对免检制度的综合分析:坚持、放弃抑或改良?

A Comprehensive Analysis on Exemption from Check System

免检制度的价值及其存废近年来受到媒体、社会大众、学者、政府等的关注。国家质检总局在免检制度制定过程中因静态思维而导致免检条件设定失当。就实施绩效而言,免检制度正面影响的作用机制存在较多问题,免检产品在获得免检资格后其销售额的增长可能主要并不在于该制度拥有的质量保障功能,而在于政府、企业、消费者、媒体及质量信号的现状等多种因素的共同作用而导致的免检标志所产生的信号功能的不当放大;由于对特定产品的功能瑕疵认知和危害测定存在难度等,免检制度的实施在产品质量方面会产生不可避免的负面影响。综合考虑多种因素,本文倾向于取消免检制度;但如果基于信息提供和执法效率提升等角度,或国家质检总局基于其他因素的考虑,认为免检制度必须存在,则应在处罚、监督、适用保留等方面对这一制度作出必要修正。

Should the Regulations of Inspection - free Status be kept, or abolished？ It has been a question in debating for years among media, public, academicians as well as administrators. Examining the performance and consequences of the regulations, this study finds that the sale growths of products being granted the status are unlikely a result of their high qualities insured by the status. Rather, they are more likely an outcome generated by amplifying improperly the inspection - free signal through complicate interactions among administration, enterprises, consumers, media and the signal itself. Because of great difficulties in inspecting product qualities and measuring possible harmfulness, the regulations as they are now would make inevitably negative impact in terms of product quality monitoring. All these are but a consequence of the vision -lack thinking of General Administration of Quality Supervision, Inspection and Quarantine （AQSIQ） in the time when the regulations were made. Therefore, this author recommends having the regulation abol- ished. Or, should the AQSIQ , due to other concerns, prefers to have the current system kept, some necessary and thoughtful modifications, in aspects of the regulations such as the punishment measure, product quality supervision and privilege reservation, must be made.