such as safety, health, consumer rights and sustainable development. It should aim to achieve reasonable influence on the market through technical means rather than administrative management, and limit public intervention to the minimum extent. Create the greatest convenience and development space for the enterprise's growth.