COSQC Instruction 4 of 2016 Fee Schedule

1. Key takeaways

COSQC’s Instruction No. 4 of 2016 on service fees (تعليمات رقم (4) لسنة 2016، حول استيفاء الأجور عن الخدمات) was issued under article 25 of the Iraqi Federal General Budget Law No. 1 of 2016 and signed by the Minister of Planning (وزير التخطيط) on 2016-09-20 (the signatory’s name reads inconsistently across repeated readings and is not relied upon); article 2 provides that it takes effect from its date of issue. Among the verified fee items, the only one naming anything medical is the calibration of non-commercial weighing instruments at 5,000 Iraqi dinars per unit (expressly including medical scales). In Instruction No. 4 of 2016 and the anonymously accessible COSQC pages, no dedicated fee items for medical devices, imported products or certificates of conformity (CoC) were retrieved; the remaining instructions and login-gated service pages were not obtained, and no final assertion is made. ⚠ The quality mark technical inspection fee carries an OCR ambiguity, and GRZAN adopts neither of the two numbers.

• The instruction rests on article 25 of the Federal General Budget Law No. 1 of 2016 and takes effect from its date of issue.
• The only medical-named item is non-commercial weighing instrument calibration, 5,000 dinars per unit, expressly including medical scales.
• No dedicated fee items for devices, imported products or CoC were retrieved in this instruction or the anonymously accessible pages.
• The quality mark technical inspection fee shows an OCR conflict between 25,000 (digits) and 250,000 (words); both figures are rejected.
• The negative conclusions cover only this one instruction and the anonymously accessible pages, and must never be widened into “COSQC does not touch medical devices”.

2. Legal basis

Two instruments are engaged: the COSQC fee instruction, and the budget law authorising it; the instruction was signed by the Minister of Planning and takes effect from its date of issue under article 2.

Evidence level: [first-hand, verified (official PDF, page-by-page OCR reading)]. https://cosqc.gov.iq/uploads/laws/instructions/1759721890_instruction2016.pdf (index page: https://cosqc.gov.iq/laws/instructions ).

Evidentiary boundary (read together with the conclusions): on this pass the COSQC website’s «التعليمات» section carries only Instruction No. 4 of 2016; the remaining instructions were not obtained and their existence is not confirmed. The three import-related service pages — “technical requirements for imported products”, “quality mark for imported products” and “Iraqi standard exemption” — all require login, returning «يرجى تسجيل الدخول للمتابعة» on anonymous access. The negative conclusions cover only Instruction No. 4 of 2016 and the anonymously accessible pages; it is strictly prohibited to state that “COSQC does not involve medical devices” or “Iraq has no device CoC regime”.

Verbatim extracts of the provisions:

• Legal basis: «استناداً لأحكام المادة (25) من قانون الموازنة العامة الاتحادية لجمهورية العراق رقم (1) لسنة 2016» — pursuant to article 25 of the Federal General Budget Law No. 1 of 2016.
• Entry into force: «تنفذ هذه التعليمات من تاريخ صدورها» — effective from its date of issue.
• Signature: the Minister of Planning (وزير التخطيط), dated 2016-09-20; the name reads inconsistently across repeated readings and is not relied upon.

3. Expert insights

Insight 1: read the scope first — this price list governs metrology, standards and inspection services, not market-access approval.

Insight 2: the only item naming anything medical is the calibration of medical scales. Across the entire list, the word medical appears only in «الموازين الطبية» (medical scales), under non-commercial weighing instrument calibration at 5,000 dinars per unit — the most telling fact: COSQC’s intersection with healthcare happens at the level of measuring instruments, not device market access.

Insight 3: numerical ambiguity must be disclosed, never resolved by choosing one. For the quality mark technical inspection fee, the OCR of the Arabic digits reads 25,000, while the word spelling in the same sentence reads «مائتان وخمسون الف دينار» (two hundred and fifty thousand, i.e. 250,000) — a 10-fold discrepancy. GRZAN adopts neither number and carries the item in quotations and budgets as “pending verification”.

Insight 4: falsification check — device imports require a dedicated COSQC fee or certificate: no basis retrieved here, but do not widen the conclusion. The fee list of Instruction No. 4 of 2016 contains no dedicated fee item for “medical devices”, “imported products” or “certificate of conformity (CoC)”. The boundary matters: only this one instruction was verified on this pass, and the login-gated import service pages are precisely where device CoC requirements could sit. Only two statements are firm: first, the instruction has no device, imported-product or CoC fee item; second, the only medical-related items are “medical scale calibration at 5,000 dinars per unit” and the “quality mark technical inspection fee”. It is prohibited to write “COSQC does not involve medical devices” or “Iraq has no device CoC regime”.

Insight 5: the signing ministry deserves a separate note. The ministry behind this fee instruction is the Ministry of Planning (article 27 places COSQC in the planning line), not the Ministry of Health — a second signal that the COSQC line and the Ministry of Health line run on two administrative sequences. ⚠ No inference about COSQC’s current affiliation may be drawn from the signature.

4. Practical recommendations

• Do not pre-set a “COSQC certificate fee” in quotations: no corresponding item was retrieved in Instruction No. 4 of 2016. If an agent demands such a payment, ask for the fee basis and verify it does not stem from an instruction not obtained on this pass.
• For weighing-instrument and metrology-type devices (medical scales, infusion-pump calibration devices and the like), budget at 5,000 dinars per unit — the only directly quotable medical-related amount.
• Do not quote the quality mark technical inspection fee for now; mark it “figure pending verification”, listed separately in proposals until a clear image of the original is obtained.
• When COSQC documents are needed, follow the website service entry application path first, with fees per the official notice in force at receiving. Practical estimate: any “COSQC device fee” figure outside this instruction has no official provision behind it (no official provision found).
• For every official fee a client is asked to pay, obtain a receipt and check the fee item name and amount, into a fee ledger for re-registration and audits.

5. Verification checklist

• □ Download https://cosqc.gov.iq/uploads/laws/instructions/1759721890_instruction2016.pdf and re-verify the amounts page by page
• □ Re-verify the quality mark technical inspection fee in particular: establish whether it is 25,000 or 250,000, finalising only after a clear image of the original
• □ Verify whether this instruction has been replaced or amended (index page: https://cosqc.gov.iq/laws/instructions )
• □ Full-text search «الأجهزة الطبية», «المنتجات المستوردة» and «شهادة المطابقة», confirming no device, imported-product or CoC fee items in Instruction No. 4
• □ Re-examine the boundary after obtaining COSQC’s remaining instructions (the index page carries only No. 4 of 2016) and the three login-gated import service pages
• □ Verify the scope of the authorisation in article 25 of the Federal General Budget Law No. 1 of 2016
• □ Re-check the relationship between the signing ministry (Ministry of Planning) and COSQC’s current placement; the affiliation was not definitively established on this pass
• □ Re-verify whether the cited official documents have been superseded (verification baseline date: 29 October 2026)

Regulatory information verified as of 29 October 2026.

How GRZAN can help. GRZAN provides medical device and IVD registration, quality system, authorised representative and local testing support for the Iraqi market. Our team prepares registration dossiers and legalisation chains, and supports post-market vigilance obligations. Business enquiries: info@grzanglobal.com