For manufacturers · May 16, 2026
Launching a new product: where to start conformity assessment
The manufacturer’s steps from the idea to labeling of the finished product.
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8 min
The move to item-level tracking is not so much a legal change as an operational one. The processes on the line, in the warehouse and in accounting change, and any mismatch between them is immediately visible to the counterparty.
What changes at three points
Where new work appears
01LineApplication, verification, rejection of unreadable codes
02WarehouseAggregation into boxes and pallets, checking at shipment
03DocumentsElectronic waybills with a list of codes
The weak link is usually the third: the line prints, the warehouse assembles, and the documents go out with a mismatch.
Equipment: what you will need
| Unit | Task | What to look at |
|---|---|---|
| Label printer | Printing the codes | Resolution of at least 300 dpi, stability at the speed of the line |
| Verification camera | Checking readability right after printing | Rejection rate, integration with line stop |
| Scanners | Aggregation and shipment | Speed, work with film and gloss |
| Accounting system | Storage and transfer of codes | Integration with electronic document exchange and the labelling system |
About a reserve of capacity
Calculate the load for the peak shift, not the average one. A line that barely copes on an ordinary day will start to accumulate unlabelled stock at pre-holiday volumes.
Typical errors on the line
What breaks most often
- The code is printed on a bend or seam of the packaging and is not readable
- The label is covered with a film that has a glare
- Aggregation is done “from memory”, without scanning each unit
- Spoiled codes are not withdrawn from circulation and stay as issued
How to do it right
- The place for application is chosen on a flat area and tested before launch
- Verification is placed right after printing, defects are removed automatically
- Aggregation — only by scanning, with a count check
- Defects are written off in the system on the same day
Preparation plan
Terms if you start now
Audit of processes and equipment
1–2 weeks
Purchase and installation of units
1–3 months
Integration of the accounting system and electronic document exchange
3–8 weeks
Trial operation
3–4 weeks
Trial operation is planned before the date of the transition, not after — on a real flow, details of the packaging come up.
What to check before the start
- All counterparties are connected to electronic document exchange
- The product codes are described in the catalogue and match the real range
- The information on the conformity documents in the product cards is up to date
- The procedure for rejecting and writing off codes is fixed in an instruction
- The staff is trained: who scans, who signs, who corrects errors
- There is a plan for equipment failure — manual mode and its limits
Labelling does not cancel the duty to confirm the conformity of products: the information on the declaration or certificate is given in the description of the product. If you launch a new item, it is more convenient to follow the general order — from the analysis of regulations to documents and labelling.
Aggregation: boxes and pallets
Item-level tracking makes scanning of each unit at every transition pointless — otherwise accepting a pallet turns into a procedure of many hours. The solution is aggregation: the codes of single units are linked to the code of the transport package.
- Box. The product units are aggregated into the code of a box, and then the box moves as one item.
- Pallet. The boxes are aggregated into the code of a pallet — a second level of nesting.
- Acceptance. The counterparty scans the code of the transport package and gets the whole composition, instead of scanning hundreds of units.
- Disaggregation. When a box is opened, the link must be broken in the system, otherwise the composition will stop matching reality.
The most frequent problem at the start: a box was opened to take one unit and this was not recorded in the system. After that the mismatch goes along the whole chain and comes up at the counterparty's inventory.
Aggregation is a tool, not a duty
The requirement of the law is to account for each unit. Aggregation only allows doing this without scanning item by item at every step. But if you work with retail chains and marketplaces, they usually require aggregated deliveries: without this, their acceptance cannot cope.
Defects, wrong items and losses
Real production is never sterile: codes are spoiled during printing, units are broken, surpluses and shortages are found. For each case there is its own order, and it cannot be ignored — otherwise the system and the warehouse diverge.
| Situation | What to do |
|---|---|
| The code is printed badly and does not scan | Write off the code, apply a new one, record the re-labelling |
| A unit is damaged before shipment | Withdraw from circulation with the reason “spoilage” |
| The goods are lost | Withdraw from circulation with the reason “loss” |
| A return from a buyer | Return to circulation if the code is readable; otherwise re-label |
| An unlabelled unit is found | Label before sale; it cannot be sold |
| Wrong items at acceptance | The difference is recorded in the documents, not “adjusted” by hand |
The general rule: any movement other than a planned sale must be reflected in the system. A quiet write-off “in the head” creates a balance that is listed as in circulation and comes up during a check as unaccounted products.
How acceptance changes at counterparties
Item-level tracking affects not only you, but everyone to whom you ship. In practice this means a move to electronic documents and a comparison of compositions.
- The shipment is accompanied by an electronic document with a list of codes
- The counterparty compares the actual composition with the document at acceptance
- A mismatch blocks the acceptance until it is clarified — the goods may stand in the warehouse
- Errors in aggregation are found exactly at this step, not at your line
- Work with retail chains requires agreeing the exchange format in advance
So preparation should start with a test shipment to one loyal counterparty, not with a full rebuild of the process at the whole volume.
Frequent questions for the transition period
- What about goods produced before the start? For stock there is a separate order of labelling and its own terms, different from the terms for new batches.
- Do products for export need to be labelled? The requirements are tied to circulation inside the country; for export there is its own order, and it should be clarified before shipment.
- What about samples and promotional giveaways? Transfer of goods, even free of charge, is circulation; the withdrawal from circulation must be recorded.
- Does labelling replace conformity documents? No. These are two independent duties, and they are checked separately from each other.
The last point is worth remembering more firmly than the others: having codes does not cancel the declaration, and the declaration does not cancel the codes. What exactly your products need on the conformity confirmation side — in the article on choosing the document form, and the calendar by product groups — in the material on labelling.
Check your product
Describe your product in plain words — the system will show the expected HS code (TN VED), the applicable regulations and the set of documents. Start the check.
