The Chinese Certification Authority CNCA has released a new statement announcing important changes on CCC Certification regulations. The changes have an impact on many automotive suppliers and car manufacturers.
The China Compulsory Certification (CCC) scheme is similar to other certifications for product quality and safety, such as the European CE system. First introduced in 2002, the CCC scheme applies to imported goods as well as to Chinese products. Products that require certification may only be imported, sold and/or used in business activities in China after a China Compulsory Certificate has been obtained.
In their latest announcement No. 44, 2019, dated October 17, 2019, the Certification and Accreditation Administration of the People’s Republic of China (CNCA) made significant changes to the CCC certification regulations.
With immediate effect, certain products like automotive interior trim parts no longer form part of the CCC certification scheme (Annex 1). For some other product categories, a new certification mode has been put into place, the CCC Self-Declaration (See Annex 2).
Both changes raise many questions and require actions to be taken by manufacturers of the products affected by the announcement. This article provides detailed information regarding the impact of the changes and what manufacturers have to know.
CCAP/CQC Mark Certification
Products listed in Annex 1 (Table 1) of the announcement such as automotive interior parts no longer fall under CCC jurisdiction and can obtain a voluntary CCAP mark or CQC mark certification to show compliance.
| Number | Name of product | |
| Product category | Sub product category and code | |
| 1 | Wire and Cables | Wire and cable for railway vehicles with A.C. rated voltage of 3kv and below (0103) |
| 2 | Electrical tools | Electric screwdriver and impact wrench (0502) |
| 3 | Sanding machine (0504) | |
| 4 | Circular sa (0505) | |
| 5 | Electric welder | Small AC arc welder (0601) |
| 6 | AC arc welder (0602) | |
| 7 | Submerged arc welding machine (0606) | |
| 8 | Plasma arc welder (0608) | |
| 9 | Arc welding transformer anti-shock device (0609) | |
| 10 | Welding cable coupling device (0610) | |
| 11 | Resistance welder (0611) | |
| 12 | Audio and video equipment | Tuning receiver, radio for various broadcast bands (0804) |
| 13 | Monitor (0809) | |
| 14 | Motor vehicle and safety accessories | Automotive interior parts (1111) |
| 15 | Car door lock and door retainer (1112) | |
| 16 | Safety glass | Railway vehicle safety glass (1303) |
| 17 | Telecommunications terminal equipment | Fixed telephone terminal and telephone add-on devices (1603) |
| 18 | Group phone (1605) | |
Table 1: Annex 1 of the CNCA announcement
The procedure of the CCAP/CQC mark certification is very similar to the current CCC processes. It still requires an annual follow-up factory inspection to maintain the validity of the certificates and to demonstrate ongoing compliance with the respective standards. Along with this, annual product testing is required. And, instead of the CCC logo, the CCAP/CQC mark is used for marking.
According to the latest information, there may be a transition period for existing certificate holders so that marking changes can be made with the next regular tool change.
Until now, manufacturers can change their CCC Certificates to CCAP or CQC certificates without much effort and at no charge. A deadline has not been communicated yet. If a certificate will not be transformed, it is no longer valid.
By converting existing CCC certificates to CCAP/CQC certificates, manufacturers can continue demonstrating compliance with China standards and regulations that are still in place. However, it is advisable that manufacturers consult with their customers, e.g., car manufacturers, since they might require CCAP/CQC certification for their products. Since it is easier to convert certificates than to start a completely new certification process, this should be done in a timely manner to avoid any issues with China’s Customs officials.
The CCC Self-Declaration
Annex 2 (Table 2) shows the products that still require a CCC certification, but that must now undergo a new certification mode called the CCC Self-Declaration or Declaration of Conformity.
| Number | Name of product | Procedure A/B | |
| Product category | Sub product category and code | ||
| 1 | Electrical tools | Electric drill (0501) | Self-declaration procedure A (Type test in optional laboratory + self-declaration) |
| 2 | Electric grinder (0503) | ||
| 3 | Electric hammer (0506) | ||
| 4 | Electric welder | DC arc welder (0603) | |
| 5 | TIG arc welder (0604) | ||
| 6 | MIG/MAG arc welder (0605) | ||
| 7 | Plasma arc cutting machine (0607) | ||
| 8 | Circuit switch and electrical device for protection or connection | Thermal fuses (0205) | Self-declaration procedure B (Type test in designated laboratory + self-declaration) |
| 9 | Cartridge fuse-links of miniature fuses (0207) | ||
| 10 | Low-voltage apparatus | Leakage protector (0306) | |
| 11 | Circuit breaker (0307) | ||
| 12 | Fuse (0308) | ||
| 13 | Low-voltage switchgear (disconnectors, switch-disconnectors and fuse-combination units) (0302) | ||
| 14 | Other circuit protection devices (0304, 0307, 0309) | ||
| 15 | Relay (0303) | ||
| 16 | Other switches (0305) | ||
| 17 | Other device (0304, 0305) | ||
| 18 | low-voltage switchgear assemblies (0301) | ||
| 19 | Small power motor | Small power motor (0401) | |
| 20 | Equipment for Household and similar uses | Motor-compressor (0704) | |
| 21 | Motor vehicle and safety accessories | Car seat belt (1104) | |
| 22 | Motor vehicle exterior lighting and light signal devices (1109, 1116) | ||
| 23 | Car seat and seat headrest (1114) | ||
| 24 | Motor vehicle indirect vision device (1110, 1115) | ||
| 25 | Car drive recorder (1117) | ||
| 26 | Car reflecting marking (1118) | ||
| 27 | Safety glass | Car safety glass (1301) | |
| Information technology equipment, Audio and video equipment | Equipment with rated voltage less than or equal to 5VDC, rated power consumption less than 15W (or 15VA) and no rechargeable battery (class III equipment) | Self-declaration procedure A (Type test in optional laboratory + self-declaration) |
|
Table 2: Annex 2 of the CNCA announcement
Starting 1st January 2020, the above-mentioned product categories have to show conformity with China’s standards and regulations through the mode of CCC Self-Declaration. Manufacturers have until 31st October 2020 to convert their current CCC certificates into CCC Self-Declaration certificates. After that date, prior CCC certificates will be cancelled.
Depending on the product category, two different procedures apply. Whilst the process of procedure A offers the possibility to freely choose the test lab, procedure B demands type tests in a designated testing facility in China. In either case, testing must be carried out in accordance with the relevant implementation rules and GB Standards. Also, test reports as well as the technical documentation must be uploaded to China’s online system. The CNCA is responsible for the supervision of the CCC Self-Declaration and its proper realization.
China’s CCC Self-Declaration is based on the implementation rule CNCA-00C-008:2019. The specific Implementation Rules for individual products still apply. However, regardless of the applicable procedure, the online registration requires that the applicant be based in China, a major change from the previous certification process. The applicant in China bears ultimate responsibility and liability for the CCC Self-Declaration and the certified products.
Due to the potential significant risk that changes to a product or production line are not reported to the Chinese authority, it makes sense to obtain a voluntary CQC or CCAP certification in addition to the CCC Self-Declaration. This approach, which includes annual factory audits, provides full assurances that the product is in compliance to China’s regulations at all times.
Current certification efforts in process must be completed before the end of 2019. After that date, certifications must follow the CCC Self-Declaration mode. The new issued CCC Self-Declaration certificates will be valid for ten years if no changes to a product are made.
Conclusion
With the latest announcement, China’s certification authorities have once more demonstrated their habit of announcing important information with immediate and far-reaching consequences. But, for now at least, there are still many questions to be investigated and decisions to be taken.
In order to bridge this period, it makes sense to convert existing CCC certificates to voluntary ones and to obtain the CCC Self-Declaration certificates for affected products as soon as possible. Since this transition is currently being offered free of charge by
China’s authorities, it will allow some time to make a decision on the future approach.
In summary, the latest changes mean a shift of responsibility towards the manufacturers and applicants as only they can be found liable in case of any quality problems or non-conformities. With a voluntary CQC or CCAP mark certification, this risk can be reduced significantly.
It remains to be seen if the Chinese certification bodies will maintain this course, exempt further products from the compulsory certification scheme, or expand the CCC self-declaration mode for other product groups. For that reason, it is critical for manufacturers to maintain compliance with China’s standards, and to stay fully informed regarding any changes to China’s regulations.
