Executive Summary of the Advertising Standards Authority rulings in the case between Identipet (Pty) Ltd, and GetMeKnown.
Identipet (Pty) Ltd lodged seven complaints with The Advertising Standards Authority of South Africa against dishonest/misleading and false claims made in advertisements by GetMeKnown for their Chinese manufactured microchips and scanners, which appeared in print, on the Internet, and on their packaging.
In two separate rulings (7 May and 31 August 2012), the ASA upheld the complaints and has ruled 100% in favour of Identipet.
In summary the rulings of the ASA, against GetMeKnown’s claims are as follows:
- 1. GetMeKnown microchips are not ISO 11784/5 compliant – as claimed.
- GetMeKnown scanners do not conform to ISO 11784/5 standards – as claimed
- GetMeKnown microchips are not ICAR approved, nor ICAR certified – as claimed. Important: ICAR headquarters in Rome confirmed that the microchips of GetMeKnown are not ICAR compliant (as claimed in the fraudulent certificate from GetMeKnown’s website).
- GetMeKnown scanners do not read FDX-A technology (which is the majority of the chips in South Africa) – as claimed.
- As these scanners do not read FDX-A microchips (as above) they are not “ideal” for use in the veterinary practice/welfare orgs. etc – as claimed
- GetMeKnown microchips cannot track animals, – as claimed.
- GetMeKnown microchips do not have unique numbers – as claimed
The most serious lie in GetMeKnown claims, is their microchips have unique numbering. This claim has been firmly “kicked into touch” by the German arbitrator Dr. Huther, who described the code numbering as “senseless”. The serious implications of this lie, are that they are not ISO (nor ICAR) compliant as usually required internationally for registrations, export, insurance, medical aid etc. Their uniqueness certainly does not stand up in a court of law, and is a passport for duplication, identity theft and fraud!
It is only as a result of Identipet’s vigilance which prompted the Advertising Standards Authority to investigate, and discount the blatant lies. GetMeKnown have now been ordered by the ASA to remove all these false, dishonest and misleading claims with immediate effect according to the ASA’s Procedural Guide and regulations.
RULING OF THE ASA DIRECTORATE
In the matter between:
IDENTIPET (PTY) LTD – COMPLAINANT
DIGIPROFS CC – RESPONDENT t/a GETMEKNOWN
7 May 2012
GETMEKNOWN / lDENTlPET/ 19769
Identipet lodged a competitor complaint against the respondents advertising claims appearing on its website www.getmeknown.co.za and its packaging as featured on the website, Both parties operate in the industry of implanting microchips in pets for tracking and/or identification purposes. The complainant specifically took issue with respondent’s claims that its:
1) Microchips / transponders are ISO 11784/5 compliant,
2) Scanners / readers/ receivers conform to ISO 11784/5 standards,
3) Microchips / transponders have unique numbers,
4) Readers / scanners / receivers are”… ideal for companion animal veterinary practices, pet rescue shelters…”
5) Microchips/ transponders _are “ICAR” approved and have IiCAR Certification”,
6) Scanners / readers / receivers operate at a frequency of 134.2KHz and 125KHz
7) Microchips / transponders can be tracked.
ln essence, the complainant submitted that the respondent’s claims are false, and mislead people into expecting qualities and capabilities that are simply not applicable to the products. The relevant details of the complaint will be dealt with below.
RELEVANT CLAUSES OF THE CODE OF ADVERTISING PRACTICE
The complainant identified the following clauses of the Code as relevant:
Section 1, Clause 1.1 – Legal, decent, honest and truthful
Section ll, Clause 2 – Honesty
Section ll, Clause 4.1 – Substantiation
Section ll, Clause 4.2.1 – Misleading claims
The respondent explained that it provides an ideal turnkey solution for pet owners, veterinary practices and farmers for pet identification. It volunteered to amend some of its claims (which will be dealt with below), and argued the merits in relation to the claims that it has unique microchip numbers, and that its products are “ideal for use”.
Insofar as the references to “tracking” animals are concerned, it explained that its intention was to refer to “tracking” in the sense of keeping track of animals (for example farmers who keep track of ostriches when they come in for feeding). ln this sense, “tracking” is synonymous “identifying” as the term is often used in other industries that monitor stock and do not necessarily track and locate it like vehicle trackers. The example of furniture being allocated and identified was used. It also tendered a potential amendment of the claim, which will be dealt with below.
ASA DIRECTORATE RULING
The ASA Directorate considered the relevant documentation submitted by the respective parties. For the sake of convenience, the Directorate retained the numbering used at the top of this ruling to correspond with the relevant claims.
The first two claims at issue were:
1) That the respondent’s microchips / transponders are ISO 11784/5 compliant,
2) That its scanners / readers / receivers conform to ISO 11784/5 standards.
While the respondent explained its rationale for making such claims, it also undertook to make it clear that its equipment is “compatible to rea ISO 11784/85 and FDX-B standards”, and that its microchip is ISO 11784/5 and FDX-B compatible to be read by all ISO [Compliant] Scanners”.
The complainant took issue with the above claims on the basis that the products had not been manufactured or verified according to the relevant procedures to. Claim compliance with these ISO standards. The proposed amendments therefore appear to address the concerns raised insofar as these claims are concerned, because it no longer creates the impression that these standards have been met, but rather communicates that the respondent’s products can be used on equipment that meets such standards.
The undertakings in this regard are therefore accepted on condition that the respondent amends all relevant claims with immediate effect within the deadlines stipulated in Clause 15.3 of Procedural Guide.
5) The claim that the respondents microchips / transponders are “ICAR” approved and have “ICAR Certification”.
In essence, the complainant submitted that the respondent’s ID numbers for its chips do not match those issued by or approved by ICAR (International Certification for Animal Recording). Correspondence from lCAR in support of this was also submitted.
The respondent explained that its microchips are produced by the same facility that produces ICAR certified microchips, but that these chips are simply programmed differently. It also denied ever claiming to be ICAR certified, but undertook to revisit the website to check for any possible misprints. In relation to the claim in general, it undertook to “… remove the ICAR phrase from our website [un]till our microchips are an approved range of codes from ICAR”.
This undertaking equally appears to address the complainant’s concerns, and is therefore accepted on condition that any and all inappropriate references to ICAR are removed with immediate effect within the deadlines stipulated in Clause 15.3 of the Procedural Guide.
6) The claim that its scanners / readers / receivers operate at a frequency of 134.2KHz and 125KHz.
The complainant conceded that the respondents readers operate on a frequency of 134.2KHz, as this corresponds with FDX-B microchips supplied by its supplier.
However, the 125KHz frequency only applies to FDX-A microchips, which the respondent is currently unable to read. The complainant made the point that this fact was verified by the respondent’s suppliers in China.
The respondent submitted that it will correct its material to display the correct frequency only. Only once it has implemented its long-range scanners will it use the appropriate frequency again.
This undertaking appears to address the complainant’s concerns, and is therefore accepted on condition that the respondent effects the relevant changes with immediate effect within the deadlines stipulated in Clause 15.3 of the Procedural Guide.
The Directorate also draws specific attention to the requirements of Clause 15.5 of the Procedural Guide, which effectively require advertisers to remove offending claims from all media irrespective of whether or not the complainant made reference to such media.
3) The claim that the respondents microchips / transponders have unique numbers. ‘
The complainant disputed this on the basis that the reference to being “unique” implies that there are no other microchips in existence that has, or is capable of having, the same ID code or number. This is paramount in the security that the chip affords both animal and owner. He explained that microchips that are not ICAR registered and do not use a country code according to ISI 3166-1 are vulnerable to duplication.
According to international authorities, proper identification depends, inter alia, on uniqueness of the relevant ID codes, as well as a properly maintained database to store such unique codes. The complainant submitted that the respondent has not implemented any of these safeguards. In this instance, the complainant specifically noted that “… the Respondent has severely breached the following highlighted sections of the ASA code …” The only section highlighted in a similar manner was the provisions of Clause 2 of Section il (Honesty). The Directorate therefore interpreted this to mean that this particular complaint was lodged only in terms of the provisions of this clause. While the provisions regarding Clause 4.2.1 of Section ll were printed in bold, they were not underlined in the same manner as those of Clause 2 of Section ll. lt was therefore not clear whether the complainant intended for the Directorate to consider these as welli. In any event, it stands to reason that if the claim was found to be exploiting consumer credulity, it would be misleading, and vice versa.
The respondent agreed that other chips could be programmed to carry the same ID number, but explained that its database would immediately pick up any duplications, and therefore prevent duplicates from being registered on its own database. It added that there is no requirement in South Africa to subscribe to or comply with ICAR, and in reality, any person can allocate any ID number to its microchip, even within the ICAR range. Its reference to “unique” relates to the fact that its numbers are uniquely allocated and maintained on its database.
It is not entirely clear from either the complaint or the response what the potential risk or harm in having duplicate microchips would be. It would appear, however, from the respondents website, that its claim and intended message is that a customer would purchase a chip, allocated with a specific 15-digit number, and have it implanted in his pet or livestock. This chip would then show up on a scanner, revealing the relevant number, which in turn can be used via a facility on the respondents website to track down the owner as well as some information about the relevant animal.
The information supplied by the complainant (from the International World Small Animal Veterinary Association as well as a document claimed to emanate from “ISO TC23/SC19/wg N308rev3” suggests that microchip ID codes should be readable from any reader and that a unique number should be allocated. The recommendation is made that either a manufacturer code, or country code should be used, and if the former is preferred, the manufacturer should install and maintain a proper database.
From the response received it would appear that this is exactly what the respondent has done; allocated its own “unique” numbers or manufacturers codes and maintained a database that stores this information.
Accordingly, the references to “unique” numbers or ID codes are not dishonest in a manner that contravenes Clause 2 of Section il (or Clause 4.2.1 of Section Il of the Code for that matter).
This aspect of the complaint is dismissed.
4) That the respondents readers / scanners /receivers are “… ideal for companion animal veterinary practices, pet rescue shelters …”
The claim in its entirety reads as follows:
“PT180 Series RFID Reader series offers three durable and versatile radio frequency identification (RFlD) reader models that are ideal for companion animal veterinary practices, pet rescue shelters and low-volume manual scanning operations. Additionally, they can serve as effective back-ups for animal identification and tracking management. They can read multiple FDX-B ISO 1784/5 compliant microchip/tag technology”.
The complaint here is based on the knowledge that the respondent’s readers can only read PDX-B protocols or microchips, whereas the majority of chips available in South Africa are FDX-A. This renders the claim dishonest and misleading.
The respondent argued that it offers an ideal turnkey solution for animal owners, farmers and breeders. The mere reference to “ideal” cannot be seen as comparative or disparaging. lf, for example, a tent manufacturer sells a tent with a canopy and its competition does as well, both are entitled to claim that their product is ideal. `
When considering this matter, the Directorate was mindful of the provisions of Clause 4.2.2 of Section lll (Puffery). This effectively allows for value judgements and matters of opinion or subjective assessment to be used in advertising provided that it is clearly seen to be an opinion and not used to mislead about any aspect that is capable of objective assessments.
Reading the claim in context, the Directorate is satisfied that it is presented as an opinion. Referring to its product as “ideal” does not suggest any type of superiority by objective comparison, and the Directorate is not convinced that a hypothetical reasonable person wouid attach such an interpretation to the claim. lt is also worth noting that the claim in its entirety is clearly contextualised in terms of FDX-B technology, and there is nothing suggesting that the respondents readers would aiso read FDX-A technology.
For the above reasons, the Directorate is satisfied that this ciaim falls within the parameters of acceptable puffery, and is therefore not in contravention of the Clauses identified by the complainant.
This aspect of the complaint is dismissed.
7) That the respondent’s microchips / transponders can be “tracked”.
The compiainant argues that the references to being “tracked” are patently faise, because the respondent’s devices do not contain a power source, meaning that no signai can be emitted, which in turn means it cannot be tracked. In reality, the respondent’s products are fitted with a capacitor, which is temporariiy powered by the RFID wave of a scanner or reader, aliowing it to be read at a distance of 7 to 1Ocrn.
The respondent repiied that its references to being tracked are intended to mean “scan the chip with our reader and then enter the code into our database for identification”. it added that it would be willing to amend its term to “scan and identify” if the ASA were to determine that the word”‘track” has a meaning that does not correlate with the reality.
Looking at the claim on the respondents website, the Directorate is inclined to agree with the complainant that the reference to being able to “track” animais would, in the mind of an ordinary consumer, likely be interpreted to mean that one would be able to track a lost animal much in the same manner as one would track a stolen vehicle or cell phone. This does not appear to match with the reality.
As such, the Directorate has considered the respondent’s proposal of amending the claim to refer to “scan and identify”, and is satisfied that this appears to match the reality, and would address the complainants concerns.
The respondent’s undertaking to amend the word “track” to read “scan and identify” is therefore accepted on condition that the amendment occurs with immediate effect and within the deadlines stipulated in Clause 15.3 of the Procedural Guide.
The respondents’ attention is drawn to the provisions of Clause 15.5 of the Procedural Guide.
Executive Summary: Dr. Huther ruled in favour of Identipet, and that the claims of GetMeKnown have not been substantiated.
In the matter between:
IDENTIPET (PTY) LTD – COMPLAINANT
DIGIPROFS CC – RESPONDENT tla GETMEKNOWN
31 August 2012
GETMEKNOWN / IDENTIPET/ 19769
According to the provided documents IDENTIPET claims that GETMEKNOWN brings products in the market of which the published information is at least partly wrong. Details of the claims are written in the documents complaint No.3 and complaint No. 4. Answers to the claims are listed in a separate document.
1. General information about ISO
The ISO 11784 (code structure) and ISO 11785 (communication between transponder and reader) have been established in 1996 with the technologies HDX and FDX-B. Three old transponder types of FDX-A technology (Destron, Trovan, Rid2000) are named in the ISO 11785 Annex-B to be used for an interim period of 2 years to be able to sell their remaining stock. Some of these manufacturers have nevertheless tried to establish their technology as a standard to create a kind of monopoly situation in dedicated markets.
Since 1998 the old technologies should not be used anymore. Unfortunately there was and still is a clear misleading information in the market, that these products are ISO. They are clearly not.
The animal code (according to ISO 11784) to be displayed on a hand held reader contains 15 digits of which 3 are either the ICAR issued manufacturer code or the country code according to ISO 3166. As there is no country with a code above 899 the manufacturer codes are all in the 9XX range. The 12 following digits are either the unique Animal ID Code or the unique National ID Code.
Where issued transponders contain a manufacturer code, the manufacturer is the responsible party for the guarantee of the uniqueness of the issued transponder code.
Where issued transponders contain a country code, the country, specifically the National Authority, is the responsible party for the guarantee of the uniqueness of the issued transponder code and to also ensure duplication of transponder codes does not occur. As such, it is therefore not the responsibility of the manufacturer to provide this guarantee, but rather the country.
The aforementioned points are of acute and particular interest in countries where the responsibility for the identification of various animal species is not assigned to an individual Ministry.
The silicon chip has a minimum of 128 bit (according to ISO 11785) of which 64 bits are used for the code structure according to ISO 11784.
The use of bit 1, the animal bit, bit 17 to 26, the country code bits and bit 27 to 64, the unique or National ID code are the relevant parts to look at.
The bit 1 is not visible and has nothing to do with the animal code; it is a bit which is relevant for the behaviour of the reader. Nevertheless it is important that the animal bit is correctly set on 1 (bit 1 = 1) as there are industrial applications like the waste management industry in Germany which uses the standard ISO 11784 (bit 1 = 0) as well and the code only varies in the first bit. If in the animal transponder the bit 1 is not set on 1, this has consequences for the readers according to ISO 11785 and to ISO 24631-6. Readers according to ISO will both not display the code at all and then need to clearly indicate “no animal code” or the code is being displayed and it has to be clearly indicated “industrial code”.
The bits 17 to 26 are dedicated to build the country code or the manufacturer code. The country code must be a valid code according to ISO 3166. The ISO 3166 shows the numeric codes for the UN letter codes for each country in the world. Ln. this table there are also numbers without any corresponding country, so no country information.
For South Africa this is ZA or ZAF or 710. All three codes are equal and valid.
For the manufacturers there is a distinguishing between manufacturers with full manufacturer code and the shared manufacturer code.
In total we have 54 ICAR approved manufacturers with full manufacturer code and their manufacturer code range is between 987 and 934.
In total we have 66 manufacturers with a shared manufacturer code which is 900, identical for all of them. To distinguish the manufacturers with a shared manufacturer code, they have been allocated an additional 3 digit code to be used in the animal ID code. This is the so called ICAR 900 allocation code.
The bits 27 to 64 stand for the animal ID. A manufacturer with a full code has the liberty to use the full code range when transponders are coded with the manufacturer code. (in total 38 bit which are 274.877.906.944 different codes)
A manufacturer with a shared code has always to use the first three digits for the ICAR 900 allocation code. Additionally the shared manufacturer is given an amount of numbers in a defined range (usually from 000.000 to 999.999 or from 000.000 to 1.999.999, which means 1 mi or 2 mi codes)
If the country code is used, the manufacturer with either a shared or a full manufacturer has to program the transponders according to the rules established by the National Authority. If no regulation for the use of the country code exists the manufacturer code has to be used.
999 is a test code, there is no guarantee for uniqueness, it is forbidden for commercial use.
Each product type (transponder size i.e. 2, 12 x 12mm or 1, 41 x 9mm) have to have an own product code approved by ICAR and published on their website.
2. Guarantee of uniqueness
At the time of the creation of the ISO standards 11784 and 11785 and of the EC regulations there was only laser programed silicon available. The ISO 11784 code was already unchangeably programed in the chip on wafer level. Today the majority of transponders are made of OTP silicon. The transponder is being built without programing the chip according to ISO 11784. The code shall be programed at any desired time of manufacturing or even after the manufacturing when the product is ready for use. Programming is only allowed for ICAR approved manufacturers.
The wafer is the first production step of the transponder. Depending on the size of the silicon chip there can be up to 20.000 chips on one wafer. In former times with the laser programed silicon sorting of transponders or producing sequential numbers was not possible, better said not payable. This is the major reason why OTP silicon has been introduced.
As the final ISO 11784 codes can be programmed at any time during or after production, the first obligation for the manufacturer is to lock the code after programming, which is a “sine qua no” for uniqueness. If this is not the case, the number can be altered at any time.
Each OTP silicon chip has a so called UID, which is a laser programmed serial number made on wafer level which can never ever be altered. It is an obligation for a respectable manufacturer to read out the UID and store it together with the programmed 11784 code in the manufacturer database. This is the second obligation to guarantee uniqueness.
This UID code is not dedicated for public use but it needs to be stored for each single transponder manufactured and programmed with an ISO 11784 code.
3. Details on Complaint No. 3
Analysing the numbers shown on page 1 in document “Arbitration on Compliant No.3” gives the following result on the first number: 111 100 000 000 168
The first three digits 111 do neither represent a manufacturer according to ICAR nor to a country according to ISO 3166, so the code in total is not an ICAR approved code. ICAR does not have numbering blocks and is the Registration Authority for ISO, so they always fulfill 100% the equivalent norms.
The second part of the code (the 12 digits) does not give any information according to the manufacturer for the traceability of the product. This is what we call a senseless code.
The correct code for Wuxi Fofia according to ICAR is a shared manufacturer code 900.
The positions 4,5,6 of the code shown are 000 and the correct way for Wuxi Fofia is 032 after the shared manufacturer code.
The rest of the numbers have to be 00 and then the range has to be in-between 0.000.000 to 1.999.999.
The only correct transponder code looks like this: 900.032.000.000.000 – 900.032.001.999.999.
The points 1-8 on page 2 are fully correct except point 8.1. as the link back to the country of manufacture is wrong whilst the link back to the manufacturer is of essential need.
On page 3 there is information for the guarantee of uniqueness missing which I described in part 2 of this document, guarantee of uniqueness. The way it is written refers to the period of time when only laser programmed silicon was available.
The describing on page 4 is not correctly understood, the product code for the 2, 12 x 12 mm glass tube transponder for Wuxi Fofia is 900018. This code is only an internal code and has nothing to do with the transponder number; the ICAR 900 allocation code is 032 for the 2, 12 x 12 mm glass tube.
Nothing to be said to page 5,6,7,8.
Page 9 is absolutely correct.
Page 10 goes back to the uniqueness, which can only be guaranteed if the manufacturer is having a database in which the data of UID and the 11784 codes are stored together.
4. Details on Complaint No. 4
A reader can only be called an ISO 11784/5 compliant reader if it reads both technologies HDX and FDX-B. As FDX-A is not part of the standard this technology has no importance for the naming of the reader. A reader which only reads either HDX or FDX-B has to be called: RFID reader for HDX or for FDX-B ISO 11784/5 transponders. Then the naming is absolutely correct, otherwise it is misleading.
The time of trading a technology has no importance on ISO level. If a reader has to read several protocols, particularly if they are not ISO, this is to be regulated by a National Authority. Nevertheless it is logical for practical reasons that the readers offered in the South African market should at least read the technologies FDX-B and FDX-A. Today there is also a 12mm implant on HDX protocol available and HDX is part of the ISO 11785. The same problem could occur again.
The question is not if a reader is ideal or not, the question is if it is conforming to ISO and which requirements in the National market are needed.
5. Respondent document
It is not my task of validating if the wording of the respondent has given unfair advantage. My task is only to evaluate the ISO part.
The answers to complaint No. 1 and 2 are not correct.
“The Reader is compatible to read ISO 11784/5 and FDX-B standards” is wrong the correct saying is: the reader reads all FDX-B transponders according to ISO 11784/5.
The term “microchip” for a transponder is wrong as the microchip is only part of the transponder, which has an antenna in addition and a surrounding material which needs to be Bio glass of the class 8625. Careful, there is a world patent by a German company and this glass is always green. When the glass is not from Schott and claimed to be class 8625, the provider needs to have a patent license or the glass is not Bio glass.
The wording “Our Microchips is ISO 11784/85 and FDX-B compatible to be read by all ISO compliant scanners” is not correct, it needs to be said: “Our transponders are conform to ISO 11784 and to ISO 11785 FDX-B.” This is the general way of correct expression, but this is not true concerning the transponder numbers already analysed in complaint No. 3.
The answers to complaint No. 3 is not sufficient, the requirements are described in the part 2 of the document, guarantee of uniqueness. The explanation is insufficient and does as such not guarantee the uniqueness above the transponder range except when the silicon is laser programed.
ICAR is a world-wide officially accepted organisation and is the Registration Authority for ISO, so in charge to take care of the handling of the codes and the product certification and surveillance. Nobody needs to subscribe to ICAR. At the moment when a manufacturer is granted a manufacturer code by ICAR it is on behalf of ISO and each manufacturer has to subscribe several documents which the manufacturer Wuxi Fofia did as well. Subscribing these documents means to respect the guidelines and the rules. ICAR is not an organisation that has and needs National Authority; ICAR takes care of the procedures and is the monitoring body. ICAR is the organisation which has the power to withdraw a product code as well as a manufacturer code.
The saying “that programing in the range used by lCAR” is wrong, it is correct to say the programing is made according to the ICAR issued manufacturer code and code range. The describing of guaranteeing uniqueness is misleading and false. It is possible to duplicate the ISO 11784 code, but the guarantee of uniqueness is the link to the serial number, the UID.
It is absolutely irrelevant if someone is living in the US or SA, it is relevant if someone uses an ISO standard where he has got the permission to use it by the Registration Authority in a clearly described way. The respondent claims that their turnkey solution secures a unique microchip number. Unique in the sense of ISO means world-wide unique number, not only unique for the manufacturer in his database. When a manufacturer uses the ISO standard he has to be conforming to the rules. If the uniqueness is the turnkey solution then there must be a verifiable proof for it.
The word “ideal” is certainly misleading in conjunction with the offered transponder codes. It neither is obvious that this range of transponder codes is programed with a valid country code according to ISO 3166 nor with a manufacturer code according to ICAR.
Tracking in the identification market is related to the production as well as in the pharmaceutical industry. It means that the transponder can always be traced back to the manufacturer and at least to the first point of sales. What the respondent is talking about is identify and reunite lost and found animals.
Indicating the frequency of 134, 2 kHz is the frequency of ISO 11785. Mentioning 125 kHz does not mean the reader is capable of reading FDX-A as 125 kHz is as well the typical frequency for LF industry applications. In the advertising it has to be expressed that it is 125 kHz FDX-A animal or FECAVA standard.
6. Conclusion and Recommendation
The complaints are relevant even if the formulation and the details are not 100% precise. The whole issue around animal identification is much more complex and can be handled in the correct way if the documents have been understood and the manufacturer as well as the distributor is willing to respect the ISO rules. Claiming that America and South Africa do not subscribe to ICAR is a senseless argument;
if a technology is used then it has to be used in the way it is allowed, this is particularly the case within ISO. The ISO standards are developed and established to help consumers around the world.
I strongly recommend a homologation procedure on a National level to be able to establish guidelines, consequences and penalties. ln this homologation document the coding as well as the readers to be used can be homologated. This might become part of another document.
The fact of claiming guarantee of uniqueness has to be provable and if the manufacturer is based in China, it is relevant to have a company registered in the South African register of commerce to be able to have legal basis. If this company is not able to proof what they are claiming then a visit at the manufacturing plant is needed to inspect the database for verification.
Essen, August the 31” 2012 Dr. med. vet. Sven Huther