A Rigorous Certification and Factory Inspection Process
Since joining the World Trade Organization (WTO) in January of 2002, Taiwan has implemented several new regulations regarding its international trade. Most of the national Taiwanese standards established in this context are based on existing international standards from the International Standards Organization (ISO) and the International Electrotechnical Commission (IEC).
In Taiwan, it is against the law to import, buy, sell, use, distribute or trade products that require Taiwanese certification if they do not have the proper mandatory certification. It is also unlawful to mark products as certified if they have not been approved as such.
As in other WTO member countries, Taiwan has assembled a system of certification and national certification authorities. The Taiwanese Ministry of Transportation and Communications (MOTC) is not only responsible for issues concerning the transportation and communications administration, but also the wording and construction of laws and regulations covering these areas. In 2006 the MOTC decided to split up the areas of vehicle certification and testing in an effort to improve vehicle safety. In 2009 the Vehicle Safety Certification Center (VSCC) was established, which today is fully responsible for certifications in the automotive sector under the authority of the MOTC.
What is Subject to Certification in Taiwan?
Not every automotive component is subject to certification in Taiwan. But the certification scope is generally similar to the scope of products covered by the European ECE standards. Based on the type of testing, the VSCC divides the products into three product categories, categories A, B and C.
Automotive interior trimming material, seats, headrests, fuel tanks and safety belt assemblies are a just few of the components that require certification in Taiwan. However, a specific evaluation as to whether a certification is needed or not should be executed with VSCC’s engineers directly.
The Taiwanese certification process is complex and can be difficult to maneuver. The first step is for the applicant to apply with the VSCC for a company registration. Only after the initial registration has been successfully accepted can documents for certification be submitted to the Taiwanese authority. It is very important to be aware that the application documents must be filled in correctly, since changing the documents after submission is difficult and costly.
Once the application documents have been accepted, the certification authority will determine the required amount of samples for product testing. It is important to keep in contact with the testing lab to make sure that any questions that may come up are answered promptly and do not result in delays.
If the VSCC requests that testing be performed in a Taiwanese test lab, the shipment of samples must be well organized. Shipping test samples to Taiwan can be difficult and the applicant is responsible for providing necessary paperwork and documentation. It is suggested that manufacturers chose a competent logistics provider as well as a skilled customs agent located in Taiwan to avoid any problems.
Typically, product tests are conducted by an accredited testing laboratory in Taiwan, with testing taking from two to eight weeks to complete, depending on the type of product. One of the biggest and most commonly used laboratories is the Automotive Research & Testing Center (ARTC) in Lukang, Taiwan.
When certifying an automotive product, testing must be carried out in accordance with the international ECE regulations. Each certification unit testing is be carried out individually. Test reports issued by an accredited Taiwanese laboratory are prepared in both Chinese and English.
For certain types of automotive products, the VSCC may accept test reports from test laboratories outside Taiwan. However, it is important to confirm in advance with the VSCC whether a test report from an external laboratory will be accepted. In cases where a test report does not fulfill the requirements of VSCC, it can be rejected and additional testing at VSCC may be required.
As soon as test reports are available from ARTC, they are sent to the VSCC and the applicant. Upon successful completion of testing, the application for an Examination Report can be then submitted to the VSCC. Once the certificate or examination report has been issued, the applicant may apply for marking permission. The accepted Examination Report serves as the official certificate. However, not all product categories need to be marked in order to be legally imported into Taiwan. Therefore, it is recommended to check the necessity of product marking directly with the VSCC before shipping certified parts
In June, 2014, the MOTC introduced a number of new regulations including a requirement for periodic factory inspections. Since January 1, 2015, the VSCC has begun carrying out so called on-site Conformity of Production (CoP) verification inspections of automotive manufacturers to monitor and to ensure compliance with the conditions of the original certification. As of January 1, 2016, these regulations became applicable to automotive suppliers as well.
An audit by the VSCC is not a pre-condition for obtaining an Examination Report. However, an on-site audit must be conducted within the first three years after the initial registration in order to maintain the certification. A follow-up mandatory factory inspection must then be conducted at least once every three years. However, more frequent inspections may be required depending on the outcome of prior audits and on any other non-conformities linked to certified products. The VSCC will inform certification applicants regarding the necessity of a factory inspection one year in advance of the actual inspection.
Usually, the inspection takes one to two days with one inspector, or one day with two inspectors respectively. The purpose of the factory inspection is to check that the manufacturing plant complies with the certification guidelines regarding quality management and to ensure that all relevant regulations are fully met. The inspection is conducted with checklists with the focus of the inspection on the quality management system. The requirements are similar to other international quality management guidelines. In addition to evaluating compliance with general quality management system requirements, Taiwanese auditors may also ask for information on the implementation of all relevant Taiwanese standards.
Another part of the inspection process is a check for consistency between the products which have been tested in Taiwan and those that are being manufactured on site. The auditors will confirm that a manufacturer ensures the conformity of production for its products as well as the documentation of test results and quality checks. VSCC auditors will usually ask the applicant to provide an insight into the production. Upon request, a manufacturer is required to provide access to production areas and quality management systems that are directly linked to certified parts.
Since a factory inspection is mandatory for each plant in which the final production step takes place, the VSCC attempts to combine the inspection of several facilities into one coherent inspection “tour” in order to reduce travel expenses and to shorten the overall process. To support this process, an applicant will be asked by VSCC to support the visa application process for auditors and to assist with travel logistical issues, including but not limited to providing transportation and accommodations.
The factory inspection is the most expensive part of the certification process, mostly due to travel and accommodation costs during the entire audit period. It is also recommended to have an interpreter present during the inspection in order to avoid communication difficulties with Taiwanese auditors.
Preparing for a Factory Inspection
Since the establishment of the VSCC in 2006, Taiwanese auditors have gained considerable experience, resulting in a quality certification process that is comparable to other international certifications such as ISO or CCC certification. Therefore, it is important to take the Taiwan certification seriously. A thorough pre‑audit preparation, including the update of audit-relevant documents, is highly recommended. Taiwanese auditors will expect that relevant standards be explicitly mentioned in
internal quality management manuals, for example, by incorporating the Taiwanese standards into internal procedures.
For a factory inspection, descriptions of the crucial production and testing processes as well as existing approvals and official certificates must be prepared in advance. In most cases, companies that have ISO or comparable quality management certification credentials will find the process similar and may be more prepared than others for the Taiwan audit. Such audit preparations should be carried out in accordance to the applicable regulations and the Vehicle Safety Testing Directions.
Although the certification process for the Taiwanese market is complex, an applicant that has successfully obtained Taiwan certification will have numerous competitive advantages, including the ability to provide certified products that can be directly sold on the Taiwanese market. And, once a manufacturer is registered with the VSCC, the extension of the certification to other automotive products is less complex and less costly than the initial registration.
Julian Busch is managing director of MPR China Certification GmbH – China Certification Corporation, a company that supports manufacturers’ worldwide obtaining product certifications for the Chinese market. He can be reached at email@example.com.