CCC Compulsory Certification in China
CCC Compulsory Certification in China
By Dr. Wolfgang Kreinberg, TÜV SÜD Product Service GmbH, Munich, Germany
published: May 2007 - EMC Compliance Journal
1) Legal requirements in China, comparison to USA and Europe
The implementation of the CCC (China Compulsory Certification) scheme in 2003 followed the request of World Trade Organisation for harmonisation of legal requirements for certification regulations for domestic and imported products. In principal it is a harmonisation of standards, catalogues, marks, and fees following international standards. The CCC certification scheme covers products related to human life & health, animals, plants, environmental protection and national security. The legal requirements are described in several levels of laws and principles.
1.1 Fundamentals of China Compulsory Product Certification System (CCC Certification)
The system is based on the following Laws:
- Product Quality Law of the People’s Republic of China
- Import and Export Commodity Inspection Law of the People’s Republic of China
- Standardisation Law of the People’s Republic of China
These laws are supported by the regulations “People’s Republic of China on Certification and Accreditation” (effective November 2003) and by the “Rules for Compulsory Product Certification”. They are further supported through regulatory documents, which have to be studied carefully, before bringing products onto the Chinese market. The applicable regulatory documents are listed below:
- Rules for Compulsory Product Certification Mark
- First Catalogue of Products Subject to Compulsory Certification
- Implementation Rules for Compulsory Product Certification
- Rules for Structural Fee Chart of Compulsory Product Certification
- Rules for Implementing Compulsory Product Certification
1.2 Competent Authority
Responsibility for the CCC system is with CNCA – the Certification and Accreditation Administration of the People’s Republic of China which undertakes unified establishment, administration and supervision over the CCC certification scheme.
1.3 The Principals for the CCC Certification System:
The system is based on four principles
(1) “Four unifications”
- Unified technical regulations, standards, and conformity assessmentprocedures
- Unified catalogue
- Unified certification mark
- Unified structural fee chart
(2) It follows relevant international standards and guides for certification
activities. During an international congress on product certification in June 2006 the representative of CNCA gave this clear political message: “The establishment & operation of CCC certification system, the operations
of certification, testing and inspection bodies, as well as rules and procedures for performing certification include and are based on ISO / IEC Guides and Standards. However it should never be forgotten that there are still national Chinese standards, which have to be taken into account”.
(3) Market access system
One simple principle applies:
Products within the CCC certification catalogue may be released from the manufacturer, marketed, imported or used for any commercial purposes only after they are certified and have the CCC mark displayed.
(4) It encourages international bilateral and multilateral recognition. CNCA stresses that the main principals for recognition are equality and mutual benefit.
1.4 Implementation of CCC certification:
(1) Certification Bodies designated by CNCA implement the compulsory product certification, grant certificates and CCC Marks, and carry out follow-up inspections.
(2) Testing and Inspection Bodies designated by CNCA are entrusted by the certification body to provide product test reports and corresponding factory inspection reports.
There are currently 14 Certification Bodies and 136 testing laboratories designated by CNCA to implement the CCC certification scheme.
The CCC scheme can be described as:
Market access = Type Test + Initial Factory Inspection + Follow Up Inspection
This is more precisely described by six certification modules:
- Design review and analysis
- Type test
- Sample examination on manufacturing site
- Sample examination on market
- Quality system auditing for manufacturing site
- Follow up inspection after approval
1.5 China Compulsory Certification Mark
The CCC Mark is actually a combination of twoprevious systems, which can be combined with letters:
Safety Mark “S”
EMC Mark “EMC”
Safety & EMC “S&E”
1.6 The product catalogue subject to CCC Certification
Within common understanding, there is only reference to the first catalogue of products which covers:
Electrical wires and cables, switches for circuits, installation protective and connection devices, low-voltage electrical apparatus, small power motors, electric tools, welding machines, household and similar electrical appliances, audio and video apparatus, information technology equipment, lighting apparatus,
telecommunication terminal equipment, and medical devices.
However, there is a second catalogue for customs with additional requirements as well, which is:
Products Catalog for China Compulsory Certification
State General Administration of China for Quality Supervision and Inspection and Quarantine (AQSIQ), China National Regulatory Commission for Certification and Accreditation, July 1st, 2002, example given below:
HS Code: 40119900.99
Commodity name and remarks: Other new pneumatic diagonal tire (for the other usage, new pneumatic tire, non-herringbone tread)
Certification application scope: Only for the products according to GB9743, GB9744 and GB518
1.7 Differences and similarities with western systems
(1) European Directives
Although most European Directives use the manufacturers declaration as the prime conformity assessment scheme, there are directives where a Notified Body has to be involved. These Notified Bodies must be located in the area of the European Community. In most cases European Harmonised Standards are applicable. However there is no mandatory certification mark like CCC in Europe. The European CE marking is not a certification mark which is granted by a Notified Body, it is a marking which is affixed by the manufacturer under his responsibility in all cases, even if a Notified Body has to be involved.
(2) NRTL programs in USA
In the USA and Canada many products need the involvement of a NRTL (National Recognized Testing Laboratory) accredited by OSHA (Occupational Safety and Health Administration). Legal requirements in most cases prohibit the acceptance in other countries like China because the reciprocity of safety requirements is not given on national level. The NRTL Mark as such is mandatory for the listed products; the applied standards have to be US based standards such as ANSI and UL.
2) The way to obtain the CCC mark
2.1 Compulsory Product Certification Flow Chart
In the first step the applicant has to identify the product category and applicable standard(s) before applying.
The application is comprised of three activities - initial application by the client, cost estimation by the DCB (Certification Body) and formal application according to CNCA procedures. The necessary technical documents are:
- Application form for CCC-Approval
- Factory Questionnaire
- Product Description Report
- Declaration of Conformity (in accordance with relevant Chinese {GB} Standards)
The pricing consists of six parts, the final approving fee being determined by the DCB.
The designated testing laboratory (determined by the DCB and not by the manufacturer, applicant or hisagent) performs the testing according to the applicable standards. These may be international standards such as IEC standards. However there may well be Chinese standards in addition (National, Sector, Province or Enterprise Standards).
In China there are mandatory and voluntary standards. Standards concerning protection of human health, public and private property, security and safety, and those enforced by laws and administrative regulations are mandatory standards, others are voluntary.
National standards shall be developed for technical requirements needed to be unified nationally.
Sector standards may be developed for which no national standards are available but unified technical requirements are needed in a certain Sector field.
Province standards may be developed for which neither national standards nor Sector standards are available, but unified requirements for safety and hygiene of industrial products are needed within a province area.
Enterprise standards (private standards) may be developed for which no national standards, sector standards and province standards are available. If the national standards, sector standards and province standards have been developed, Enterprises are encouraged to develop the enterprise standards which strictly meet the requirements of national standards, sector standards and province standards.
Factory inspections are required to be carried out on successful completion of testing. The inspector(s) for the initial factory inspection is selected by the DCB in all cases. The inspection teams will generally take one to four man days to evaluate the quality management system and the production of the tested sample(s). European inspectors may be sub-contracted by the DCB after they have been trained and registered in China; however practical experience shows that the majority of inspections are still carried out by Chinese inspectors.
The certification decision will be given within 90 days after the acceptance of application; however this is not the calculation from the day of the initial application. It is 90 days after all necessary documents are available at the DCB, e.g. application, test reports (safety & EMC).
The certification decision together with the certificate provides the necessary registration number. The CCC
labels for the product have to be purchased by the DCB or, upon application a printing licence may be granted to print the CCC label directly on the product itself. After this and the payment of the bill, the certificate will be issued to the client, who now can market his products in China.
Follow-up inspections are necessary to maintain the certificate. The factory inspectors are always determined by the DCB in all cases. The inspection teams will generally spend one to two man days evaluating the quality management system, the production of the tested sample(s), the comparison of the components list and the correct application of the CCC label.
Statistics relating to issued CCC marks as of December 2005:
Certificates:
175,127 Total
162,931 Domestic
13,699 Import
Factories:
37,008 Total
33,702 Domestic
2,524 Import
The question of alternate routes to obtain CCC certification is often asked. A representative of CNCA stated in June 2006 that the IECEE CB Scheme is an important alternate route. China recognises 12 product categories of the IECEE CB Scheme, which is a good alternative solution for certification. Looking at the 2005 IEC statistics we can see that China is the largest market for CB Certificates and is also one of the largest markets to recognise CB Certificates. Experience of manufacturers has clearly demonstrated that the IECEE CB scheme is a valuable vehicle for obtaining China Compulsory Certification and the CCC Mark.
3) What else is expected in the near future?
New requirements for automotive parts will be mandatory within the CCC scheme:
CNCA-
02C-055: 2005 Horn for Motor Vehicles
02C-056: 2005 Retro-reflector for Motor Vehicles
02C-057: 2005 Brake Hose for Motor Vehicles
02C-058: 2005 External Lighting and Light Signaling Devices for Vehicles
02C-059: 2005 Rearview Mirror for Vehicles
02C-060: 2005 Interior trimming material
02C-061: 2005 Door Lock and Door Retention Components
02C-062: 2005 Fuel Tank for Motor Vehicles
02C-063: 2006 Seat and Seat Headrest Products for Motor Vehicles
02C-064: 2005 Rearview Mirror Products for Motorcycle
02C-065: 2005 External lighting and light signaling devices for motorcycles
And in the near future we will have requirements for:
Energy efficiency
Noise restrictions
Restriction of hazardous materials
Whereas in the field of energy efficiency we already have the situation that certain household refrigerators and room air conditioners are covered by the mandatory labeling system since 1st March 2005.
Moreover, standards covering 21 products are already available; legal requirements and implementation is pending for:
- Householder appliances: 8
- Lighting products: 6
- Commercial equipment: 2
- Industrial equipment: 4
- Passenger cars
Importers and manufacturers are subject to supervision and inspection and have the following obligations: - Test energy-efficiency for their products
- Identify the information for the label
- Print the label and attach it to products
- Maintain the compliance of the label information
- Register the label to DCB
With regards to noise restrictions, requirements are already in place:
- Obligatory since 1st August 2005
- Technical requirements in GB 19606-2004
- Some product categories mandatory (e.g. refrigerators, air conditioning, washing machines, microwave ovens )
However no Chinese test report, certification, registration, or labeling are currently required.
These products are controlled by market surveillance in China.
For hazardous materials China will define requirements - “Chinese RoHS”. However it is not yet clear whether European RoHS compliant products / materials will be
accepted in China.
Within the next few years we expect to see requirements for:
(1) Waste management of electrical and electronic equipment
(2) Social responsibility
4) Potential for improvement
Even if schemes are clearly described in laws and regulations, there is always
room for improvement, not at the expense of reduced safety or quality but for facilitation of trade.
- Customs Code Catalogue should be clearer and unambiguous e.g. a link between CCC requirements to products and HS codes
- Access to database of all CCC certificates
- CNCA announcements and AQSIQ orders should be provided in English
- Avoid double testing in China, e. g. telecommunication equipment needs several type approvals
- Acceptance of test reports based on international standards
- IECEE CB Scheme
- Recognition of product safety tests as well as EMC tests - Avoid deviations from IEC Standards
- Acceptance of accredited European laboratories for CCC tests
5) Summary
The Chinese CCC scheme shows some similarities to European and American schemes, e.g. the combination of international and national standards, requirements for dangerous products before they may be placed on the market. This situation is well known to western manufacturers.
However the CCC scheme has some more stringent requirements such as labeling, use of laboratories, and inspectors.
With good preparation and early involvement of competent consultants the Chinese
market will continue to be more than interesting!
