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The government of China has introduced a new safety license system. The new system requires manufacturers in 132 product categories to obtain the China Compulsory Certification (CCC) mark before exporting to or selling in the China market. The new system, implemented on May 1, 2002 and fully effective on May 1, 2003, will impact many U.S. exporters, across a wide range of manufacturing sectors. Products not meeting CCC requirements may be held at the border by Chinese Customs and will be subject to other penalties.

The application process for the CCC mark:

• can take sixty to ninety days or longer;
• requires testing at accredited laboratories in China;
• generally does not permit self certification or third-party testing results;
• requires submission of numerous technical documents;
• requires submission of a product sample to a Chinese testing laboratory;
• requires a factory inspection by Chinese officials at the applicant's expense;
• requires follow-up inspections every twelve to eighteen months; and
• can cost several thousand dollars.

THE CHINA COMPULSORY CERTIFICATION MARK

Chinese requirements for safety and quality certification are not new. Since 1989, China has had a safety licensing system, which included the CCIB Safety Mark, required for products in 47 product categories, and the CCEE "Great Wall" Mark, for electrical commodities in seven product categories. As the certification system grew through the 1990s, many companies exporting to China raised concerns about the dual certification systems, redundant testing, and differential treatment of domestic products and imported products.

When China negotiated the terms of its World Trade Organization (WTO) membership in the late 1990s and through 2001, it acknowledged some of the problems inherent in its existing system, and agreed to merge its two certification regimes into a single unified system, with equal treatment for domestic products and imports.

In December, 2001, at about the same time it joined the WTO, China announced the new China Compulsory Mark system and the list of covered products. The system was put in place on May 1, 2002, with a one-year transition period, with the system fully effective -- and mandatory for all goods in the product catalogue -- on May 1, 2003.

The CCC Mark is administered by the Chinese government agency Certification and Accreditation Administration (CNCA). The China Quality Certification Center (CQC) is designated by CNCA to process CCC mark applications.

Step One: Determine Whether Your Products Require CCC Marking

• First, examine CNCA's product catalogue and determine whether your products, or component parts within your finished goods, require CCC marking. The product catalogue is a list, divided into 132 broad product categories, of all the products requiring CCC marking. Click here to view the list or go to the catalogue on the CQC's website at: http://www.cqc.com.cn/ccc/catalogureeng.pdf.

• If the short descriptions in the product catalogue are not specific enough to determine whether the CCC mark applies to your product, you have two other options:

• Review CNCA's "Implementation Rules" booklets, described at Step Two, below. The 47 booklets each provide a "scope" section which in some cases provide a more detailed description of which products require the CCC mark.

• Review CNCA's "Announcement 60," a table linking HS codes to products which require the CCC mark. http://www.cnca.gov.cn/board/bianmabiao.htm. The document is only available in Chinese, but you may be able to locate the HS codes of your company's products. You may then want to hire a translator to translate that section. Don't know your HS codes? If you've exported to China before, check with your distributor, export agent, or whoever handles your Chinese Customs paperwork. If you've not exported to China and need to find out your HS codes, contact the Foreign Trade Division of the U.S. Census Bureau. For durable goods, call 301-763-3259. For non-durable goods, call 301-763-3484.

• Be aware that component parts of a manufacturer's finished products may in some cases require CCC certification; in those cases, the component manufacturer is generally required to apply for the CCC mark. Also be aware that spare parts and replacement parts shipments may in some cases require CCC certification, or application for an exemption. Click here for more information on spare parts, components, and the CCC exemption process.

Step Two: Get the Implementing Regulations

CNCA has published 47 "Implementation Rules for Compulsory Certification." The booklets are available on the Web, in English, at http://www.cnca.gov.cn/download/english.html. The booklets outline detailed technical application requirements for each of the 132 product categories.

CNCA's Implementation Rules cite numerous "GB Standards," which are mandatory standards. Information on mandatory standards is 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
Facsimile: 0086-10-856-22884
E-Mail: TBT@AQSIQ.GOV.CN

Step Three: Consider Your Options for Applying

Some companies use agents or consultants to manage their CCC mark applications. Other companies apply on their own, or rely on their importers or distributors. Check with your Chinese partners, distributors, or your export managers. They may have experience with the CCC mark and can point you to other resources.

If you elect to use a consultant, several U.S. firms can help you apply and manage your applications for CCC certification. Several firms have indicated to the Commerce Department that they provide such services. The Department of Commerce cannot endorse any individual company. Please note that this is not a comprehensive list.

Approval Specialists, Inc.
EMC Compliance Management
Emerge Logistics
Intertek Testing Services
SIMCOM International
TUV America
TUV Rheinland of North America
Underwriters Laboratories

Step Four: Apply

There are five major steps in the CCC mark application process. If your company elects to handle the application process, your first step should be to visit the website of the China Quality Certification Center (CQC), which administers the CCC mark application process.

At the website, click on the "CCC Application Online Guide," a Microsoft Word Document giving step-by-step instructions on how to apply for the CCC mark. The five-step application process includes:

1. Application. Submission of an application and supporting materials, including user guides, CB reports, EMC reports, regulatory labels and other information.
2. Type Testing. A CNCA-designated test laboratory in China will test product samples.
3. Factory Inspection. CQC will send representatives to inspect the manufacturing facilities for your product. They will inspect each factory producing your product (e.g. If your company manufactures Product Z in five separate factories, all of which ship product to China, you will need to have five separate factory inspections). Please note: Chinese inspectors will need U.S. visas to visit U.S.-based facilities. The U.S. State Department is now subjecting visa applications to a greater degree of scrutiny than in the past, and visa applicants are being advised to expect delays. These visa delays may slow your CCC mark application.
4. Evaluation of certification results, and approval (or failure or retesting).
5. Follow-up Factory Inspection. Manufacturing facilities for the product will be re-inspected by Chinese officials every 12-18 months.

Step Five: Note Other Chinese Licensing Requirements

Like many countries, China has multiple certification schemes. Though the CCC mark is the widest-ranging certification requirement, your product may have to meet other requirements as well. For example, China's Ministry of Information Industry regulates telecom and internet equipment, and for certain equipment requires manufacturers to obtain a "Network Access License" and "Network Access Identifier Mark," which includes requirements for testing in Chinese test laboratories. Similarly, China's State Drug Administration requires product registration for certain medical devices.

CONTACT US

U.S. exporters with questions about the CCC mark can contact the Commerce Department for more information about CCC mark rules, as well as other questions about China's regulatory system and its standards. The Commerce Department is the principal advocate for American enterprises doing business overseas, and also serves as an information resource for exporters.

Contact the Commerce Department's China Desk with any questions about the CCC mark and other Chinese standards and certification requirements.

Timothy Wineland
TBT and Standards Specialist
Office of the Chinese Economic Area
International Trade Administration
U.S. Department of Commerce
Washington, DC 20230
Telephone: 202-482-5316
Facsimile: 202-482-1576
E-Mail: Timothy_Wineland@ita.doc.gov

Contact the Commerce Department's Trade Information Center with any export-related question.

Trade Information Center
Telephone: 1-800-USA-Trade
E-Mail: TIC@ita.doc.gov
http://www.export.gov/tic

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February 2003
U.S. Department of Commerce
International Trade Administration

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