Overview
The Standardization Administration of China (SAC: https://www.sac.gov.cn/sacen/) is the central body for all activity related to developing and promulgating national standards in China. The China National Certification and Accreditation Administration (CNCA: http://english.cnca.gov.cn/) coordinates compulsory certification and testing, including the China Compulsory Certification (CCC) mark.
Standards in the PRC fall into at least one of five broad categories: national standards, industry standards, local or regional standards, enterprise standards for individual companies, and association standards. National standards (also called [GB] standards) can be either mandatory or voluntary. Either way, they take precedence over other types of standards.
A few standards-related trends are commonly applicable to exporters to the PRC.
- First, it is important to note that laws and regulations can reference voluntary standards, thereby making the voluntary standard effectively mandatory.
- Second, for certain products, such as some electrical products, information technology products, consumer appliances, fire safety equipment, and auto parts, the PRC requires that a manufacturer obtain a safety and quality certification mark (the aforementioned CCC mark) before selling in or importing to China. This process can take some time.
- Third, numerous government agencies in the PRC mandate industry-specific standards or testing requirements for products under their jurisdiction, in addition to the GB standards and the CCC mark described above. This often leads to onerous and duplicative testing requirements.
Standards
The PRC is in the process of significantly reforming its standardization system with a stated goal of decreasing the number of mandatory standards and employing both a top-down standards development system like the European Union and a bottom-up system like in the United States.
China’s 2018 Standardization Law and subsequent implementing measures define a new system that includes national standards development by technical committees (TC) and allows for other standards-setting processes, including processes driven by industry organizations.
TCs developing national or GB standards must be accredited by the SAC. These TCs are comprised of members from government agencies, private industry associations, companies, and academia.
Chinese regulators regularly issue policies calling for standards to be developed to support national economic development. These policies often call for drafting and revision of large numbers of standards; in some cases, these policies provide incentives for the development of certain categories of standards.
Under recent reforms to China’s standardization process, certain registered industry alliances are also allowed to develop association standards, which are intended to be developed in accordance with processes similar to those in market-driven standards systems like the United States.
Some business community experts are concerned about the independence of the process for setting association standards and potential mechanisms for association standards to become national standards. A common concern among U.S. businesses operating in China is the inability to participate equally as local stakeholders in standards-setting processes.
Recently issued policies, including China’s 2019 Foreign Investment Law and the 2021 National Standardization Development Outline, state that foreign-invested enterprises should be able to participate equally with local firms in standardization processes, but in many industries, foreign companies do not enjoy equal treatment in practice.
Product Certification
The China Compulsory Certification (CCC) mark is China’s national safety and quality mark. The mark is required for 130 types of products, ranging from electrical fuses to toaster ovens to automobile parts to information technology equipment. About 20% of U.S. exports to China are on the product list.
Please review China’s CCC catalogs to determine if your product requires a CCC mark. If an exporter’s product is on the CCC mark list, it cannot enter the PRC until the CCC registration has been obtained and the mark is physically applied to individual products as an imprint or label. Domestic products also cannot be sold in China without obtaining registration and applying the mark on individual products.
Obtaining the CCC mark involves an application process with authorized Chinese certification bodies. At present, six foreign testing organizations have been designated to test certain categories of products to CCC mark GB standards. The application process can take several months or more and can cost upward of $4,500 in fees, in addition to inspectors’ travel costs.
The CCC process can include the following steps:
- Safety testing of products to ensure the products meet safety and/electrical standards in a Chinese laboratory.
- Inspection of applicant’s factories to determine whether the product line matches the samples tested in China.
- Approval of the design and application of the CCC logo on the applicant’s products by Chinese testing authorities.
Some companies, especially those with a presence in the PRC and with a dedicated certification/standards staff, can manage the application process in-house. Other exporters can work with standards consultants based both in the United States and in China who can provide application management services and handle all aspects of the application process.
Though the CCC mark is the PRC’s most widely required product certification mark, other product certification requirements exist.
Accreditation
China National Accreditation Service for Conformity Assessment (CNAS) is the national accreditation body of the PRC solely responsible for the accreditation of certification bodies, laboratories, and inspection bodies as authorized by the CNCA in accordance with the Regulations of the People’s Republic of China on Certification and Accreditation. A list of accredited bodies can be found on the CNAS website.
Conformity Assessment
CNCA is the primary government agency responsible for the supervision of China’s conformity assessment policies, including its primary safety and quality mark, the China Compulsory Certification (CCC) mark. CNCA supervises the work of the China National Accreditation Service for Conformity Assessment (CNAS), which accredits certification bodies and laboratory and inspection facilities.
Publication of Technical Regulations
The PRC is obligated to notify other World Trade Organization members of proposed technical regulations that would significantly affect trade. Notifications are made through the Technical Barriers to Trade (TBT) Committee notification point.
All WTO members, including China, are required to allow for a reasonable amount of time for comments to proposed technical regulations. Historically, China habitually only allowed comment periods of a few weeks, as opposed to the standard of 30 to 60 days practiced by other nations and recommended by the TBT Committee.
Use ePing to review proposed technical regulations and conformity assessment procedures
The ePing SPS&TBT platform (https://epingalert.org/), or “ePing”, provides access to notifications made by WTO Members under the Agreements on Sanitary and Phytosanitary Measures (SPS) and Technical Barriers to Trade (TBT), distributed by the WTO from January 16, 1995 to present. ePing is available to all stakeholders free of charge and does not require registration unless the user wishes to receive customized e-mail alerts. Use it to browse notifications on past as well as new draft and updated product regulations, food safety and animal and plant health standards and regulations, find information on trade concerns discussed in the WTO SPS and TBT Committees, locate information on SPS/TBT Enquiry Points and notification authorities, and to follow and review current and past notifications concerning regulatory actions on products, packaging, labeling, food safety and animal and plant health measures in markets of interest.
Notify U.S., operated and maintained by the National Institute of Standards and Technology (NIST) since 2003 to distribute and provide access to notifications (and associated draft texts) made under the WTO TBT Agreement for US stakeholders, has reached its end of life. Per obligation under the TBT Agreement, each WTO Member operates a national TBT (and an SPS) Enquiry Point. National TBT Enquiry Points are authorized to accept comments and official communications from other national TBT Enquiry Points, which are NOT part of the WTO or the WTO Secretariat. All comment submissions from U.S. stakeholders, including businesses, trade associations, U.S domiciled standards development organizations and conformity assessment bodies, consumers, or U.S. government agencies on notifications to the WTO TBT Committee should be sent directly to the USA WTO TBT Inquiry Point. Refer to the comment guidance at https://tsapps.nist.gov/notifyus/data/guidance/guidance.cfm for further information.
Contact Information
For updated details on testing, inspection, and certification, please contact Cathy.Feig@trade.gov.