Chinese Certification Authorities to Announce Important Changes in the CCC Certification Scheme for Automotive Components

In 2002, China established the China Compulsory Certification system (CCC), which represents the country’s quality standardization system. It applies not only to imported goods but also to Chinese products which are sold and/or used in business activities within the country. The certification process and testing requirements for the CCC certification are defined by the National Standards (GB standards) and Implementation Rules. Failure to demonstrate compliance with these standards can result in goods being detained by China’s Customs officers or denied entry into the country.

The State Market Regulatory Administration (SMRA), which was established in 2018, is the supervising certification authority. The Certification and Accreditation Administration of the People’s Republic of China (CNCA), based in Beijing, is responsible for the development and implementation of new standards and regulations. The execution of those standards is managed by certification authorities, such as the China Certification Centre for Automotive Products (CCAP) and the China Quality Certification Centre (CQC).

The whole certification process consists mainly of product tests at a Chinese test laboratory and a factory audit. For those without the requisite experience, the certification process can be very complex and take several months or even up to a year for certain products.

Together with the introduction of the CCC certification system in 2002, a catalogue with products that are subject to the certification was published. It includes more than 132 product categories. Since then, there have been several changes, adjustments and additions to the CCC certification scheme, as the scope has been expanded to address a variety of aspects like human health, environmental protection and public safety. As a result, CCC certification is now mandatory for a wide range of products, including automotive parts, devices and systems.

What Is New?

In June and December 2018, the SAMR and CNCA published announcements No. 11-2018 and No. 29-2018, which include important reformations as well as adjustments of the implementation rules for the CCC certification scheme. The announcements include two annexes that were related to automotive parts. Parts that are listed in the first Annex no longer fall under the CCC certification scheme, such as brake hoses, fuel tanks, horns and retro reflectors. The reforms applied with immediate effect, so that affected components are no longer required to have a CCC mark.

Tables 1 and 2 show the products listed by CNCA according to announcement No. 11-2018 and No. 29-2018 that no longer require CCC certification, along with the corresponding Implementation Rules.

Table 1: Products no longer requiring CCC certification, per announcement no. 11-2018

Table 2: Products no longer requiring CCC certification, per announcement no. 29-2018

It is important to note that automotive parts still must be in compliance with the applicable Chinese GB standards, and that testing of parts listed in the first Annex may still be required as part of a voluntary certification scheme or as part of vehicle certification testing. Further, products can still be certified voluntarily in accordance with the corresponding GB standards.

Since October 2018, parts that were listed in the second Annex can either undergo the standard CCC certification testing process, or demonstrate conformity with the applicable standards by obtaining a supplier declaration of conformity (SDoC). Under the new SDoC process, testing in China is still required for most products, but an audit is no longer needed. However, the manufacturer will be held directly liable in case of any problems or deficiencies.

Tables 3 and Table 4 list the products which can now take advantage of the self-declaration route according to announcement No. 11-2018.

Table 3: Products eligible for self-declaration, per announcement no. 11-2018

Table 4: Products eligible for self-declaration, per announcement no. 29-2018

Note that manufacturers of products categorized as Type A in Table 3 may choose the China-based testing laboratory to conduct the required testing. However, manufacturers of products categorized as Type B must use a testing facility that has been accredited by Chinese authorities.

How Can Voluntary Certification Be Obtained?

Although CCC certification for certain products such as brake hoses, fuel tanks, and horns is no longer mandatory, product requirements laid down in the applicable Chinese national standards continue to apply. To fulfill these requirements, manufacturers can undertake a voluntary CCAP certification or CQC certification of their products.

The CCAP is responsible for the approval of the CCAP Mark certification and focuses its efforts exclusively on the automotive sector and the CCC certification of products in this field. The Implementation Rules present the corresponding guidelines and have been adjusted accordingly. CCAP now marks these products with an addition of an “A” after the year (for example, motor vehicle horns: CCAP-SB-3721:2018A; brake hoses: CCAP-SB-3561:2018A; fuel tanks: CCAP-SB-1101:2018A). The essential adjustments of the three Implementation Rules consist of a modification of CCAP internal specifications for the process of certification, the part marking, and the control procedures for the documentation of marked products. Therefore, it is important to have the latest version available in time for the next factory audit.

The voluntary CCAP and CQC Mark certifications have gained significant importance and have become the preferred approach of car manufacturers for their suppliers. By obtaining a voluntary CCAP or CQC Mark certification a manufacturer can provide assurances regarding the compliance of their products with Chinese standards covering quality, safety, environment and performance regulations. Moreover, the voluntary CCAP/ CQC Mark certifications serve as acceptable evidence for both Chinese Customs officials and customers that Chinese quality requirements are being met, thereby increasing the competitiveness of products in the Chinese market. And, for a limited period of time, manufacturers who have already obtained CCC certificates for their products may convert these into voluntary CCAP Mark certificates.

Conclusion

Chinese regulations for automotive products are subject to regular changes. The exclusion of products from the official CCC product catalogue is an exception. In fact, the product catalog is regularly expanded. Products that did not previously require CCC certification could be required to have CCC certification at some point in the future without advance notice. A resumption of previously-dropped products is possible as well.

However, if a voluntary CCAP or CQC Mark approval has been obtained for a product and CCC certification once again becomes mandatory, the CCAP or CQC certificate can be converted into a regular CCC certificate without much effort. And the shortened recertification process will give the manufacturer an advantage over competitors, who may struggle with a new CCC certification process for their products.

This is why the most reliable way to demonstrate conformity of production is through a voluntary certification. Further, the CQC and the CCAP can convert existing CCC certificates into voluntary CQC or CCAP certificates. Finally, the basic process of voluntary certifications and the corresponding follow-ups are almost identical to the CCC certification, only the logo for the marking is different.

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.