Certification regulation for Canadian exporters in China

China Compulsory Certification (CCC) is a compulsory product certification system covering a wide range of products. Items subject to CCC generally encompass goods with potential implications for safety, health, environmental protection, or regulatory control, spanning many consumer, industrial, and technical products placed on the Chinese market. If you intend to export products to China, you need to be aware of CCC's coverage and requirements.

For a comprehensive list of the products covered by the new regulations, please refer to the Certification and Accreditation Administration of China (CNCA) (in Simplified Chinese only), the Chinese government agency that regulates the CCC.

Getting the CCC mark

When Canadian companies are exporting to China, their products, if identified under the CCC regime, must be certified with the CCC mark. The length of time needed to obtain certification varies. CCC's service standard is three months, but the time required can be much longer depending on the nature of the product and required testing.

There are five major steps in the CCC mark application process:

1. Submission of an application and supporting materials, including credentials of the applicant, a general assembly diagram, an electrical schematic diagram, a circuit diagram, a list of key components and/or main raw materials, a copy of the contract, and other information. A Canadian company can apply on its own, or use an agent or a consultant to manage the application.
2. Type testing. A CNCA-designated test laboratory in China will test product samples.
3. Initial factory inspection. A CNCA-designated certification body will send representatives to inspect the manufacturing facilities for the product.
4. Evaluation of certification results, and approval (or failure or retesting)
5. Follow-up factory inspection. The certification body will re-inspect the product and the manufacturing facilities on a regular basis. The frequency of follow-up inspection depends on the security level and quality stability of the product and the record of the manufacturer.

Applicants must pay the following fees: the application fees, product testing, initial factory inspections, follow-up inspections, and label costs. Once the application is approved, a CCC certificate is valid for five years. Applicants can apply for the renewal of the CCC certificate 90 days before the expiry of the certificate.

Since the short description in the product catalogue may not be specific enough to determine whether the CCC mark applies to your products, we encourage exporters and potential exporters to review CNCA's "Implementation Rules for Compulsory Certification" booklets which outline detailed technical application requirements for each of the product categories. The booklets each provide a "scope" section, which in some cases includes a more detailed description of which products require the CCC mark.

The CCC regime stipulates special conditions under which CCC requirements do not apply, as follows:

• Those which diplomatic agencies and personnel use;
• Those which Hong Kong and Macao SAR agencies and personnel use;
• Those brought by travellers into China for self-use;
• Those with the nature of governmental aid and gift.

CNCA also grants exemptions upon application in order to address special situations in the commercial activities such as manufacturing and importing.

• Those for research and testing;
• Those parts for testing the production lines with an intention of importing technology;
• Those directly used for maintenance for end users;
• Those equipment/parts complementing the factory production lines/sets of production lines (excluding office supplies);
• Those exclusively for commercial exhibition, but not for sale;
• Those imported temporarily and then outbound (exhibition commodities included);
• Those parts imported in general trade with a purpose of exporting the complete machines;
• Those spare parts imported in imported materials processing trade or supplied materials processing trade with a purpose of exporting the complete machines.

To obtain exemptions, manufacturers, distributors, or agents, have to apply directly to local inspection and quarantine bureaus, with sufficient evidence such as responsibility guarantee certificates, and product compliance announcements (including testing reports). After being approved and obtaining exemption certificates, products can be sold, imported or used for other commercial activities.

Under special circumstances (CNCA Announcement No. 38, 2008), low-volume goods, which are used as a production input and for household consumption do not need CCC certification due to "special use" or "special reasons", may be exempted from CCC after inspections administered by local inspection and quarantine bureaus and authorized laboratories. Applications for this type of exemption should be addressed to local inspection and quarantine bureaus.

Regarding components, CNCA informs us that if a complete product does not require CCC, a component subject to CCC will generally not need a CCC label as long as it is an integral part of the finished product and so shipped. However, a lack of clarity exists regarding the treatment of finished products' components. Therefore, we strongly recommend that exporters consult a certification body or CNCA directly for clarification prior to export. CCC requirements for parts used for maintenance, repair or operations purposes may be waived, but an application should be made directly to CNCA.

The Trade Commissioner Service can assist you by conducting a preliminary check to see whether your products are likely covered by CCC. For assistance, please email us at bejingtdinfocentre@international.gc.ca.

To make further technical inquiries regarding CCC, for formal confirmation, and to proceed with a CCC application, we recommend contacting a CNCA-designated certification body listed at the CNCA website. 

Hundreds of Chinese and international agents and consultants are in the business of assisting companies apply and manage applications for CCC certification. Below, we have provided the contact information of a number of agents. Please note that this is not a comprehensive list. The inclusion of the listed third party service providers should not be considered to be an endorsement. You should independently verify any service providers and complete all reasonable due diligence prior to engaging their services.

• CSA Group (Canadian Standard Association) 
• CCIC Canada Inc. 
• TUV Rheinland
• Bureau Veritas
• Intertek Testing Services