Key Product Regulatory Developments in China January to June 2018 – Your Questions Answered

Compliance & Risks recently hosted a webinar on Key Product Regulatory Developments in China January to June 2018. 

During the webinar we encouraged attendees to submit questions. Below is a list of the some of the more common queries we received, along with answers supplied by Amy Chen, Regulatory Compliance Specialist at Compliance & Risks.

What is the meaning of CCC?

CCC stands for China Compulsory Certification. It is a mandatory certification system in China. Products listed in the CCC catalogue must comply with the Implementation rules issued by the Certification and Accreditation Administration of China (CNCA). Products have to be tested, certified, and have the CCC mark affixed to them before they can be placed on the Chinese market.

Are the changes on compulsory certification and self-declaration applicable already? Can you provide further information on self-declaration?

The requirement on self-declaration will take effect on 1 October 2018.

The implementation measures on self-declaration are attached to Announcement No.11 on Reform of Compulsory Certification Product List and the Implementation Measures which sets out the procedure and all requirements on self-declaration.

Self-declaration is an alternative method to compulsory certification. Instead of choosing a qualified institution to handle the test and certification, companies may use their own lab for testing, and then submit the testing report and conformity report. The product will then be granted the certificate and the right to use the CCC mark as if it had been certified by qualified institution. All details are contained in the Implementation measures.

Do the new Mandatory National Standards on Product Energy Efficiency supersede any previous Minimum Energy Efficiency requirements such as those relating to fans with blades over 20mm have a MEP limit?

None of the new standards repeal or supersede previous standards or requirements set out in other minimum energy efficiency standards.

Would China push back the implementation date for the Catalogue and Exemption List (CEL) if the rules concerning conformity procedure are not finalized by March 2019?

According to Article 18 of China RoHS 2, products listed in the China RoHS 2 (Restriction of Hazardous Substances) Catalogue are subject to conformity assessment. China’s Certification and Accreditation Administration is responsible for the drafting and issuance of the implementation rules on the conformity assessment system. The Ministry of Industry and Information Technology (MIIT) is responsible for supervision and for offering suggestions on the system.

The drafts were reviewed and discussed on the Electronic Standardization Institution meeting last year and we would expect them to be made available to the public in the near future.

It cannot be said for certain whether China would push back the implementation date. However, there is precedent on this being done – the enforcement date for RoHS labelling standard SJ/T 11364-2014 was pushed back, whilst the China RoHS 2 draft regulation was being finalized. Therefore, it is certainly possible that the implementation will be postponed if the key legislations are not finalized by March 2019.

How would the exemption list apply?

According to the Announcement publishing the Catalogue and Exemption List, only the products listed in the catalogue are subject to compliance restrictions and conformity assessment. Use of the hazardous chemicals contained in the exemption list are not subject to the restriction sets out in national and industrial standard.

However, in the absence of the Implementation Rules on Conformity Assessment and the Regulations on Company Declaration, it is not yet clear how the conformity assessment system will work and how the exemptions would apply in terms of conformity assessment.

Can you please provide further details on the CEL regulation for desktop computers?

The energy labelling requirements on desktop computers are set out in Energy Efficiency Labelling Rules for Microcomputers CEL 027.

The Rules CEL 027 Implements the energy efficiency labelling management approach. Both the energy performance and calculation set out in the Rules CEL 027 are based on the currently valid edition of Standard GB 28380. The Rules further specify requirements for the following:

•     Label format and specifications
•     Energy efficiency testing methods
•     Conformity of label contents
•     Printing, application and display of energy efficiency labels
•     Label records
•     Announcement of the labels

The rules and a detailed summary are available to download in C2P, the compliance knowledge management platform.

Are toys covered by changes to the CCC system?

Announcement No. 10 on the Reform of Application and Issuance of CCC Marks applies to all products subject to compulsory certification, and therefore also applies to toys.

Announcement No. 11 on the Reform of Compulsory Certification Product List and Implementation Measures only applies to products listed in Annex 1 and Annex 2. Toys are not listed in either Annex.

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