Haryana Plywood Manufacturers Association has sought to review the retrospective implementation of an BIS order dated 10th April 2023, following which the cancellation of Plywood manufacturer’s license has been made applicable retrospectively from 10th April 2021 on the grounds of failure of more than 50% sample in the last 2 years from the date of circular.
Plywood, Block Board, Marine Plywood, Shuttering Plywood and Flush Door fall under sl. no. 5, 17, 19, 20 and 49 of the above circular and each of the above products has been put for sampling 2 nos. from factory every year and 4 nos. from market every year.
It is a general principle of natural justice that no punishment can be awarded retrospectively. But the licenses, at regional level and zonal level, are cancelled two years preceding the date of notification of the above circular.
HPMA submits that there are many cases where more than 50% failures are reported but corrective measures have already been taken and verified by the Bureau and special visit fees of Rs. 7000/ -, lab testing charges of the independent test house have been paid by the license holder and the license has been regularised from 'Stop - Marking' to operative.
By retrospective execution of the above circular, the whole exercise of corrective measures, special inspection, independent lab testing shall become infructuous, therefore it is requested in the interest of Yamunanagar plywood manufacturer to review the applicability date of the cancellation provision.
As plywood, doors and block board has been put under QCO w.e.f. 11th Feb 2025. The sampling and surveillance procedures are most stringent. Very few units will survive these measures. It is therefore also requested by HPMA that number of samples be reduced by 50% for initial 2 years of the QCO until the producers get settled and familiar with QCO compliance.