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What is the CCC Self Declaration?
The Certification and Accreditation Administration of China (CNCA) established the CCC Self Declaration process as the only certification process for specific products compared to the traditional CCC certification process.
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The CCC Self-Declaration (also called China Self-Declaration, Declaration of Compliance (DoC), Self-Declaration of Compulsory Product Certification/ Self-Declaration of Certification or more prominently the China Supplier Declaration of Conformity (SDoC)), serves as a declaration by the manufacturer, that the manufactured products comply with the Chinese standards and that product conformity is continuously maintained in accordance with Chinese regulations. The CCC certification, which can be achieved by means of a CCC SDoC for selected product groups, is mandatory for products that are imported to or sold on the Chinese market.
Here is a brief video about the CCC Self-Declaration, presented by Julian Busch, director of
MPR China Certification GmbH / China Certification Corporation:
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In order to be allowed to go through this process of China Compulsory Certification Self-Declaration, the applicant must be a Chinese company with a Chinese contact person in China. The applicant may only be a subsidiary or the dealer/importer of the manufacturer.
We can offer customers without a company in China the placement of a CCC applicant service to overcome this hurdle.
A Chinese cooperation partner acts as the applicant for the CCC Self-Declaration and will upload the necessary documents into the CNCA database. All your manufacturing facilities can be registered for the CCC Self-Declaration via this applicant.
You can find more information on this service here.
The manufacturer’s CCC declaration resembles a streamlined form of conventional CCC certification, but is associated with considerably higher risks for manufacturers and applicants.
The CCC SDoC is subject to the general CNCA implementation rule CNCA-00C-008: 2018. However, the respective CNCA implementation regulations for the individual component categories remain valid and must be observed by the manufacturers.
For which products does the CCC Self-Declaration/ Supplier Declaration of Conformity SdoC apply?
Here you will find a list of the products announced by CNCA which must carry out a China SdoC as of 17 October, 2019. Until 31st December, 2019 it is still possible to also perform the traditional certification process with CQC or CCAP.
Please find also our latest news dated October 18th, 2019 about that topic here.
Here is a brief video about the CNCA announcement no. 44 for manufacturers that are affected by the CCC Self-Declaration, presented by Julian Busch,
director of MPR China Certification GmbH / China Certification Corporation:
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(Unofficial translation):
| Number | Name of product | CNCA Implementation Rules | Procedure A/B | Remark | |
| Product category | Sub product category and code | ||||
| 1 | Electrical tools | Electric drill（0501） | CNCA-C05-01:2014 | Self-declaration procedure A (Type test in optional laboratory + self-declaration) | Newly added |
| 2 | Electric grinder（0503） | Newly added | |||
| 3 | Electric hammer（0506） | Newly added | |||
| 4 | Electric welder | DC arc welder（0603） | CNCA-C06-01:2014 | ||
| 5 | TIG arc welder（0604） | ||||
| 6 | MIG/MAG arc welder（0605） | ||||
| 7 | Plasma arc cutting machine (0607） | ||||
| 8 | Circuit switch and electrical device for protection or connection | Thermal fuses（0205） | CNCA-C02-01:2014 | Self-declaration procedure B (Type test in designated laboratory + self-declaration) | Newly added |
| 9 | Cartridge fuse-links of miniature fuses（0207） | Newly added | |||
| 10 | low-voltage apparatus | Leakage protector （0306） | CNCA-C03-02:2014 | Newly added | |
| 11 | Circuit breaker（0307） | Newly added | |||
| 12 | Fuse（0308） | Newly added | |||
| 13 | Low-voltage switchgear (disconnectors, switch-disconnectors and fuse-combination units)0302） | Newly added | |||
| 14 | Other circuit protection devices（0304, 0307, 0309） | Newly added | |||
| 15 | Relay（0303） | Newly added | |||
| 16 | Other switches（0305） | Newly added | |||
| 17 | Other device（0304, 0305） | Newly added | |||
| 18 | low-voltage switchgear assemblies （0301） | CNCA-C03-01:2014 | |||
| 19 | Low power motor | Low power motor （0401） | CNCA-C04-01:2014 | ||
| 20 | Equipment for Household and similar uses | Motor-compressor（0704） | |||
| 21 | Motor vehicle and safety accessories | Car seat belt （1104） | CNCA-C11-04:2014 | Newly added | |
| 22 | Motor vehicle exterior lighting and light signal devices （1109, 1116） | CNCA-C11-07:2014 CNCA-02C-065:2005 | Newly added | ||
| 23 | Car seat and seat headrest (1114） | CNCA-C11-12:2014 | Newly added | ||
| 24 | Motor vehicle indirect vision device （1110, 1115） | CNCA-C11-08:2014 CNCA-02C-064:2005 | |||
| 25 | Car drive recorder （1117） | CNCA-C11-14:2014 | |||
| 26 | Car reflecting marking（1118） | CNCA-C11-13:2014 | |||
| 27 | Safety glass | Car safety glass （1301） | CNCA-C13-01:2014 | Newly added | |
| Information technology equipment, Audio and video equipment | Equipment with rated voltage less than or equal to 5VDC, rated power consumption less than 15W (or 15VA) and no rechargeable battery (class III equipment) | CNCA-C09-01:2014 CNCA-C08-01:2014 | Self-declaration procedure A (Type test in optional laboratory + self-declaration) | ||
Procedure:
Below you can find a simplified overview of the process for the China SDoC.
Before starting the process of the China Compulsory Certificate Self-Declaration, there should always be an internal audit of the quality management system carried out to check whether it continuously meets the requirements of CCC certification with regard to product conformity (CoP: Conformity of Production) to the Chinese GB standards and regulations (CNCA Implementation Rules).
We offer to support you in carrying out such an audit. Please feel free contact us.
Overview of the CCC Self-Declaration/ SDoC procedure:
- Preparation of the application documents for the CCC Self Declaration and conduct of an internal audit
- Contact with the test lab to identify the test samples needed
- Customs clearance procedure of the test products in China and execution of the tests (usually in a CNAS accredited test laboratory in China. The requirements result from the mentioned above type of self-declaration: A or B)
- After completion of the tests: Selection of test reports in the online system and providing additional application documents to the online system
- After checking of the documents, the CNCA will issue the CCC Self Declaration Certificate
- The CCC Self-Declaration Certificate must be signed and stamped by the applicant and uploaded to the online system
- Marking of the products with the CCC logo
The CCC China Self-Declaration process is largely the same as the regular CCC certification process. Instead of the application being submitted to the Chinese certification authorities such as CQC or CCAP, the application has to be done in the CCC Self Declaration system of the CNCA authority by the contact person of the applicant. The most important difference in the process is that no factory inspection is required. Instead, the manufacturer must autonomously enter all the necessary information into an online system and continuously monitor the information and conformity by himself. In addition, the CNCA does not carry out any checks on the correctness of the application documents.
We recommend to stick to the established process with the annual audit by obtaining a voluntary certification in addition to obtaining the Supplier Declaration of Conformity. Going through an annual audit may seem to be more complex and time-consuming, but it gives you and your customers more security since the audit and the process are organized and approved by the Chinese certification authority.
Product testing is still mandatory, but is now divided into Type A and Type B:
Self-declaration for Type A products (see table above): Product tests in chosen laboratories*1 + self-declaration
*1: internal/ third party laboratory with ISO 17025 certification
Self-declaration for Type B products (see table above): Product testing in specified laboratories*2 + self-declaration
*2: Test laboratories with CCC authorization/ accredited by the Chinese authority CNAS
Marking of the products:
If the tests have been completed successfully and the test reports have been uploaded to the online system together with the other application documents, the application will be processed by the CNCA.
If all application documents are formally in order as well as the test report, the CNCA issues the CCC Self-Declaration using the online system.
The manufacturer can then affix the CCC logo to the certified products.
Further information and risks:
For the entire period of the validity of the China SDoC (10 years), the manufacturer must ensure ongoing conformity to the Chinese standards (CoP: Conformity of Production) on his own responsibility. This applies in particular to the test standards (GB standards) and the CNCA implementation rules.
Product conformity must be ensured by annual product tests according to the Chinese GB standard.
In addition, the quality management system must be continuously monitored by internal audits.
It should be noted that the degree of responsibility and liability of the manufacturer and the applicant for this new process is increased compared to the regular CCC certification processes which includes annual factory audits.
Possible reasons for non-conformities could be: Implementation of a material change without prior approval by CNCA, incorrect marking, incorrect unit classification during application, adjustment of the production process without approval, relocation of the production without approval, etc.
Due to the nature of the Self Declaration of Certificate, significantly higher penalties and sanctions are to be expected in the event of deviations.
It is to be expected that the Chinese authorities will intensify their checks on the import of products and on vehicles themselves (harbor check). In addition, control-checks can also take place on the Chinese market, e.g. on the sale of components.
Therefore possible changes to the standards and regulations (GB standards and CNCA implementation rules) by the authorities must continuously be taken into account.
The company’s ownchange managementsystem must also be particularly reliable, as every change to the product and numerous types of changes regarding the factory must be approved in advance by the CNCA.
The homologation of the entire vehicle can be particularly troublesome here, as the conformity of production (CoP) of the components to the GB standards must always be ensured by the vehicle manufacturer. The self-declaration CCC alone cannot guarantee this due to lack of audits, so that the risk of the car manufacturer is increased.
Maintaining the current certification process in cooperation with the Chinese certification authorities as part of the voluntary certification is, in our view, a safer and more risk-averse approach for automotive suppliers and car manufacturers. The CCC Self Declaration alone does not ensure oversight of the conformity of production and could lead to problems.
Of course, there are also other ways to ensure conformity of production. The manufacturer can for example perform internal audits in addition to internal testing. We can also support with professional audits and annual tests.
The integration of companies in China into the social credit system introduced in 2014 also includes risks due to reduced social rating scores if violations of Chinese regulations occur. The applicant for the China Supplier Declaration of Conformity must be a Chinese company (subsidiary or importer/dealer of the manufacturer). This company must submit its certificate of the social credit system when applying for the China CCC Self Declaration. The applicant’s rating is therefore at risk should there be non-conformities with the products. Serious violations can lead to the withdrawal of the business license.
Our service package:
For optimal support, MPR China Certification GmbH/ China Certification Corporation offers you a complete package for the CCC Self Declaration process. You will receive an individual contact person who is available to answer all your questions at any time.
We understand that the China CCC Self Declaration can be a complex hurdle. We are here to see you through.
Our service package:
- Clarification of the CCC certification obligation for your products
- Full preparation for the application process (consulting on prudent completion of all forms, communication with the certification authority, payment of fees in China)
- Full handling of product tests (customs clearance, document/payment transactions, communication, evaluation of Chinese test reports)
- Consulting on printing-specifications for marks, provision of templates for CCC-specific procedural instructions for marking products with the CCC logo
- Conducting internal audits
- Support for complete monitoring of product-conformity (annual tests and annual internal audits)
We also offer support in revising the quality documents and procedures required for the China Compulsory Certification.
If you do not have a company in China that can act as an applicant, we can assist you with our company foundation package. Hereyou can find more information.
Of course we also offer support for the voluntary CQC mark certification and CCAP mark certification. Here you can download our brochure about the voluntary CQC and CCAP certification.
You can download hereour detailed brochure about the CCC Self Declaration.
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Like to many other ongoing customers, China Certification is offering you outstanding support and expertise for your CCC Certification. We stand for first-class performance, transparency and traceability at all times. Call us today at +49-69-2713769150 or send us an Email.
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