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The Chinese government is implementing a series of reforms in various industries, including the process of certifying product for sale there. The purpose of these reforms is to open the certification and testing market, accelerate the certification process, and reduce the burden on manufacturers and importers seeking access to China’s vast and lucrative marketplace. The Certification and Accreditation Administration of the People’s Republic of China (CNCA) has announced several changes in its certification requirements for different product categories, and those changes are now in effect.
The China Compulsory Certification (CCC) scheme requires manufacturers to obtain approval for their products before they can be legally marketed in China. CCC testing and certification can only be performed by certification bodies that have been approved by the CNCA. CNCA regulations serve as a general guide for certification bodies in China, and CNCA-approved certification bodies like CQC, ISCCC, CESI, CCAP, CCCF and CVC had previously issued their own detailed regulations which may differ from one another in some respects.
There are 21 product types in the current CCC category and each product category has its own set of requirements. The new regulations published in 2014 cover most product categories, and generally include the following changes:
Certification mode varies depending on the classification levels assigned to the manufacturer’s factory
Type test can be conducted in manufacturer’s own lab
Initial factory inspection can be arranged after obtaining CCC certification
There are fewer requirements for critical components
Factories are now classified into different levels according to the following factors:
Initial factory inspection and follow up inspection result
Reputation or product quality accident
CQC (a CNCA-approved certification body) has listed the factory level classification factors as follow:
No serious failure found in initial factory inspection or in follow-up inspections within the past two years
No test failure during or after certification test
No non-conformances identified in the national or state market survey within the past two years
No product quality accident within the past two years
Class B:  Factories other than Class A, C and D
Initial factory inspection and follow-up inspection failure caused by product quality, which has been corrected and verified through on-site inspection
Product quality disqualification, but not a cause for certificate suspension or withdrawal
Other negative factors, including product information or input from the manufacturer
Failure of initial factory inspection and follow-up inspection
Failure of post-certification product testing
Refusal to conduct inspection or post-certification testing
Serious quality issues that may result in certificate suspension or withdrawal
Non-conformance in the state or national market survey
Suspension or withdrawal of product certification for other reasons
Other negative factors, including product information or input from the manufacturer
Some certification bodies have a different number of factory classifications (for example, three class levels instead of four). Generally, however, a new factory will be initially categorized at a middle level, and moved to a higher or lower level based on the factors mentioned above. A manufacturer’s factory classification level may affect a number of other certification factors, including certification mode, factory inspection frequency and product series classification
Certification mode involves the sequence of the CCC certification process, including the required factory inspection. Under the new regulations, most product categories now permit the awarding of a CCC certificate without waiting for the initial factor inspection to be conducted. For many manufacturers, this means receiving certification once the results of type testing have been approved.
As an example, Class I and Class II information technology, audio, video and telecom equipment (per GB 4943/IEC 60950) can now be certified upon the conclusion of type testing, with factory inspections to be conducted following certification. For equipment and devices other than Class I and Class II, certification can also be issued following successful type testing, with factory follow-up inspections to follow.
Generally, the first factory inspection must be completed within three months after the issuance of the CCC certificate. This means that any corrective actions identified during type testing must be addressed within that time as well.
Post-certification audits can consist of follow-up inspection, on-site sampling and tests or market sampling and tests. Certification bodies will determine the extent of post-certification audit activities based on the assigned factory levels. In addition, follow-up inspection frequency depends on the assigned factory Class level, with better factories likely to require fewer follow-up inspections.
For some product categories like automotive parts, fire protection devices, and security protection devices, an initial factory inspection must still be completed in advance of product certification.
Type Tests Can Be Conducted in Manufacturer’s Own Lab
Manufacturers can choose to have required type testing performed at their own testing laboratories or at the factory’s testing laboratories. Such testing laboratories must be accredited to the requirements of ISO/IEC 17025, “General requirements for the competence of testing and calibration laboratories,” and owned by the manufacturer or the factory. There are two options to conduct the test:
Testing on Manufacturer’s Premises (TMP): Testing is conducted by the test engineer from the authorized CCC test lab.
Witness Manufacturer’s Testing (WMT): Testing is conducted by the manufacturer and witnessed by the authorized CCC test lab engineer.
Note that, in utilizing these options, manufacturer will still be responsible for the cost of travel expenses and witness fees for the representative from the authorized CCC testing laboratory. Further, TMP or WMT accreditation require periodic auditing by the certification body. Finally, the capacity of the laboratory may be too limited to conduct all aspects of the required testing. In these cases, remaining tests will still need to be conducted by the CNCA-approved testing laboratory.
Other CCC regulatory changes cover the following issues:
Critical Component Requirements—Some EMC-related components were removed from the original list of critical components requiring testing. In addition, voluntary certification marks may be accepted for some critical components, which means that, if the component is outside of CCC category, the manufacturer can provide evidence of a voluntary certification mark to avoid component level test.
Self-Made Components—Self-made components that come under a CCC category may be tested as part of the end product, rather than requiring a separate CCC certificate first. For example, if the end product is a server, and the manufacturer also produces the server power supply that will only be used in the server, the power supply does not require separate certification.
Product Series Classification—The new regulations clarifies the product series identification for group application. For example, displays should be grouped by screen size, power supplies should be grouped by power ratings, etc. Factories with higher level classification may have more flexibility for group application.
Other Issues—There are also some minor changes in the new regulation. Specifically, OEM/ODM agreements need to signed by the applicant, the manufacturer and the factory. Also, “factory quality control capability self-declaration” needs to be submitted in advance of the actual factory inspection.
Preparing for the Changes
If your factory maintains an ISO 9001-certtified quality control system and the product consistency is stable, you can take the advantage of the new regulation and apply for the new certification mode, that is, conduct the factory inspection after CCC certification. This is a good change especially for new factories located outside of China, since it may save a minimum of two to three months compared with the original process. On the other hand, your factory must be well prepared for the inspection, since an inspection failure may delay the release of the CCC certificate. Of course, if you have doubts about the ability of your factory to pass inspection, you can also choose to pursue the original certification route, and have the initial factory inspection conducted first.
Regulations applicable to existing factories will be updated as new or existing products are recertified. The main challenge here is to maintain complete and accurate records of factory inspection results, and to work toward elevating your factory classification level according to the factory classification requirements. The benefit of obtaining Class A factory classification means fewer factory inspections, reduced inspection scope and more flexibility regarding group applications.
For factories with test labs…
You can expand your test lab capabilities to conduct WMT or TMP testing. This is good for companies that manufacturer large equipment that is difficult to ship or complicated to configure. But the test lab capability must cover all related GB standards to avoid the need to ship samples to a separate testing laboratory for additional testing. Testing fees may also be less compared with the cost of testing products in China-based testing laboratories, but you will still incur witness fees and travel expenses related to WMT or TMP testing. If you have multiple models to be certified, you can apply for this test mode and conduct witness test at one time. If the test sample is easy to ship, testing in China-based testing laboratories may still be a good choice.
If you have an alternate component to be replaced or added, and if that component has been removed from the new regulation, you can simply apply to update to the new regulation and the component will be removed. If your component has a valid voluntary certificate, you can also apply for a new regulation update and avoid verification testing.
Paul Wang is the technical director for G&M Compliance, focusing primarily on China certifications including CCC, SRRC, NAL, CFDA and China RoHS. He can be reached at paulwang@gmcompliance.com.
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Paul Wang works for G&M Compliance Inc. in the China office as Technical Director, mainly focusing on China certifications. He is also on the Board of Directors of IEEE Product Safety Engineering Society.
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