对进口并销售无许可批件的涉水产品进行处罚的主要依据是《生活饮用水卫生监督管理办法》第二十七条,但是在具体的适用过程中存在许多值得思考的问题,比如进口行为定性、违法所得的计算、具体罚款条款的适用以及自由裁量等。作者结合案例,详细分析了该类案件在行政处罚过程所遇到的各类问题,并展开分析讨论。 The main basis for penalizing the import and sale of wading products without a license is the provision of Article 27 of the Measures for the Administration of Sanitary Supervision of Domestic Drinking Water. However, there are many issues worth considering in the specific application process, such as the qualitative , The calculation of illegal income, the application of specific terms of the fine and discretion. In combination with the case, the author analyzes all kinds of problems encountered in the process of administrative punishment in detail and analyzes and discusses them.