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Omission of Compulsory CCC Certification for Certain Products and Implementation of CCC Self-Declaration for Other Products

18. October 2019

In their latest announcement (No. 44, 2019, dated October 17, 2019) the Chinese certification authority CNCA (Certification and Accreditation Administration of the People’s Republic of China) made changes to the CCC certification regulations.

As of October 17, 2019, certain products including automotive “Interior Trimming” and automotive “Door Locks and Door Retention Components” are no longer subject to CCC certification (see Annex 1 for a complete product list).

Automotive “Interior Trimming” and automotive “Door Locks and Door Retention Components” can still obtain voluntary certifications from the CQC and CCAP.

For selected other products, including automotive components such as “Safety Belts, Exterior Lighting and Light Signaling Devices, Seats and Seat Headrests, Indirect Vision Devices and Safety Glass,” the CCC Self-Declaration mode is required and will be the only mode of CCC certification for these products (see Annex 2 for a complete product list).

All products requiring China self-declaration/ China Supplier Declaration of Conformity (SdoC) can still obtain a voluntary CQC mark certification or voluntary CCAP mark certification in addition to the CCC Self-Declaration.

All products requiring China SDoC can still obtain voluntary CQC mark certification or voluntary CCAP mark certification in addition to the required CCC Self-Declaration.
Here is a brief video for manufacturers of interior trimming products about the CNCA announcement no. 44, presented by Julian Busch,
director of MPR China Certification GmbH / China Certification Corporation:

Here is a brief video about the CNCA announcement no. 44 for manufacturers that are affected by the CCC Self-Declaration, presented by Julian Busch,
director of MPR China Certification GmbH / China Certification Corporation:

Omission of Compulsory CCC Certification for Certain Products

With the immediate omission of the CCC certification, affected products (see Annex 1) may no longer obtain a CCC certificate and existing certificates are subject to cancellation. Product conformity however, must still be maintained and demonstrated. For this reason, we recommend the conversion of current CCC certificates into voluntary CQC or CCAP certificates at the respective certification authorities (CCAP and CQC). This will ensure that the Chinese regulations are fulfilled at all times and simplify the homologation of the complete vehicle as well.

The process of voluntary certification is almost identical to the current CCC certification, the only major change would be to replace the CCC logo with the logo of the respective certification authority (CCAP or CQC logo) providing the voluntary certification.

Please read our news regarding the marking of parts that are already certified here.

The transformation of the current CCC certificates to voluntary certificates can be done free of charge within a certain period of time and will be handled by us at no charge during this transition period.
To avoid difficulties during the import of your products to China, the conversion should take place in a timely manner.

For all other questions about the voluntary certification, the application process, audit preparation, change management or certificate extensions, please call or email us. We will be happy to advise you.

The CCC Self-Declaration for Certain Products

Manufacturers of certain products listed in Annex 2 (below) can chose between the traditional certification process at CQC or CCAP and the CCC Self-Declaration until December 31, 2019. However, new certificates with the traditional certification mode can only be issued till December 31, 2019. After this date, applications must be completed with a CCC Self-Declaration. From January 1, 2020, manufacturers must apply for a China CCC Self-Declaration for new products as well as for changes or adjustments to existing products.

Manufacturers must convert their traditional CCC certificates into CCC Self-Declaration certificates by October 31, 2020. Traditional CCC certificates for products mentioned in Annex 2 will be cancelled on November 1, 2020.

In addition to the CCC Self-Declaration of Certification manufacturers can always apply for a voluntary product certification with the CQC or CCAP to ensure and proof the conformity of production to the Chinese regulations.

The CCC Declaration of Conformity is a new process that was first established in 2018, however the Self-Declaration of Compulsory Product Certification must not be confused with an omission of the CCC compliance regulations – all relevant GB standards and CNCA Implementation Rules remain valid and product compliance must continue to be proven during production by conducting annual product tests according to the GB standard. All affected products will still need to be marked with the CCC logo.

The Implementation Rule for the CCC Self-Declaration is CNCA-00C-008: 2018. An online platform managed by CNCA is used for the applications and maintenance of the China SDoC’s. Applicants must register their plants and products and provide information regarding the products and production facility. No factory inspection will be required, but annual product tests will remain a key part of the CCC Self-Declaration. The applicant must be a Chinese subsidiary, importer or dealer of the manufacturer. Please find more information here about the possible impact on the social credit rating of the applicant.

If you do not have a company in China that can act as an applicant, we can assist you with our company foundation package. Here you can find more information.

We can also offer you the placement of a CCC applicant service for the Self Declaration.

You can find more information on this service here.

The Self-Declaration of Compulsory Product Certification has two product types known as “Type A” and “Type B.” Type A products will be allowed to be tested in own or self-determined laboratories, whereas Type B products must be tested in laboratories accredited by the Chinese authority CNAS.

We recommend to stick with the established process with the annual audit by obtaining a voluntary certification in addition to obtaining the CCC Self-Declaration. Going through an annual audit may seem to be more complex and time-consuming, but it gives you and your customers more security since the audit and the process are organized and approved by a Chinese certification authority.

Without annual audits the risk increases significantly that relevant changes to the product, production or plant are not reported to the CNCA. With the audit, process problems and shortcomings can be quickly identified and remedied. In the case of the Supplier Declaration of Conformity, the responsibility and liability lie primarily with the applicant and manufacturer. High penalties and sanctions are expected in the event of violations of the Chinese regulations. It is expected that customs inspections and vehicle inspections will be intensified in order to detect possible problems such as incomplete or incorrect information in the CCC Self-Declaration.

Maintaining the current certification process in cooperation with the Chinese certification authorities as part of the voluntary certification is, in our view, a safer and more risk-averse approach for automotive suppliers and car manufacturers. The CCC SDoC alone does not ensure oversight of the conformity of production and could lead to problems.

Of course, there are also other ways to ensure conformity of production. For example, the manufacturer can perform internal audits in addition to internal testing. We can also support with professional audits and annual product tests.

Here is a brief video about the CCC Self-Declaration, presented by Julian Busch, director of MPR China Certification GmbH / China Certification Corporation:

Here is a brief video about the CQC and CCAP mark certification, presented by Julian Busch, director of MPR China Certification GmbH / China Certification Corporation:

Find more videos on our Video Channel.

Here you can download our detailed brochure about the CCC Self-Declaration.

Here you can download our brochure about the voluntary CQC and CCAP certification.

Please contact us if you have any questions regarding the new regulations, voluntary certifications, the CCC Self-Declaration or the transformation of CCC certificates.

You can contact us via email, or call us (Europe: +49 69 2713769150, UK: +44 2071931135, US: +1 773 654-2673).

Appendix 1

NumberName of productCNCA Implementation Rules
Product categorySub product category and code
1Wire and CablesWire and cable for railway vehicles with A.C. rated voltage of 3kv and below (0103)CNCA-C01-01:2014
2Electrical toolsElectric screwdriver and impact wrench (0502)CNCA-C05-01:2014
3Sanding machine (0504)
4Circular sa (0505)
5Electric welderSmall AC arc welder (0601)CNCA-C06-01:2014
6AC arc welder (0602)
7Submerged arc welding machine (0606)
8Plasma arc welder (0608)
9Arc welding transformer anti-shock device (0609)
10Welding cable coupling device (0610)
11Resistance welder (0611)
12Audio and video equipmentTuning receiver, radio for various broadcast bands (0804)CNCA-C08-01:2014
13Monitor (0809)
14Motor vehicle and safety accessoriesAutomotive interior parts (1111)CNCA-C11-09:2014
15Car door locks and door hinges (1112)CNCA-C11-10:2014
16Safety glassRailway vehicle safety glass (1303)CNCA-C13-01:2014
17Telecommunications terminal equipmentFixed telephone terminal and telephone add-on devices (1603)CNCA-C16-01:2014
18Group phone (1605)

Appendix 2

NumberName of productCNCA Implementation RulesProcedure A/BRemark
Product categorySub product category and code
1Electrical toolsElectric drill(0501)CNCA-C05-01:2014Self-declaration procedure A (Type test in optional laboratory + self-declaration)Newly added
2Electric grinder(0503)Newly added
3Electric hammer(0506)Newly added
4Electric welderDC arc welder(0603)CNCA-C06-01:2014
5TIG arc welder(0604)
6MIG/MAG arc welder(0605)
7Plasma arc cutting machine (0607)
8Circuit switch and electrical device for protection or connectionThermal fuses(0205)CNCA-C02-01:2014Self-declaration procedure B (Type test in designated laboratory + self-declaration)Newly added
9Cartridge fuse-links of miniature fuses(0207)Newly added
10low-voltage apparatusLeakage protector (0306)CNCA-C03-02:2014Newly added
11Circuit breaker(0307)Newly added
12Fuse(0308)Newly added
13Low-voltage switchgear (disconnectors, switch-disconnectors and fuse-combination units)0302)Newly added
14Other circuit protection devices(0304, 0307, 0309)Newly added
15Relay(0303)Newly added
16Other switches(0305)Newly added
17Other device(0304, 0305)Newly added
18low-voltage switchgear assemblies (0301)CNCA-C03-01:2014
19Low power motorLow power motor (0401)CNCA-C04-01:2014
20Equipment for Household and similar usesMotor-compressor(0704)
21Motor vehicle and safety accessoriesCar seat belt (1104)CNCA-C11-04:2014Newly added
22Motor vehicle exterior lighting and light signal devices (1109, 1116)CNCA-C11-07:2014 CNCA-02C-065:2005Newly added
23Car seat and seat headrest (1114)CNCA-C11-12:2014Newly added
24Motor vehicle indirect vision device (1110, 1115)CNCA-C11-08:2014 CNCA-02C-064:2005
25Car drive recorder (1117)CNCA-C11-14:2014
26Car reflecting marking(1118)CNCA-C11-13:2014
27Safety glassCar safety glass (1301)CNCA-C13-01:2014Newly added
Information technology equipment, Audio and video equipmentEquipment with rated voltage less than or equal to 5VDC, rated power consumption less than 15W (or 15VA) and no rechargeable battery (class III equipment)CNCA-C09-01:2014 CNCA-C08-01:2014Self-declaration procedure A (Type test in optional laboratory + self-declaration)

MPR Author

About the author: Julian Busch is founder and managing director of MPR China Certification GmbH
Publisher: MPR China Certification GmbH

Tel.: +49 69 271 37 69 150