China Country Commercial Guide
Learn about the market conditions, opportunities, regulations, and business conditions in china, prepared by at U.S. Embassies worldwide by Commerce Department, State Department and other U.S. agencies’ professionals
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Standards for Trade
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Overview

The State Administration for Market Regulation (SAMR) is China’s central regulatory body for all activity related to developing and promulgating national standards and coordinating compulsory certification and testing, including the China Compulsory Certification (CCC) mark. SAMR was established in 2018 by merging several agencies, including the Standards Administration of China (SAC) and the China National Certification and Accreditation Administration (CNCA). SAMR continues to use the names of the SAC and CNCA in public-facing information and communication, including maintaining their respective websites, to denote the duties of these former agencies, although their respective responsibilities now fall under different subdivisions of SAMR. In recent years, regulatory enforcement actions—including anti-monopoly, cybersecurity, and so-called ‘industrial competitiveness’ investigations—have raised concerns among foreign businesses about the politicization of China’s regulatory environment.

Standards in the PRC fall into the following categories:  

Government-led standards 

  • National standards (also called GB standards): take precedence over other standards and are further subdivided into national mandatory standards (also called GB standards) and recommended national standards (also called GB/T standards)
  • Industry standards: recommended/voluntary standards developed by PRC ministries and other administrative departments of the State Council

Local standards 

  • Recommended/voluntary standards developed by provincial and other local governments for local adaptation purposes

Market-driven standards 

  • Association standards: also called group standards, these are developed by industry associations, chambers of commerce, and other organizations to address market and innovation needs
  • Enterprise standards: formulated individual companies for their own technical, management, and work requirements

A few standards-related trends are commonly applicable to exporters to the PRC. 

  • First, 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 the CCC safety and quality certification mark before selling in or importing into China. This process can take several months.  
  • 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. This often leads to onerous and duplicative testing requirements. 

Standards

As referenced above, the PRC employs a hybrid standards development system, including top-down government-led standards and bottom-up market driven standards. The top-down government-led standards take precedence over the market-driven standards. Mandatory national standards are considered the minimum requirements and take precedence over all other standards.  

Market-driven standards do not imply they are developed wholly by the private sector, as they often involve state-owned enterprises (SOEs) and government-sponsored industry associations. However, the technical committees (TCs) organized to develop all types of standards, to include national standards, generally include members from private industry associations, companies, and academia, in addition to government agencies. Chinese TCs often include foreign companies and organizations, including from the United States.  

TCs developing national (GB) standards must be accredited by SAMR. Chinese regulators regularly issue policies calling for standards which support national economic development. These policies often call for the drafting and revision of large numbers of standards. In some cases, these policies provide incentives for the development of certain categories of standards. The China Standards 2035 initiative exemplifies the government’s strategic approach to shaping domestic standards with the intent of promoting them globally, particularly in emerging technology sectors.

Under China’s revised Measures for the Administration of National Standards, which came into effect on March 1, 2023, certain registered industry alliances are also allowed to develop voluntary association standards.The intention is for these standards to be developed similarly to those in market-driven standards systems like the United States.  

Foreign companies are frequently unable to participate fully in the process for setting association standards, which disadvantages foreign companies compared to domestic firms. U.S. companies often are unable to participate in the standards setting process on an equal footing as local firms, even if they are members of the association. Moreover, the SAMR Interim Regulations for the Adoption of Association Standards and Recommended Standards, released in August 2023, creates a path for association standards to be adopted as national standards after two years of “good performance.” Therefore, U.S. firms worry that the current process for establishing association standards may result in the creation of recommended national standards, without an opportunity for them to provide input. These standards will then advance to international standards-setting bodies with the full support of China’s government and private industry, creating the risk that standards established to advance China’s domestic industry and strategic objectives will become global.

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. In August 2023, the State Council’s Opinions on Further Optimizing the Foreign Investment Environment and Increasing the Attraction of Foreign Investment specifically called for “Support[ing] foreign-invested enterprises in participating in standard formulation, promoting full-process information disclosure in standard formulation and revision, ensuring that foreign-invested enterprises participate in standardization technical committees and standard formulation work on an equal footing with domestic enterprises in accordance with the law, encourage foreign-invested enterprises to develop enterprise standards on their own or jointly with other enterprises, and provide standardization services.” However, foreign enterprise access to Chinese TCs been uneven. 

Product Certification

The China Compulsory Certification (CCC) mark is China’s national safety and quality mark. The mark is required for 96 types of products, ranging from electrical fuses to toaster ovens to automobile parts to information technology equipment. About 20 percent 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 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. Note that many companies report that Chinese government administrative procedures can require foreign companies to divulge trade secrets and other sensitive information without adequate justification or safeguards. At present, nine foreign testing organizations (UL Solutions, SGS China, TUV Rheinland, Intertek, DEKRA, VDE-CGC, CSA Group, DNV GL and Bureau Veritas) have been designated to test certain categories of products to CCC mark GB standards. However, these foreign organizations do not cover every item requiring a CCC mark, so depending on the product being exported companies may need to use a Chinese certification body. 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 application process varies depending on the product, but often includes 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, 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 China’s most widely required product certification mark, other product certification requirements exist such as the Network Access License for internet connected devices, Electromagnetic Compatibility certifications, and cybersecurity review requirements, among others. 

The China National Certification and Accreditation Administration announced that certain IT products and requiring a CCC mark and imported into free trade zones could comply through a self-declaration process, which will simplify the process and reduce compliance costs.  

Accreditation and Conformity Assessments 

SAMR is the primary government agency responsible for the supervision of China’s conformity assessment policies, including its primary safety and quality CCC mark. The China National Accreditation Service for Conformity Assessment (CNAS), which is directly affiliated with SAMR, 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. CNAS is also a member of the International Laboratory Accreditation Corporation (ILAC).  

Publication of Technical Regulations

The PRC is obligated to notify other World Trade Organization (WTO) members of proposed technical regulations that would significantly affect trade. Notifications are made through the Technical Barriers to Trade (TBT) Committee notification point.  

Under the WTO TBT Agreement, all WTO members, including China, are required to notify and allow for a reasonable amount of time to provide comments on proposed mandatory technical regulations and conformity assessment procedures that may have a significant impact on international trade. Historically, China’s use of notice-and-comment procedures has been unpredictable, sometimes providing only a few weeks for comment, as opposed to the TBT-recommended 60 days that is standard practice for many other WTO members.  

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 Members of the World Trade Organization (WTO) 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 is a versatile tool that can be used 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,
  • Receive customized e-mail alerts when new notifications are distributed,
  • Find information on trade concerns discussed in the WTO SPS and TBT Committees. 

Per obligation under the TBT Agreement, each WTO Member operates an 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 Enquiry Point. Refer to the comment guidance at https://www.nist.gov/notifyus/commenting for further information. This guidance is provided to assist U.S. stakeholders in the preparation and submission of comments in response to notifications of proposed foreign technical regulations and conformity assessment procedures.