A Practical Guide to Obtaining the CCC Mark for High-Tech Products

Kevin Ravo

The key to getting to market quickly in China is planning and preparation.

The high-tech product market in China has grown markedly in depth and breadth over the past decade. China is already home to Asia's largest information technology (IT) market outside of Japan. Industry experts also estimate that the Chinese mainland's IT market will surpass that of the United States by the year 2010.

Since China's Compulsory Product Certification System (CPCS) took effect August 1, 2003, many high-tech manufacturers are scrambling to put together a compliance plan for obtaining the China Compulsory Certification (CCC) mark. This article provides a practical and concise overview for the CCC-mark-related approvals process in China.

Please note that this information is accurate at the time this article was written, but that regulatory requirements such as these are subject to change. It is important, therefore, to check for the most current information when the company is actually ready to engage in the application process. It is critical to proceed using the most current information to increase the chances of successfully completing the process in a timely manner.

China's CPCS requires that products under the scope of this system must bear the CCC mark prior to entering the Chinese marketplace. The CCC mark is regulated by the China Certification and Accreditation Administration (CNCA).

A number of products that are covered by the scope of the CPCS are what may commonly be referred to as high-tech. High-tech products typically include consumer electronics, IT equipment, telecommunications equipment, and medical equipment. Most of these high-tech products are covered to some extent in the scope of the CPCS. For a complete listing of all products covered by the CPCS, go to http://www. cqc.com.cn/ccc/catalogureeng.pdf.

A previous article provides complete information regarding the incredible market opportunity in China and the history and background of the CCC mark.1 That article focused primarily on telecom approvals, whereas this article will address the CCC mark approvals process for all high-tech-related products. The requirements and processes for the various high-tech product segments are similar. Various regulatory requirements exist for the four product types indicated above that make up high-tech products. The three major regulatory or conformity requirement types that must be considered for China (and indeed most countries) include safety, electromagnetic compatibility (EMC), and terminal attachment.

Table I provides an overview of the related standards and requirements in each of these areas for the four product types. Please note that the table contains only limited information to provide an overview of the related requirements for the most common types of products. Table II provides a collected listing of these organizations and information for easy future reference. Additional information, including a site for accessing the implementation rules, can be found on the Web site links in Table III. The indicated sites provide a wealth of information and are relatively up-to-date with information about the CCC mark requirements and related processes.

Table II. Key organizations.

The process for obtaining the CCC mark is not unlike the regulatory process in many countries. Figure 1 provides a high-level view of the process for obtaining the CCC mark and then maintaining it. Follow-up is required in addition to the initial type testing. This is a simplified view of the overall process. As with many approvals processes, the devil is in the details. For this procedure, those details include the requirement to submit nearly all documentation in Chinese. The submission process can be frustrating and may take 60 to 90 days or longer to complete, particularly for companies that are not well prepared. There are ways to speed up the overall process. The most notable is to start planning early and be prepared once the product is ready for submission.
 

Table III. Useful Web sites.

Planning and Preparation

As with all market acceptance issues, success in obtaining the CCC mark is deeply rooted in thorough planning and preparation. It is never too early in the product development cycle to begin considering these issues. Even at the design phase, various requirements must be considered to identify the path for approaching the relevant local authorities and determining necessary tests and so on. Project management of the conformity-assessment-related market access issues is therefore critical. Management of the compliance process can be fully integrated into the product team's scope, specifically contracted out to another group within the organization, or outsourced completely to a third party.

The key is to involve the relevant regulatory or conformity expert resources early in the product development process so issues can be addressed during the design phase. Remember, there are at least three typical regulations that need to be addressed, including safety, EMC and terminal attachment.

Figure 1. CCC mark process flow.

Changes to the product, even apparently simple ones, could create a need to retest one or all of the regulatory areas. Including the relevant regulatory considerations up front minimizes changes later and saves both time and money. Mapping out the overall process (including the order of testing, test samples available, etc.) for addressing all regulatory requirements allows for obtaining the necessary certifications and approvals in the most effective and cost-efficient fashion.

CB Scheme

The flow chart in Figure 1 indicates an option to use a CB certificate in lieu of in-country testing. The CB Scheme, established by the International Electrotechnical Committee for Conformity Testing to Standards for Electrical Equipment (IECEE), is a very successful international data exchange program for test data related to safety requirements. It is based on a common standard for each product type and allows for one set of tests to be conducted by one national certification body. These tests may then be accepted by certification bodies in other countries for the purpose of issuing the local certification without the need for additional testing.

The CB Scheme is a useful tool for the CCC mark approvals process. Without it, in-country testing is required that can add considerable cost and time to the approval of the product. The CB certificate is not only useful for obtaining the CCC mark, but it can serve as a passport to the certifications for many other markets. It is important to note that the CB Scheme is applicable only to safety certification at this time. EMC requirements are not covered by the CB Scheme, and, in the case of the CCC mark, in-country EMC testing is required.

Conclusion

Much information is available about the CCC mark and China's product certification system. The requirements and process will certainly continue to change, so it is important to know the current requirements at the start of the process. Some companies work through the process on their own, whereas others opt to use third-party organizations. The key is to develop a plan so that the process can be navigated with the least effort, cost, and time. With careful project management and the use of the CB Scheme, the certification process can be completed in as little as 30 days. An unorganized approach can triple the time needed.

References

1. L Bai, "China: The Final Frontier in Telecom Approvals," Compliance Engineering 20, no. 3 (2003): 119-125.
 
Kevin Ravo, PE, is general manager for the ITE and telecom strategic business units at Underwriters Laboratories (Northbrook, IL). He has been involved in a broad range of conformity-assessment-related activities for more than 27 years. Ravo can be reached at kevin.l.ravo@us.ul.com.