Source: Office of Chinese Economic Area, Market Access & Compliance International Trade Administration, U.S. Department of Commerce
The CCC safety license requirement by the government of China requires manufacturers to obtain the China Compulsory Certification (CCC) mark before exporting to or selling products covered in the CCC catalogue in the China market. The system, implemented on May 1, 2002 and made fully effective on May 1, 2003, impacts many U.S. exporters, across a wide range of manufacturing sectors. Products not meeting CCC requirements may be held at the border by Chinese Customs and will be subject to other penalties.
ALERT: New product categories have been added to the CCC catalogue. Review the Product Scope, and confirm current list with CNCA.
CCC Mark Product Scope - a detailed line-by-line list of which products are included on the CCC catalogue.
The application process for the CCC mark:
1. can take sixty to ninety days or longer;
2. requires testing at accredited laboratories in China;
3. generally does not permit self certification or third-party testing results;
4. requires submission of numerous technical documents;
5. requires submission of a product sample to a Chinese testing laboratory;
6. requires a factory inspection by Chinese officials at the applicant's expense;
7. requires follow-up inspections every twelve to eighteen months; and
8. can cost several thousand dollars.
The CCC Mark is administered by the Chinese government agency Certification and Accreditation Administration (CNCA). The China Quality Certification Center (CQC) is designated by CNCA to process CCC mark applications.
Step One: Determine Whether Your Products Require CCC Marking
First, examine CNCA's product catalogue and determine whether your products, or component parts within your finished goods, require CCC marking. The product catalogue is a list, originally divided into 132 broad product categories, of all the products requiring CCC marking.
Step Two: Get the Implementing Regulations
CNCA has published 47 "Implementation Rules for Compulsory Certification." The booklets are available on the Web, in English, at http://www.cnca.gov.cn/20040420/column/227.htm . The booklets outline detailed technical application requirements for each of the product categories.
CNCA's Implementation Rules cite numerous "GB Standards," which are mandatory standards. Information on mandatory standards can be requested from China through the U.S. WTO/TBT National Enquiry Point.
U.S. WTO/TBT National Enquiry Point National Institute of Standards and Technology
100 Bureau Drive, MS-2160 Gaithersburg, MD 20899-2160
Step Three: Consider Your Options for Applying
Some companies use agents or consultants to manage their CCC mark applications. Other companies apply on their own, or rely on their importers or distributors.
Check with your Chinese partners, distributors, or your export managers. They may have experience with the CCC mark and can point you to other resources.
If you elect to use a consultant, several U.S. firms can help you apply and manage your applications for CCC certification. Several firms have indicated to the Commerce Department that they provide such services. The Department of Commerce cannot endorse any individual company. Please note that this is not a comprehensive list.
Step Four: Apply
There are five major steps in the CCC mark application process. If your company elects to handle the application process, your first step should be to visit the website of the China Quality Certification Center (CQC), which administers the CCC mark application process.
At the website, click on the "Application Process", a document giving step-by-step instructions on how to apply for the CCC mark. The five-step application process includes:
1. Submission of an application and supporting materials, including user guides, CB reports, EMC reports, regulatory labels and other information.
2. Type Testing. A CNCA-designated test laboratory in China will test product samples.
3. Factory Inspection. CQC will send representatives to inspect the manufacturing facilities for your product. They will inspect each factory producing your product (e.g. If your company manufactures Product Z in five separate factories, all of which ship product to China, you will need to have five separate factory inspections). Please note: Chinese inspectors will need U.S. visas to visit U.S.-based facilities. The U.S. State Department is now subjecting visa applications to a greater degree of scrutiny than in the past, and visa applicants are being advised to expect delays. These visa delays may slow your CCC mark application.
4. Evaluation of certification results, and approval (or failure or retesting).
5. Follow-up Factory Inspection. Manufacturing facilities for the product will be re-inspected by Chinese officials every 12-18 months.
Step Five: Note Other Chinese Licensing Requirements
Like many countries, China has multiple certification schemes. Though the CCC mark is the widest-ranging certification requirement, your product may have to meet other requirements as well. For example, China's Ministry of Information Industry regulates telecom and internet equipment, and for certain equipment requires manufacturers to obtain a "Network Access License" and "Network Access Identifier Mark," which includes requirements for testing in Chinese test laboratories. Similarly, China's State Drug Administration requires product registration for certain medical devices.
MORE ON THE CHINA COMPULSORY CERTIFICATION MARK
Chinese requirements for safety and quality certification are not new. Since 1989, China has had a safety licensing system, which included the CCIB Safety Mark, required for products in 47 product categories, and the CCEE "Great Wall" Mark, for electrical commodities in seven product categories. As the certification system grew through the 1990s, many companies exporting to China raised concerns about the dual certification systems, redundant testing, and differential treatment of domestic products and imported products.
When China negotiated the terms of its World Trade Organization (WTO) membership in the late 1990s and through 2001, it acknowledged some of the problems inherent in its existing system, and agreed to merge its two-certification regimes into a single unified system, with equal treatment for domestic products and imports.
In December 2001, at about the same time it joined the WTO, China announced the new China Compulsory Mark system and the list of covered products. The system was put in place on May 1, 2002, with a one-year transition period, with the system fully effective -- and mandatory for all goods in the product catalogue -- on May 1, 2003.
International Trade Specialist
Office of China Economic Area