China’s State Administration for Market Regulation (SAMR) and Certification & Accreditation Administration of the People’s Republic of China (CNCA) have published an important announcement regarding the reformation and adjustment of current implementation rules for China CCC Scheme for automotive components. This published announcement includes two Annexes relating to certification of automotive components.
- As of June 16, 2018, products under Annex 1 no longer fall under the CCC scheme but can be transitioned to CQC or CCAP voluntary certification scheme.
- In addition, after October 1, 2018, products under Annex 2 will have a new route to conformity under the Supplier Declaration of Conformity (SDoC) scheme to comply with CCC certification. Alternatively, manufacturers can still elect to keep their current CCC certification process for Annex 2 products.
- Automotive components currently under the CCC certification scheme that are not listed in Annex 1 or 2 will not be affected and will continue with the established CCC certification process without change.
The following automotive components are affected under Annex 1 or 2:
- Horn – Annex 1
- Brake hoses – Annex 1
- Fuel tanks – Annex 1
- Vehicle theft alarm system – Annex 1
- Interior trim – Annex 2
- Door locks & retainers/hinges – Annex 2
As of June 16, 2018, Automotive components under Annex 1 now fall outside of CCC certification scheme and are no longer allowed to be marked CCC. Although CCC certification is no longer possible, testing of these components will still be required either as part of the voluntary certification scheme, or as part of vehicle certification testing. It is recommended that component manufacturers under Annex 1 transition to CQC or CCAP voluntary certification for the following reasons:
- Certified components will not require additional testing during vehicle certification
- Minimize potential supply chain issues due to China local market surveillance
- Competitive market advantage to have components certified for certain provinces in China
The switch from CCC to CQC or CCAP certification can be performed without any additional testing or agency cost. The transition is simply a documentation process. Please contact us for more information, or to begin pursuing this transition.
As stated, automotive components under Annex 2 will still require mandatory CCC certification but will now have an option to choose the Supplier Declaration of Conformity (SDoC) scheme or keep the current CCC certification scheme. The new scheme will limit the certification body’s role in the certification process, mainly by eliminating mandatory annual factory inspections. The Supplier self-certification process includes the following conditions:
- Application for certification must be submitted to a designated government body (to be determined)
- Initial product testing must be conducted in China by a CCC accredited laboratory
- Modifications or addition of parts need to be approved by a designated government body (to be determined)
- Annual reporting/self factory inspection report must be submitted to a designated government body (to be determined)
The information currently provided by Chinese government authorities regarding the implementation of SDoC scheme and the transition details are still evolving. We expect to have more details by October 2018. For now, manufacturers under Annex 2 list must follow the current CCC certification process, but manufacturer’s producing Annex 1 type components can start pursuing a transition to the voluntary certification scheme today.
For additional information, please contact G&M Compliance, Inc. at 714-628-1020