New CCC Marking Regulations in China

China is the second biggest economy in the world. The strong economic growth of the last decades has lead the country to develop its own quality standardization system. In 2002, the China Compulsory Certification (CCC) was established, a system which is comparable but not identical in terms of standards and requirements to the European Union’s (EU’s) CE mark or the Federal Communications Commission’s (FCC’s) declaration of conformity in the U.S.

Who Is In Charge Of CCC Certification In China?

The most important regulations for CCC certification are the Certification and Accreditation Administration of China (CNCA) implementation rules and the so-called GB standards (“GB” stands for Guo Biao and means national standard). These standards are product-specific and define the certification scope and the test requirements.

Due to comprehensive government restructuring
plans announced in March 2018, there have been many changes regarding the authorities responsible for the CCC certification. The newly established State Market Regulatory Administration (SMRA) is now the highest-ranking certification authority. It combines, amongst others, the former national certification authority and one of the institutions responsible for the creation of the GB standards. It supervises the CNCA, which develops the implementation rules for CCC certification. The execution of these regulations is managed by certification authorities, such as the China Quality Certification Centre (CQC) or the China
Certification Centre for Automotive Products (CCAP).

What Is The CCC Certification?

CCC certification focuses on a variety of aspects like human health, environmental protection and public safety. In consequence, the CCC certification is mandatory for a wide range of products, such as automotive interior trimming parts, wall tiles, safety glass and toys. Without a valid CCC mark, products that are subject to CCC certification may neither be produced, imported into nor sold in China.

The basic process of the CCC certification is similar for all kinds of products. Without any experience in the certification of certain products, however, the process may turn out to be quite complex and take more than a year to finish.

As a first step, application documents must be submitted to one of the Chinese certification authorities. The application documents require that comprehensive information about the manufacturing plant, the production process and the product which is to be certified be provided. The application documents should be prepared with absolute accuracy, as any mistake in them can lead to problems later in the process and may be difficult and costly to resolve afterwards.

After the application has been accepted, test samples need to be prepared in accordance to the relevant
GB standards. Applicants should be aware that in many cases only test laboratories in China hold the required accreditation for conducting tests for the CCC certification.

The third step is a factory audit of the manufacturing plant. Chinese auditors will come and visit the plant, analyzing its capability to meet the Chinese regulations and verifying the accuracy and completeness of all information in the application documents.

Once the product testing and the factory audit have been successfully completed, the Chinese certification authority issues the CCC certificate. The final and last step of the process is the CCC marking. While the former three steps remain unaffected by the most recent reforms of the regulations, the latter has undergone a series of changes.

The CCC Marking

Only CCC certified products may be marked with the CCC logo. There are different options for the CCC marking, e.g., by label or by tool (molding, pressing or laser carving the CCC logo into the product). According to the implementation rules for CCC marking from the CNCA, the mark must contain the CCC logo and the factory code.

Practice has shown, however, that there should be different recommendations for different kinds of marking to prevent problems during customs clearance. While it may be sufficient for markings via tool to include only the CCC logo and factory code, labels should always include the factory and part name as stated on the CCC certificate to avoid problems when importing the products into China. The inclusion of the part name for tool marking is also highly recommended as it allows for the easier matching of CCC certificates and parts, hence reducing potential risks for the import of the products to China and for audits in the manufacturing plant.

The size of the CCC logo can be freely chosen, starting from 6mm. But one important aspect to keep in mind when changing the size of the CCC logo is its ratio (width to height), which should be exactly 1.27:1 and must not be distorted. For certain product categories there are also alternative CCC logos which may be used for the marking. This option is available, amongst others, for cables and wire products as well

as for brake hose products for motor vehicles. Another option is the purchase of “CCC-stickers” from the Chinese authorities. Manufacturers who would like to use this option should be aware that the stickers may only be applied to products with a valid CCC certification. Any infringement can have severe consequences including fines or voiding the validity of a CCC certificate.

Changes In The CCC Marking As Of March 2018

Until recently, the CNCA was in charge of CCC marking. After a CCC certificate had been issued, applicants needed to apply to the CNCA for a Permission of Printing (PoP). The document would contain the name of the manufacturer as shown on the CCC certificate, the numbers of all covered CCC certificates, detailed information about the CCC marking, such as method of marking, the width and color of the CCC logo, as well as a picture of the CCC mark for a certain product.

With the “CNCA Announcement No. 10, 2018,” this has now changed. In an unexpected move, the CNCA has shut down the department which had previously handled all matters related to the CCC marking. The responsibility for the marking process has now been transferred to the Chinese certification authorities (CCAP, CQC and CTC, etc.) and the requirement for the PoP has now been officially abolished. Manufacturers may now start marking their products with the CCC logo directly after receiving the CCC certificate.

It is important to consider that, according to the CNCA’s announcement, only the approval of the marking permission has been omitted and not the marking requirements in total. Allowing manufacturers to directly mark their products can be regarded as a measure to streamline the certification process. However, having said this, conformity between CCC marks and the current regulations is now more important than ever. Since the marking is no longer checked and approved, it is important that a manufacturer completely understand the marking requirements to avoid customs problems. Products with inconsistent or defective CCC marking might be seized by the Chinese Customs upon entry into China. Although it may be possible to eventually obtain the release of previously detained products from Customs, severe punishments or even destruction of products with wrong CCC marking are being reported with increasing frequency.

While the general marking regulations are still defined in the relevant CNCA implementation rules, there are now different approaches for the CCC marking depending on the responsible Chinese authority.

CQC, as one of the main certification bodies, has issued statements with detailed information for CCC marking requirements for different product categories. In these statements, the design, possible size and position of the CCC logo is stipulated.
CCAP has issued a new marking application document which will still need to be submitted in the course of an initial certification, or if there is a change of marking from the existing permissions of printing (change from tool to label or vice versa, or different size of the CCC logo, etc.). The purpose of the application is to enable CCAP to check that the marking follows the required guidelines as stated by the corresponding implementation rules, and to allow both the manufacturer and the authority to have clear documentation of the marking.

In both cases, however, there will no longer be any kind of official marking approval; hence, the full responsibility for the correctness of the CCC marking is now borne entirely by the manufacturer.

There is also an important change regarding the CCC logo. The supplementary-letters “S” (safety), “EMC” (electromagnetic compatibility), “S & E” (safety and EMC), “F” (firefighting) and “I” (information security) have been removed from the CCC logo. All previous CCC logos are replaced with the new logo without any additional letters. While the new logo must be used for all new certification projects, there is no clear deadline by which the logo must be updated for products with a PoP. According to the CNCA announcement, the CCC logo of such products shall be replaced by the CCC logo without any letter in the course of future tool or product modifications.

Last but not least, there will be a stronger focus on the CCC marking during future annual factory inspections. Manufacturers will need to strengthen their internal supervision processes in accordance with the specific regulations of the responsible certification authority. All uses of the CCC mark shall be recorded and archived to ensure transparency.

Conclusion

The CCC marking is the final and most important step of the CCC certification process. Even though the PoP has been abolished, only markings that fully comply with the current regulations will be permitted on products slated for import to China. In the medium term, the new CCC logo without the complementary-letter should be implemented for all products, including those for which a PoP exists. We recommend proper documentation and careful supervision of the product marking process to avoid difficulties during the annual CCC factory inspection.

Julian Busch is managing director of MPR China Certification GmbH – China Certification Corporation (www.china-certification.com/en), a company that supports manufacturers’ worldwide obtaining product certifications for the Chinese market. He can be reach at busch@china-certification.com.

About The Author

Julian Busch

Julian Busch is managing director of MPR China Certification GmbH – China Certification Corporation (http://www.certification-india.com/en), a company that supports manufacturers worldwide obtaining product certifications for India, China, Korea and other markets.

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