04/12/2019
Like the European CE system, China’s CCC (China Compulsory Certification) system is a basic market access system that manufacturers and importers usually confront when putting their products on the Chinese market. The system was first established in 2002 in support of the Chinese government’s commitment to the WTO, and 132 kinds of products within 19 categories were included into its scope. The number of products under the CCC scope kept increasing in the following years until the latest round of the CCC reform was initiated by the State Council in 2018, removing dozens of products from the CCC scope.
Initiated by the State Council
In January 2018, China State Council issued the Opinions on Improving the Quality and Certification System and Promoting the Total Quality Management, proposing to improve China’s compulsory certification system. Several specific requirements in the document are:
- carrying out compulsory certification following the WTO rules and the principles of necessity and minimization;
- focusing on products related to human health, safety, and environmental protection;
- introducing the conformity assessment method of self-declaration to CCC system;
- optimizing the certification process.
Implemented by SAMR/CNCA
SAMR/CNCA, China’s authority for accreditation and certification, is responsible for the implementation of the reform, and they divided the reform into 4 main parts:
- A smaller CCC scope.
According to CNCA, products with low risk, low quantity, and less opportunity to come in contact with consumers shall be removed from the CCC scope.
- Introduction of the conformity assessment methods of self-declaration.
The CCC certification can be conducted through one of the following 3 methods:
- Self-declaration method A: type test in any labs + self-declaration.
- Self-declaration method B: type test in designated CCC labs + self-declaration.
- Third-party certification: type test + factory audit + period inspection after obtaining certificate.
According to the design of SAMR/CNCA, the self-declaration methods will be implemented to products with stable quality and low safety risks, while the third-party certification shall be conducted for products with high safety risk and closer contact with consumers.
Figure 1: three solutions for the CCC products
- Simplification of the certification processes and procedures. The specific measures include:
- Optimize the process of factory audits and realize “one audit for multiple certificates”.
- Implement the “issuing certificate before factory audit” for those enterprises who have met certain criteria.
- Merge and simplify certification units and certificates, simplify application for component modification.
- Promote the online handling of the CCC certification process.
- Utilize enterprises’ test and inspection resources with rules approved by CNCA (details check with CNCA).
- Facilitation of fair competition related to certification. The specific measures include:
- Increase the number of designated certification bodies and labs (6 foreign investment labs have been included in the CCC system by March 2019, including SGS, UL, Intertek, TUV Rheinland, TUV SUD, STC group).
- Strengthen administrative supervision including cracking down on unauthorized and fraudulent use of certificates.
- Implement the work mechanism of “randomly select the sample and inspectors and make public the inspection results”.
What has been done?
SAMR/CNCA took a sequence of actions afterwards, to implement the above 4 parts.
- In June 2018, 26 kinds of products were removed from the CCC scope, and the conformity assessment method for 22 kinds of products was converted into self-declaration (2 for method A and 20 for method B). Currently, the Implementation Rules for CCC Compliance Self-declaration have been published. (SAMR/CNCA Announcement No. 11, 2018).
- In December 2018, 12 kinds of products were removed from the CCC scope, and the conformity assessment method for 4 kinds of product was converted to self-declaration (1 for method A and 3 for method B). (SAMR/CNCA Announcement No.29, 2018).
- In October 2019, 18 kinds of products were removed from the CCC scope, and the conformity assessment method for 17 kinds of product was converted to self-declaration (3 for method A and 14 for method B). A template of CCC compliance self-declaration was published at the same time. (SAMR/CNCA Announcement No.44, 2019).
Figure 2: a series of adjustments
Although there are many products that were removed from the CCC scope, several products were transferred from the scope of production license to the CCC system to, according to Chinese government, reduce proactive supervision and increase post-supervision. In July 2019, explosion-proof electrical apparatus, household gas appliances and refrigerators with a calibration capacity of over 500L, which used to be subject to the production license, were transferred into the CCC scope. (SAMR/CNCA Announcement No.34 2019) despite the explosion-proof electric apparatus not meeting the criteria that SAMR/CNCA defined as “easy to be contacted by customers”.
Likewise, motorcycle helmets, electric blankets, and electric bicycles were moved from the scope of production license to the CCC system as well.
Summary of the changes
As a result, 119 kinds of products within 21 categories remain in the CCC scope after 56 kinds of products were removed. Among the products remaining in the CCC scope, 27 kinds were converted from third-party certification to the CCC compliance self-declaration (7 for mode A and 20 for mode B).
Figure 3: statistics about the changes
CNCA’s statistics show there have been 8 general rules and 40 product-specific rules released for the CCC system, and 31 certification bodies and 238 labs designated to do the relevant testing, auditing and certification. These certification bodies have issued 567,000 CCC certificates to 65,000 enterprises by October 2019.
The next steps
Since the adjustment of the CCC scope is coming to an end, CNCA stressed that there will not be any big changes to the scope in a very long time. Thus, the following work focus will be:
- Maintain the stability of the CCC scope and be prudent for adding new products into it.
- Further reduce industries’ burdens by merging multiple factory audits and multiple certificates, optimizing certification units.
- Include more certification and test bodies into the system to facilitate competition.
- Strengthen administrative supervision by striking unauthorized cases, implementing credit supervision and the work mechanism of “randomly select the sample and inspectors and make public the inspection results”.
SESEC Observations
Under the background of economy slowdown, the reform was designed to relieve enterprises’ burdens and release economic growth potential. The measures taken in the reform can to some extent respond to the requirements. However, there are still many deficiencies existing even after the reform, e.g. private sectors, especially foreign investment organizations, still have limited access to participate in the system; adding products like explosion-proof electric apparatus into the CCC seems to not conform to the rules of the CCC scope; how to conduct CCC certification in some specific circumstances, like small batches of imported goods, is not clear; etc.
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Key takeaways
- 56 kinds of products were removed from the CCC scope, but 6 kinds of products were added
- Until Nov 15, 2019, 119 kinds of products within 21 categories remain in the CCC scope
- Conformity assessment method for 27 kinds of products were converted from the third-party certification to self-declaration
- The CCC certification system are still using some sectoral standards and recommended national standards
- Foreign certification bodies can do CCC now but still have limited access to CCC certification business
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