The National Certification and Accreditation Administration of China issued a new statement announcing important changes to the CCC certification regulations. These changes have had an impact on many car suppliers and car manufacturers.

The China Compulsory Certification (CCC) program is similar to other product quality and safety certifications, such as the European CE system. The CCC program was first launched in 2002 and is applicable to imported goods and Chinese products. Products that require certification can only be imported, sold and/or used in commercial activities in China after obtaining the China Compulsory Product Certificate.

In its Announcement No. 44 of 2019 dated October 17, 2019, the National Certification and Accreditation Administration of the People's Republic of China (CNCA) made major changes to the CCC certification regulations.

With immediate effect, certain products (such as automotive interior parts) no longer form part of the CCC certification program (Annex 1). For some other product categories, a new certification model has been put in place, namely CCC self-declaration (see Annex 2).

Both of these changes raise many questions and require manufacturers of products affected by the announcement to take action. This article provides detailed information about the impact of the change and what manufacturers must know.

The products listed in Annex 1 (Table 1) of the announcement, such as automotive interior parts, no longer fall under the jurisdiction of CCC, and can voluntarily obtain CCAP mark or CQC mark certification to show compliance with the requirements.

The CCAP/CQC mark certification process is very similar to the current CCC process. It still needs to conduct a follow-up factory inspection once a year to maintain the validity of the certificate and prove that it continues to meet the relevant standards. At the same time, annual product testing is also required. And, instead of the CCC mark, use the CCAP/CQC mark for marking.

Based on the latest information, there may be a transition period for existing certificate holders so that the marking can be changed the next time the tool is regularly replaced.

So far, manufacturers can easily change their CCC certificate to CCAP or CQC certificate for free. The deadline has not been communicated. If the certificate will not be converted, it will no longer be valid.

By converting existing CCC certificates to CCAP/CQC certificates, manufacturers can continue to demonstrate compliance with China's current standards and regulations. However, it is recommended that manufacturers consult their customers, such as car manufacturers, because they may need CCAP/CQC certification for their products. Since it is easier to convert a certificate than to start a brand new certification process, the conversion should be done in time to avoid any problems with Chinese customs officials.

Annex 2 (Table 2) shows products that still require CCC certification but must now pass a new certification model called CCC self-declaration or declaration of conformity.

Starting from January 1, 2020, the above product categories must demonstrate compliance with Chinese standards and regulations through CCC self-declaration. Manufacturers must convert their current CCC certificates to CCC self-declaration certificates before October 31, 2020. After this date, the previous CCC certificate will be cancelled.

Depending on the product category, two different procedures apply. Although the procedure of Procedure A provides the possibility of free choice of testing laboratories, procedure B requires type testing in designated testing facilities in China. In either case, it must be tested in accordance with relevant implementation rules and GB standards. In addition, test reports and technical documents must be uploaded to the online system in China. The CNCA is responsible for supervising the CCC self-declaration and its correct implementation.

The China CCC self-declaration is based on the implementation rule CNCA-00C-008:2019. Specific implementation rules for individual products still apply. However, regardless of the applicable procedures, online registration requires the applicant to be in China, which is very different from the previous certification process. The Chinese applicant bears the ultimate responsibility and obligation for the CCC self-declaration and certified products.

Due to the potentially significant risks of changes in products or production lines that have not been reported to the Chinese authorities, in addition to the CCC self-declaration, it makes sense to obtain voluntary CQC or CCAP certification. This method includes annual factory audits, which can fully ensure that products always comply with Chinese regulations.

The certification work currently in progress must be completed before the end of 2019. After this date, certification must follow the CCC self-declaration model. The validity period of the newly issued CCC self-declaration certificate is ten years, if no changes are made to the product.

With the release of the latest news, Chinese certification bodies have once again demonstrated their habit of publishing important information with immediate and far-reaching impact. However, at least for now, there are still many issues that need to be investigated and decided.

In order to cross this period, it is meaningful to convert the existing CCC certificate to a voluntary certificate and obtain the CCC self-declaration certificate of the affected products as soon as possible. As this transition is currently provided free of charge by

The Chinese authorities, this will allow some time to decide what to do in the future.

In short, the latest changes mean that the responsibility is transferred to the manufacturer and the applicant, because only they can take responsibility in the event of any quality problems or non-conformities. Through voluntary CQC or CCAP mark certification, this risk can be significantly reduced. 

It remains to be seen whether the Chinese certification body will maintain this process, exempt more products from the compulsory certification scheme, or expand the CCC self-declaration model for other product groups. Therefore, manufacturers must always comply with Chinese standards and fully understand any changes in Chinese regulations.

Julian Busch is the managing director of MPR China Certification GmbH-China Certification Company (http://www.certification-india.com/en), which supports global manufacturers in obtaining product certifications in India, China, South Korea and other markets.

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