China Standards for Trade
China’s market of 1.4 billion consumers offers opportunities for U.S. companies. There are national and other standards, such as the CCC mark, that may apply to products sold in the country.
The Standardization Administration of China (SAC) is the central body for all activity related to developing and promulgating national standards in China. The China National Certification and Accreditation Administration (CNCA) coordinates compulsory certification and testing, including the China Compulsory Certification (CCC) mark.
Standards in China 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 common standards-related trends are commonly applicable to exporters to China.
- It is important to note that laws and regulations can reference voluntary standards, thereby making the voluntary standard effectively mandatory.
- For certain products, such as some electrical products, information technology products, consumer appliances, fire safety equipment and auto parts, China requires that a safety and quality certification mark (the aforementioned CCC mark) be obtained by a manufacturer before selling in or importing to China. This process can take some time.
- Numerous government agencies in China 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.
China 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, along with subsequent implementing measures, defines 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, and often calling for drafting and revision of large numbers of standards; in some cases, these policies provide incentives for development of certain categories of standards.
Under recent reforms to China’ standardization process, 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 about potential mechanisms for association standards to become national standards. A common concern among U.S. businesses operating in China is the inability to participate on an equal basis as local stakeholders in standards setting processes.
Recently issued policies, including China’s 2019 Foreign Investment Law, state that foreign-invested enterprises should be able to participate on an equal basis with local firms in standardization processes, but in many industries, foreign companies do not enjoy equal treatment in practice.
Testing, Inspection & Certification
The China National Certification and Accreditation Administration (CNCA) is the primary government agency responsible for 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.
The China Compulsory Certification (CCC) mark is China’s national safety and quality mark. The mark is required for 17 categories of 103 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 catalogues to determine if your product requires a CCC mark. Additionally, the U.S. Department of Commerce maintains a comprehensive CCC mark website to help U.S. exporters determine whether they need the CCC mark and how to apply. If an exporter’s product is on the CCC mark list, it cannot enter China 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 China and with a dedicated certification/standards staff, are able to manage the application process in-house. Other exporters can tap the expertise of 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 China’s most widely required product certification mark, other product certification requirements exist.
The China National Accreditation Service for Conformity Assessment (CNAS) is the national accreditation body of China 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.
Publication of Technical Regulations
China 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 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.