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CCC Investigation Letter
Import regulations and certification requirements can be challenging for exporters who want to send their products into China. Before shipping to China, the certification obligation of the products should always be confirmed through a CCC check. Keep in mind that additional certification requirements such as SRRC, NAL, SELO, GACC, CEL, etc. may also apply. There is a high risk that certification obligations of a product are not correctly determined and that the product may be held by Chinese Customs.
For many products, it is not readily apparent whether a CCC certification obligation exists or not. Not every single Chinese customs official may have the specific expertise for all products. A shipment that passes through customs in Beijing without any problems may be held up for weeks in Shanghai due to perceived certification requirements.
Problems often arise during import for products that are not subject to mandatory certification due to the assumption by Chinese customs that CCC certification is required. If there is no certification requirement, we recommend that you attach a CCC investigation letter to your shipping documents. With an investigation letter from a competent organization, you minimize your risk of Chinese customs mistakenly requesting a CCC certificate for a product that does not require certification. This document shows the customs authority in China that there is no CCC obligation for the goods to be imported.
You can also use the CCC investigation letter to show your customers in China that the product is not subject to mandatory certification. Chinese business partners often do not know certification obligations either and for the reasons mentioned above, they also do not receive a conclusive or binding answer to their questions at customs. In this respect, a written confirmation by an expert body is can be helpful.
Checking the CCC requirements of products
To avoid problems at the Chinese customs, it is very important to check in advance for goods whether import regulations apply in China. It should be checked for each product whether CCC or other certification is required.
Lists of products requiring CCC certification are for general guidance only. To reliably determine the CCC obligation for products, it is necessary to check the products according to your specific functionalities and performance characteristics.
- HS Code:
A “CCC check” based only on the HS code (customs tariff number) is not useful. The code does not offer enough information to determine CCC obligation. A check based only on the customs tariff number results in many of these products being detained by Chinese customs with the indication of a missing CCC certificate. Often a CCC obligation can also be assumed, although the product does not appear in the CCC catalogue.
The reasons for errors in determining CCC obligation are that the HS code does not address the performance characteristics of products and therefore cannot cover the exact requirements of GB standards (the Chinese testing standards). In addition, the HS code is updated independently from the CCC database. Certain HS codes have not been assigned a GB standard even though the products must pass CCC certification.
- Reliable Determination of the CCC Requirement:
To reliably determine the CCC requirement for products, it is necessary to check the products according to their functionalities and performance characteristics. It is also useful to compare the international standards such as IEC with the Chinese GB standards. Consultation should also be made with the relevant authorities (CQC, CCAP, CAMC, etc.). In addition, it is advisable to communicate with CNCA-accredited test laboratories to interpret the GB standards correctly.
CCC Investigation Letter
We recommend that a CCC investigation letter be attached to the shipping documents for import into China for products that do not require CCC certification. The letter contains information on the exporter and the products themselves and shows through an independent expert body that no CCC certification is required. The letter conveys to Chinese Customs and your customer that you have done your due diligence in checking the CCC certification need for this product and that you have engaged a professional third-party service to confirm that no CCC is required.
Our CCC investigation letter can only be issued for products that are not subject to the CCC certification requirement. This is checked in advance by our CCC experts to provide the highest possible security. With the investigation letter, you can minimize the risks and additional costs incurred when the Chinese customs detains products indicating a CCC certification requirement, at a reasonable cost upfront.
CCC Customs Service and CIQ
Customs clearance in China is always a critical point for exporters in their business. Many assume that their products are not subject to a certification requirement or that an exemption applies, and therefore expect a smooth import into China. Unfortunately, products are still often detained by Chinese customs with the notification that CCC certification is required.
If a CCC certificate is obligatory, one should check whether a certification is economically reasonable. In some cases, an exemption can be applied for during import. An exemption may state that certain products subject to CCC can also be imported without a CCC certificate. Unfortunately, many people miss the fact that it is very difficult to provide the relevant evidence to apply for an exemption and that the approval is also frequently objected to by customs.
If your product qualifies under the current exemption regulations, we can support you with our CCC customs service in China and the with application for a CIQ certificate. With a CIQ certificate it is officially shown to customs that no CCC certificate is required for the goods to be imported. In this context it can make sense to have customs clearance done directly by experts in China.
If you are interested in CIQ certificate or complete customs clearance in China, please feel free to contact us.
MPR China Certification – We will be happy to assist you in verifying the CCC certification requirement of your products.
Send us an email with your request and please attach a datasheet with photo, technical data, description of use and the applicable international standards. We will check the certification obligation for up to two products free of charge.