Question ID: 808
Regulation Reference: (EU) No 2015/2450 - templates for the submission of information to the supervisory authorities
Article: 35
Status: Final
Date of submission: 19 Oct 2016
Question
In the "Characteristics of product" section, it is required to provide, per Product ID Code (C0090) a number of characteristics. It is possible to have, for a specific Product ID Code, several different versions of a product, each with a different Product denomination (C0120), with further possible variations in Product classification (C0100), Product still commercialised (C0130) and Type of premium (C0140). Is the requirement to only have one entry per Product ID Code, giving a fairly generic Product denomination in C0120 and completing C0100, C0130 and C0140 to cover the widest possible range, or is the requirement to use a Product ID Code as many times as is necessary, covering all specific variations of the product covered by the Product ID Code?
EIOPA answer
In this case, even if the commercial product is the same, 3 different codes should be attributed for technical reasons. The ID code of the product cannot be repeated in table 2 (titled "Characteristics of product").
In this particular case the way to report the information about the product is to provide a code of the product followed by the identification number of the variant of the product. To see how this should be done from an IT perspective, please consult the List of know issues (add link and number later).
If a code is already attributed by the NCA, and the NCA attributes the same code in this situations, the same approach should be followed, i.e. code attributed by NSA followed by a variant.