COSQC Imported Product Requirements Under Construction

1. Key takeaways

The COSQC website service entry does contain two services, “Technical requirements for imported products” (المتطلبات الفنية للمنتجات المستوردة) and “Application for the quality mark for imported products” (طلب الحصول على علامة الجودة للمنتجات المستوردة), but on this pass the body text could not be obtained through anonymous access: the service pages either require login (returning «يرجى تسجيل الدخول للمتابعة», meaning “please log in to continue”) or display under construction («تحت الإنشاء»), and no substantive list of requirements was obtained. This state cannot be read as “Iraq imposes no technical requirements on imported products”, and it equally cannot be read as “mandatory technical requirements exist”. When threshold information does not sit in the public area, compliance confirmation cannot rely on browsing the web alone; this article makes no final assertion. GRZAN’s recommendation is to hedge the risk on the assumption that “requirements may exist but cannot currently be checked”.

• Two import-related service pages exist on the COSQC site, but neither yielded substantive text through anonymous access.
• Two page states were observed — login required and under construction — and neither maps conclusively to a specific page on this pass.
• The common feature is that anonymous access obtained no body text, so no final assertion is made about whether requirements exist.
• Cross-reading with article 28 points in the same direction, but the two findings together still do not prove absence of requirements.
• The hedge: prepare a complete conformity evidence package against the international standards applicable to the product, ready for submission at any time.

2. Legal basis

Three sources are engaged. The first two are COSQC service pages whose substantive content was not obtained on this pass; the third is the fee instruction verified through OCR of the official PDF.

Evidence level: the first two rows are [first-hand, verified (page level; body text not obtained)] — the URLs are https://cosqc.gov.iq/service/service-completion/imported-products-requirements and https://cosqc.gov.iq/simple-service/quality_mark_request respectively; the third row is [first-hand, verified (official PDF, OCR reading)].

Verbatim extracts of the page text:

• «يرجى تسجيل الدخول للمتابعة» — please log in to continue. Returned on anonymous access; the body text is not displayed.
• «تحت الإنشاء» — under construction. The other state observed during this visit.
• Note: the correspondence between the two states and the two pages could not be fixed one by one on this pass; the common feature is that anonymous access obtained no body text in either case, so this article makes no final assertion about whether requirements exist.

3. Expert insights

Insight 1: three explanations are possible for the missing body text, and GRZAN attributes it to none of them singly. First, the page may require login, with content open only to registered users or specific roles; second, the page may still be under construction, with requirements not yet drafted; third, a system migration may have left the content temporarily missing. The three situations imply entirely different intensities of obligation, and the evidence gathered on this pass cannot distinguish them. Reading “no body text obtained” directly as “no requirements” is the most common misreading of pages of this kind.

Insight 2: cross-reading with article 28 points the same way, but neither finding constitutes a conclusion. Instruction No. 4 of 2016 contains no dedicated fee item for imported products, and “the technical requirements page yields no body text” points in the same direction; yet the two findings combined still cannot prove that there are no requirements — administrative requirements are not necessarily paired with fee items, nor necessarily synced to the website in real time. GRZAN presents the two findings side by side and lets readers see the shape of the evidence, rather than drawing the conclusion on their behalf.

Insight 3: how should the risk be hedged? Since certainty is unavailable, prepare an evidence package that could be submitted even in the worst case, instead of waiting for an official checklist: build complete conformity evidence against the international standards applicable to the product (for example the IEC 60601 series and the ISO 10993 series), with test reports and declarations of conformity attached, and keep the technical documentation in a state where it can be submitted at any time. Then, whenever a checklist comes online, nothing needs to be built from scratch — the real cost has never been “preparing too much”, it is “rushing at the last minute”.

Insight 4: horizontal comparison — Saudi Arabia has an explicit checklist; Iraq does not. The Saudi SASO/SABER system provides an explicit conformity procedure for imported products, a list of applicable standards and a system entry point, so companies can simply follow the map; the corresponding public checklist for Iraq remained unobtainable as of this evidence pass. For companies deployed across multiple markets, using the Gulf-side conformity evidence package as the baseline and then adding or removing items according to the actual requirements applied by Iraq at the time of receiving is the most cost-effective path.

Insight 5: the “login required” layer actually strengthens the case that this cannot be self-checked. When threshold information does not sit in the public area, compliance confirmation cannot rely on browsing the web alone: either register a COSQC account and enter the system to read the original text, or have an entity or agent in Iraq obtain written confirmation from COSQC. GRZAN reserves a dedicated buffer for this item in the Iraq project schedule: a window for supplementary documents and remediation is set aside, and “awaiting official confirmation” is carried as a trackable task item rather than written as “none” in the risk register. Practical estimate: the length of the buffer is a GRZAN recommendation (no official provision found).

4. Practical recommendations

• Prepare technical documentation and test reports to the highest standard among the target markets, so that they can be submitted at any time. Practical estimate: no official provision was found for the specific list of standards on the Iraqi side (no official provision found).
• Re-check the COSQC “technical requirements for imported products” page on a fixed cycle, recording the before-login and after-login display states with screenshots, building a timeline of evidence.
• When the quality mark is needed, register an account through the website service entry and apply, keeping the submission receipt; a “cannot display” message in the logged-out state does not mean “no need to apply”.
• In client proposals and quotations, list this stage separately as “pending official confirmation”, promising no deadline and pre-setting no fee. Practical estimate: no official provision found (no official provision found).
• If tender documents contain formulations such as “a COSQC certificate must be obtained”, require the tendering party to provide the Arabic document title and publication date; absent these, handle it as “no such requirement” and leave a written record.

5. Verification checklist

• □ Access https://cosqc.gov.iq/service/service-completion/imported-products-requirements and record the current display state (login required / under construction / live)
• □ Re-check the page after registering a COSQC account and confirm whether the content is open only to logged-in users
• □ Search whether COSQC has published a downloadable PDF or ministerial instruction on “technical requirements for imported products”
• □ Search in Arabic using «المتطلبات الفنية للمنتجات المستوردة», looking for mirrored or reposted versions
• □ Verify the current entry point and required documents of the quality mark application page (https://cosqc.gov.iq/simple-service/quality_mark_request )
• □ Re-check whether any dedicated technical regulation or mandatory standards list for medical devices has appeared
• □ Re-verify whether the official documents cited here have been superseded by later instructions or resolutions (verification baseline date of this article: 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