*4/2/03 U.S.-China Roundtable on CCC Mark Implementation*
On April 2, 2003 U.S. Embassy officers met with officials from China’s Certification and Accreditation Administration (CNCA) to discuss implementation of the China Compulsory Certification (CCC) mark, a new safety and quality mark system. U.S. industry representatives also attended the meeting.
The meeting addressed several key issues on which U.S. companies and government officials have sought clarification, in the weeks and months before full CCC mark implementation (August 1, 2003).
1. Spare parts exemption - how to apply?
2. Spare parts exemption - where to apply, time frame, fees?
3. Spare parts exemption - how long is it good for?
4. Spare parts exemption - who do I contact?
5. Spare parts exemption - what is a “spare part?”?
6. Spare parts exemption - products used within factories.
7. Do spare parts on the CCC list, shipped as replacement parts, need the CCC Mark?
8. Spare parts made in China for export - can they be used within China?
9. What paperwork is required for spare parts shipped as replacement parts?
10. When do individual components of a finished assembled unit need the CCC Mark?
1. English-language source for CCC Mark requirements.
2. CCC Mark standards for harmonic emissions.
3. China’s use of IEC electrical standards.
1. Non-Chinese laboratory testing - when and how?
2. Is actual lab testing required, or can an applicant show existing test results?
3. Can sample testing be waived and foreign test results accepted?
4. Different models of same product - necessary to go through testing/certification twice?
5. Scheduling a factory inspection.
1. China Customs’ and CNCA’s systems for linking CCC product coverage to HS codes.
2. Product Classification - how does Chinese Customs determine what products need the CCC Mark?
3. How do CCC Mark regulations affect a company’s ability to transfer equipment?
1. Import of product before the CCC Mark has been physically applied to the product.
2. Can a company apply for CCC Mark labels simultaneous with the overall CCC certification process?
3. CCC Mark factory identification codes.
1. Can a company announce a product while it is still in the application process?
2. Products needing the prior CCIB Mark but not the new CCC Mark.
1. We understand there is an exclusionary notice that exempts spare parts from the CCC Mark requirement. However, there is some confusion on this point:
Many foreign firms without local representation have expressed difficulty in determining how to apply for exclusion. Are there plans to publish the guidelines in English and make them available via an internet site or other medium?
[editor’s note: Document No. 8 (2002) was replaced by CNCA Announcement No.3 (2005)]
2. We understand that currently, a company can apply for a CCC Mark exclusion only in Beijing. Are there plans to expand to other cities in China? What is the timeframe for getting spare parts into China? Is there a fee associated with applications for exclusion? ·
3. We also understand that an exclusion license is only valid for 1 month. Is it possible to extend the validity period? Are there other ways to make the exclusion process simpler? For example, is there a form that can be filled out and sent to CNCA for exclusion consideration, especially for entities outside of Beijing?
4. Can you provide us with specific contact information (name, address, fax number) of the CNCA department that processes applications for exemptions? U.S. exporters without local representation do not have information on how to apply for the exemption. Can the process be done via facsimile?
5. What is the definition of spare or replacement parts; i.e. are the following considered examples of spare parts:
Replacement of a broken breaker with a new one?
Replacement of a cable in a manufacturing tool?
It is also possible that a whole machine could break down and would need to be replaced. In such instances, would the machine be considered a replacement?
6. CNCA Document No. 8, describing the exemption process, does not specifically indicate whether products and components used within factories, in manufacturing processes, qualify for exemptions. To what extent do industrial products and component parts, when used only in a factory/manufacturing capacity, qualify for exemption? (But not for re-export, for which exemptions clearly apply.)
7. Are spare parts, which might be individually regulated, required to have a CCC Mark when imported as replacement parts for equipment already in China? Explanation: A company may have a lot of equipment in China that is not currently regulated. If a spare part happens to be regulated, must it be CCC marked before it can be imported? Which spare parts and component parts require the CCC Mark and which do not?
8. Can a company purchase spare parts in China made for the external market and use them within China?
9. If regulated spare parts do not need a CCC Mark, what paperwork is required for these parts that are imported as replacement parts?
10. In cases where individual components of an assembled product are on the First Catalogue, but the overall assembled product is not on the list, must those individual components obtain the CCC Mark when the product ships as an assembled unit? What about when those individual components are shipped separately, or as spare parts?
For example, when shipping an assembled automobile, would component parts like motors for power windows need the CCC Mark? If those motors for power windows are shipped later as spare parts, would they need the CCC Mark? Would they qualify for exemption?
In addition, machine tools that are not on the First Catalogue may use electrical components and cables that are on the list. When shipped as an assembled unit, would the components need the CCC Mark? If those electrical components and cables are shipped later as spare parts, would they need the CCC Mark? Would they qualify for the exemption?
1. Is there now or will there soon be an official English language source for CCC Mark requirements and all standards-related matters? Although many documents are available in English, certain critical documents such as CNCA Document Nos. 60 and 8 are not yet translated. Are there plans to translate these documents? Can you describe the methodology used to determine which documents will be translated and when they will be translated?
[Editor’s Note: CNCA has published 47 "Implementation Rules for Compulsory Certification." The booklets are available on the CNCA’s Web, in English. The booklets outline detailed technical application requirements for each of the 132 product categories. Information on all mandatory standards and mandatory conformity assessment rules are available at China's WTO/TBT National Enquiry Point:
WTO/TBT National Enquiry Point Administration of Quality Supervision, Inspection and Quarantine the People's Republic of China Telephone: 0086-10-856-22885
2. Regarding requirements for a harmonic emissions standard, it appears that China is using the 1995 IEC version while Europe is using an updated IEC version. We understand that China has agreed to delay implementing the standard. However, we have heard from U.S. companies that their products are being held to the old IEC standard and have been rejected. Can you comment on the current status of this standard?
3. Chinese standards (GB, GB/T, etc.) are often very similar but not identical to the corresponding IEC standards. How will China use the IEC standards for their compliance regulations?
1. When and how will non-Chinese lab testing and approval be incorporated?
2. Would it be possible to just show testing results rather than submit samples for testing, which can often be troublesome?
3. Submitting samples to testing and certification bodies designated by CNCA delays the time-to-market for many new products. Is there any way to waive sample testing by accepting foreign, specifically US, testing results?
[Editor’s Note: China, as a member of the international “CB Scheme,” is obligated to accept test reports for certain electrical standards from more than 40 countries participating in the CB Scheme, including the United States. Acceptance of these test reports does not eliminate the type testing requirement, but can speed the CCC mark application process in some cases.]
4. For different models of the same product, is it necessary to go through this testing and certification process twice?
5. Currently, when considering a CCC Mark application, Designated Certification Bodies wait until after all type testing and product certification is complete, before beginning the process of setting factory inspection dates. Because visa delays sometimes occur, this is slowing the factory inspection process and delaying applications. Is it possible to set tentative factory inspection dates at an earlier point in the application process?
[Editor’s Note: Chinese inspectors will need U.S. visas to visit U.S.-based facilities. The U.S. State Department subjects visa applications to a high degree of scrutiny, and visa applicants are advised to expect delays. These visa delays may slow CCC Mark applications.
At the time China announced a delay in CCC Mark enforcement to August 1, 2003, the U.S. Commercial Service in Beijing learned that CNCA is requesting about 20 foreign certification bodies it has worked with in the past to conduct factory inspection on behalf of CNCA.]
1. Regarding the HS code system, Customs changes the codes every year, which results in a discontinuity between the HS codes used by Customs and those used by CNCA. Does CNCA have a plan to synchronize their system with Customs or to update their HS codes to coincide with those used by Customs?
2. What specific items need the CCC Mark? Specifically, in cases where only a portion of the product falls under a specific a HS code requiring the CCC Mark, how does Chinese Customs assess what products need the CCC Mark and what items don’t? How can a company confirm (officially) whether a product needs a CCC Mark or not (in writing)? For example, several companies have been advised over the phone that a specific product does not need a CCC Mark, but when the product is being cleared through Customs, officers there insist the product requires a CCC Mark. If a product has been pre-determined by CNCA not to need a CCC Mark, it would be useful for a company to be able to present to Customs a written declaration from CNCA stating the product does not need the CCC Mark.
3. Will CCC Mark regulations affect a company’s ability to transfer equipment in and out of China/**/? If a company transfers equipment requiring a CCC Mark that was purchased before it was required to have the CCC Mark, must the company then get a CCC Mark? Example: A welding machine was bought in 2001, and a company wants to transfer it from Penang to Pudong in June 2003. Will they need to get it CCC marked given that it is in the current catalog of products that need to be regulated by May 1, 2003?
1. There is often a time delay between receiving the certification and physically applying the CCC mark to the product. Is it possible to import the product prior to the mark being applied so as to avoid delays and labor constraints?
2. A company must have a product CCC certificate in order to apply for a CCC compliance label. Can the approval for the labeling be obtained outside of Beijing and can it be done simultaneously with the CCC process instead of in series?
3. Currently, any factory manufacturing products for sale in China must have a factory identification code given to them by one of the designated certification bodies. China has two such bodies, i.e., CQC and CEMC. Each body has their own code, which results in each factory having to manage two separate identification code for each product line it produces depending on which certification body tests it. In the past there was only code that was issued by CCIB, is it possible to return to the old system where there was only one code?
1. Can a company announce a product while it is still in the application process so as to speed up the time-to-market for the new product?
2. Regarding post-market surveillance (after May 1st), what will be the registration process for products that need the CCIB Mark (for example, scanners and servers) which have no CCC Mark or CCIB Mark? Is there a time frame as to when such rules/regulations will be announced and made publicly available? Moreover, are there plans to implement a type of official channel of communication for companies to get clarification from central authorities if problems arise at the local level?
[Editor’s Note: With CNCA’s announcement of a delay until August 1 for full CCC Mark enforcement, please substitute “August 1" for “May 1" in the preceding answer.]
To the best of our knowledge, the information contained in this report is accurate as of the date published. However, The Department of Commerce does not take responsibility for actions readers may take based on the information contained herein. Readers should always conduct their own due diligence before entering into business ventures or other commercial arrangements. The Department of Commerce can assist companies in these endeavors.