Conformity Magazine

See this article in our Digital Edition
Download a pdf of this article (right click to save the pdf)

China has long been described as a sleeping giant and, in this day of the global economy, China has opened its doors for the import of goods for use in residential and commercial applications. To sell these goods in China, there is a compliance path that must be followed. [1]

The Chinese government started the China Compulsory Certification (CCC) system at the end of 2001. This system is the statutory, compulsory, safety certification system for electrical and electronic products and EMC compliance. The basic approach is to safeguard the consumers’ rights and interests and to protect personnel and property.

The CCC system came into force May 1, 2002 by the State General Administration for Quality Supervision, Inspection and Quarantine of the People’s Republic of China (AQSIQ) and the Certification and Accreditation Administration of the People’s Republic of China (CNCA). In essence, this new program combined two former certification programs, the CCIB Mark that covered 47 product categories, and the CCEE Mark, which covered 7 electrical categories.

In the implementation of the CCC system, CNCA is responsible for authorizing the CCC certification bodies and test laboratories. It is also responsible for issuing the CCC Mark’s related rules and the product lists requiring CCC certification. CNCA has authorized 9 CCC certification bodies, such as China Quality Certification Center (CQC), China Certification Center for Electromagnetic Compatibility (CEMC), and more than 100 test labs throughout China for CCC tests. Each CCC certification body is only authorized for some product categories and is responsible for only those products.

Today, the CCC Mark program covers 163 products divided into 22 categories, including household appliances, motor vehicles, medical devices, information technology equipment, and others.

Taking the First Step
When U.S. companies are considering marketing their products in China, the first thing to determine is if the product is listed as having CCC requirements. Many categories that CNCA published are explained with specific products identified. Product categories that require CCC certification are listed in Table 1; however, a more detailed list can be found at this link.

Categories	Name of the product category	No. of products
1	Electric Wires and Cables	5
2	Connecters such as Plugs and Sockets for Household and Industry Appliance	6
3	Low-voltage Circuit Switches and Protective Devices	9
4	Small-Power Motor	1
5	Electric Tools	16
6	Electric welding machines	15
7	Household Appliances	18
8	Audio & Video products	16
9	Information Technology Equipments	12
10	Lighting Electrical Appliances	2
11	Motor Vehicle Products	4
12	Tire Products	2
13	Safety Windows for Car and Buildings	4
14	Rubber Products	1
15	Equipments for Crop Protection Purpose	3
16	Telecommunication Terminal Equipments	9
17	Medical Equipment	12
18	Fire fighting Products	3
19	Intruder Alarm Systems for Security Purpose	1
20	Wireless Local Area Networks	40
21	Decoration materials for Construction Industry e.g. Wallpaper	2
22	Chemistries Product for Carpentry	1

Table 1: The summarized product list covered by CCC certification [2]

In some instances, products that are not specifically identified leave options for companies planning to market goods in China. One option is to use the CNCA Announcement 60, which lists HS codes or product tariff codes. This is a very detailed list with detailed descriptions. For those companies that may not have experience with HS codes, the U.S. Census Bureau can provide assistance in this area.

In many cases, component parts that go into products and devices must also carry the CCC Mark. Additionally, some spare parts and replacement parts may also fall under the CCC guidelines. Companies do have the ability to apply for an exemption in these cases, provided the correct procedures are followed and proper approvals are issued.

Once a company has determined what categories the products fall under, they then determine which mandatory standards are needed for certification. The GB series and industrial standards, which are similar to the IEC standards, are used for CCC certification.

The Application Process
Companies need to formally apply for the approval to market products in China. There are a number of options for this application. Some companies have an established distribution network in China, and the distributor can handle the application process. Other companies apply themselves, which can be a daunting process. You may wish to opt for assistance from an experienced agent. In many cases these agents are located in the U.S. and have knowledge, expertise, and experience in the application process. They can coordinate all aspects of the compliance process. [3]

The application process requires the submission of a formal application and additional supporting documentation. The supporting documentation includes a user’s guide or operating manual, a critical component list both for safety and EMC, a marking label, and other specific information related to the operation, handling, storage, and intended use of the product to be certified.

Upon approval of the application, the product will be required to be formally tested at a CNCA-designated testing laboratory in China. Chinese labs do not offer mitigation and problem-solving as a rule, and product failures often delay the approval process by several months. Therefore, it is recommended that a product be fully tested and approved under a CB and EMC certification process before being sent to China for type approval. Figures 1 and 2 show primary safety and EMC tests being performed before the product is sent to China.

Figure 1: Temperature testing

Figure 2: EMC problem solving

Marking and Factory Inspection
Once the product is tested, the results are reviewed and evaluated by CQC, CEMC or another certification body. If compliant, the CCC certificate will be issued, after which the manufacturer must apply to use the CCC Mark on their product.

There are two different CCC Marks. The first (see Figure 3), indicates that the product meets both EMC and safety requirements. The second (see Figure 4) means that the product complies only with the applicable safety requirements. The CCC Mark must be created by the manufacture; there is no size requirement for the Mark, as long as it is clear and visible. This differs from the CE Mark, which has size requirement.

Figure 3

Figure 4

If a factory has not been previously inspected for a particular CCC Mark product category, the certification body will send an inspector to factory locations where the products are produced to perform an ISO-style initial factory inspection. The cost for this inspection is the responsibility of the company placing the products on the market. This can be a lengthy process, since obtaining a visa by the Chinese inspector can take time. In the event a new factory location is added, or a contract manufacturer is to be used, these facilities must also be audited under the same conditions, and approved before products produced at these locations can be legally marketed with the CCC Mark.

During the initial factory inspection, the Chinese inspector will review all aspects of the quality and manufacturing process, and perform certain tests to ensure the product is manufactured and assembled using same components that were originally supplied for type testing approval. For example, for ITE equipment, the inspector will ask the manufacturer to perform the ground resistance and electric strength tests during the inspection.

Follow-up factory inspections are required as long as the products continue to be manufactured. This follow-up inspection is required at all locations every 12-18 months, and it is a cost that the marketing company must bear. Any changes to the manufacturing location, process, or componets identified during these factory inspections can lead to the product being removed from the approved product listing and subject to fines.

Impact of Other Requirements
Since March 1, 2007, China has required compliance with the requirements of China RoHS legislation for all information technology equipment, which directly affects the entire IT industry. The Chinese RoHS requirements are the same as the EU RoHS requirements, except that the Chinese RoHS legislation only affects information technology equipment.

At this time, RoHS compliance for China requires only self-declaration of conformity (DoC). However, in the near future, it is expected that RoHS evaluation and compliance will become a formal part of the CCC regulation, and all related products will require an evaluation at a CNCA-authorized Chinese RoHS test lab.

In addition to the CCC Mark, some categories require additional certifications. As an example, certain medical devices require approval from the China State of Food and Drug Administration, similar to FDA requirements in the United States. Additionally, the China Ministry of Information Industry regulates telecom and internet equipment. In some cases, a network access license and network access identifier mark must be obtained. This process will include testing at China-based government testing laboratories.

In an effort to promote exports to China, the U.S. Department of Commerce has established a trade and standards specialist in their International Trade Administration. This is a valuable resource available to all U.S. companies that are interested in establishing a market for their products in China. Contact information is:

Jenny May
TBT and Standards Specialist
Office of Chinese Economic Area
International Trade Administration
US Department of Commerce
Washington, DC 20230
Phone: 1-202-482-5681
Fax: 1-202-482-1576
E-mail: jenny_may@ita.doc.gov

China offers a vast and growing market for various products. In order to tap this market, the CCC certification process must be followed in explicit detail. The U.S. Department of Commerce can lend guidance; however, many companies opt for the use of consulting companies and agents to assist in the time consuming process, identification, application, pre-compliance testing, and final authorization. n

Jack Black is Business Development Manger at D.L.S. Electronic Systems, and can be reached at jblack@dlsemc.com.

Dr. Yaqing Liu is an EMC and Safety Engineer at D.L.S. Conformity Assessment, and can be reached at yliu@dlsemc.com.

References

“China Visit” (page 2).
“Are you ready to take Advantage of the Huge New Market in China?” (page 2).
For more information on Chinese agents, contact Mr. Black at jblack@dlsemc.com.