China Compulsory Certificate
The China Compulsory Certificate mark, commonly known as a CCC Mark, is a compulsory safety mark for many products imported, sold or used in the Chinese market. It was implemented on May 1, 2002 and became fully effective on August 1, 2003.
It is the result of the integration of China's two previous compulsory inspection systems, namely "CCIB" (Safety Mark, introduced in 1989 and required for products in 47 product categories) and "CCEE" (also known as "Great Wall" Mark, for electrical commodities in 7 product categories), into a single procedure.
The CCC mark is required for both Chinese manufactured and foreign imported products. Consequently, there is a relevant and useful catalogue of CCC-compulsory products just for this purpose. Further, if any commodities or other general vendibles need to be certified, then it is a fittingly practical undertaking for one to also look at the Guobiao standards - the National Standards of China used in the testing process (short: GB Standard). The catalogue itself addresses the following sets of goods, in addition to their parts:
- Electrical wires and cables
- Switches for circuits, Installation protective and connection devices
- Low-voltage Electrical Apparatus
- Small Power motors
- Electric tools
- Welding machines (incl. wire feeder and power supply)
- Household and similar electrical appliances
- Audio and video apparatus
- Information technology equipment
- Lighting apparatus
- Telecommunication terminal equipment
- Motor vehicles and Safety parts
- Motor vehicle tyres
- Safety Glasses
- Agricultural Machinery
- Fire Fighting Equipment
- Detectors for Intruder Alarm Systems
- Wireless Local Area Network (WLAN) systems
Apart from the GB Standard, the implementation rules are the second important component that form the basis of CCC certification. The implementation rules determine the process of the CCC-Certification and list the mandatory products for the certification. Based on many regulatory amendments, it is important to get the latest version of the implementation rules before starting the certification process.
In 2014, a comprehensive regulatory amendment of the Implementation Rules had taken place. The major changes are:
- Amendments for Automotive Parts
- Introduction of factory levels (A-D)
- Self-made products for end products do not require a CCC Certificate anymore
The CCC mark is administered by the CNCA (Certification and Accreditation Administration of the People's Republic of China). The China Quality Certification Center (CQC) is designated by CNCA to process CCC mark applications and defines the products that need CCC. The products are summed up in overall product catergories. Additionally, the following certification authorities are responsible for specific groups of products:
- CCAP (China Certification Centre for Automotive Products) products in the automotive area
- CSP (China Certification Center for Security and Protection) certifies security products, forensic technology and products for road safety
- CSCG (China Safety Global Certification Centre) for safety glass
- CEMC (China Certification Centre for Electromagnetic Compatibility) all electronic products
The certification process usually takes between 4–8 months and includes the following steps:
- Submission of application documents and supporting materials
- Type Testing. A CNCA-designated test laboratory in China will test product samples
- Factory Inspection. The certification authority will delegate representatives to inspect the manufacturing facilities
- Evaluation of the results
- Approval of the CCC Certificate (or failure and retesting)
- Annual Follow-up Factory Inspections by Chinese officials
The CCC certificate and the Permission of Printing, which allows the manufacturer to mark the CCC-certified product with the CCC mark, must be renewed annually in order to keep the validity of the certificate. The renewal can only be done through a follow-up certification. Part of the follow-up certification is a one-day factory audit.
The proceedings of the follow-up certification are comparable with those of the initial certification, but overall much shorter, simpler and associated with a lower cost. Usually, no further product tests in China are requested and the audit will be kept compact.
IT security products
On April 27, 2009, China announced 13 categories of the IT security sector products that must conform to the additional authority that was newly bestowed on the CCC (China Compulsory Certificate), and this requirement was to be put into effect on May 1, 2009. In view of the security measures taken by China, there was a seemingly high likelihood that they would request the full disclosure of all source codes running on any and all devices, imported or otherwise. The divulgence of such source codes is of great concern to countries like the U.S., Japan, the EU, and South Korea; all four asked China to reverse this decision and objected to the implementation of the Chinese plan. Thus, the certification agents were soon limited to the organizations and entities within China - a compromise of sorts. However, despite this restriction, there still arose other concerns as to whether source codes and trade secrets could be leaked to the private sectors. In response to these enduring concerns, China altered the previously planned CCC policy programme. Instead of administering broad and stringent encroachments upon the relevant categories of imports (primarily, computer technology), they decided to engage in an alternate regulatory action solely affecting government procurement projects, while simultaneously postponing the enactment of the policy programme to May 1, 2010. China also stated that the number of applicable CCC product categories is not to expand past the current 13 already in place.
List of IT security products
- Secure operating system package
- Organisational systems for the isolation, safety, and exchange of information
- Secure network routing devices
- Security supervision system
- Secure database architecture technology
- Countermeasure program for spam (trouble/nuisance) mail
- Firewall security system
- Invasion and detection system
- Data backup/recovery product
- Network security involving LAN card and hub switching
- Network vulnerability scanning programs
- Web site recovery product
- Secure Smart card and advanced smart card operating system technology
Protection of intellectual property in the CCC certification
Although the CCC-Certification’s only purpose is to ensure compliance of products with the Chinese standards, many companies are worried that infringements of their trademarks or patent occur during the CCC-Certification. Especially regarding the following steps, companies are troubled:
- Comprehensive product information for the application are required
- Type test of the products in an accredited test laboratory in China
- Factory audit by Chinese inspectors examine the factory
The risk of trademark or patent infringements caused by the CCC-Certification are small. In general it is not only important for the CCC-Certification to deal with the protection of intellectual property in China.
For the best possible protection for the own products there are:
- Preventive Measurements
- Protecting Intellectual Property Rights in China
- "Certification in Brief". China Quality Center (CQC). Retrieved 2013-03-13.
- "Switches for circuits, Installation protective and connection devices", CQC, http://www.cqc.com.cn/english/ProductCertification/CCC/CertificationScope/webinfo/2014/09/1409864497489063.htm vom Juni 2015, abgerufen 16.06.2015.
- "CQC Toys". Retrieved 2015-07-01.
- "Regulations for Compulsory Product certification". CQC. Retrieved 2015-07-22.
- „ New factory levels for CCC-Inspection", CCAP, http://www.cccap.org.cn/newsHtml/20150409/20150409.htm July 2015, 22.07.2015.
- "Official website of Certification and Accreditation Administration of the People's Republic of China". CNCA. Retrieved 2015-07-22.
- "Official website of the CCAP". CCAP. Retrieved 2015-07-22.
- "CCC Certification for Electromagnetic Compatibility assigned to CEMC". CQC. Retrieved 2015-07-20.
- "Information Security, U.S.-China Joint Commission on Commerce and Trade". USTR. 2009-10-29. Retrieved 2009-12-31.
- "China, CCC Certification News Update". nemko.com. 2009-09-10. Retrieved 2009-09-18.
- "Chinese certification of information security products". nemko.com. 2009-08-28. Retrieved 2009-09-18.
- Note that product naming is literal translation from China published wording to Japanese by several number of Japanese industrial associations, then further literary translated to English.
- "中国CCC 強制認証対象品目一覧表2009 年版" [List of CCC applicable products, 2009 edition] (PDF) (in Japanese). Shibuya, Tokyo: JET:Japan Electrical Safety & Environment Technology Laboratories (電気安全環境研究所). p. 9/10. Archived from the original (PDF) on 2009-08-28. Retrieved 2009-09-18.
- "Protecting Intellectual Property Rights In China". Forbes. Retrieved 2015-07-20.
- "A Brief Guide to CCC: China Compulsory Certification", Julian Busch, ISBN 978-1484115534
- Full list of CCC applicable product, in Japanese 28 August 2009 Edition (In Japanese) web site of JET:Japan Electrical Safety & Environment Technology Laboratories (電気安全環境研究所)
- Foreign-made, intellectual and IT security, products procurement policy
- USTR Releases 2010 Special 301 Report on Intellectual Property Rights
- ABC NEWS - Geithner to Press China on Trade Barriers, Yuan 7th paragraph; "American companies are very concerned that this approach has the potential to discriminate against foreign-made products and could disadvantage American exporters and investors as they compete with Chinese firms," Geithner said. "We share these concerns." (May 18, 2010)
- Strategic and Economic Dialogue Closing Statement, Treasury Secretary Tim Geithner, Beijing, China As Prepared for Delivery on May 25, 2010 (United States Department of the Treasury)
- CQC website
- CNCA website