Electrical and R&TT products accessing the market of China are subject to:

• CCC (China Compulsory Certificate) Certification. The CCC mark is Chinese national safety and quality mark.  
• SRRC (State Radio Regulation Committee) Certification. Type approval for radio communications equipment and wireless products.  
• NAL (Network Access License) Licensing. Approval of all telecom equipment with access to public networks;  
• CEL (China Energy Label) Labeling. Proof of energy efficiency registration through the CELC (China Energy Label Center) for household products, ITE, lamps, etc.;  
• China RoHS 2 (Restriction of Hazardous Substances). Self-declaration label for electrical and electronic products.

Telecom approval

The Ministry of Industry and Information Technology of the People’s Republic of China (MIIT) is mainly responsible for the development and revision of standards in the areas of electronics and communications. The MIIT is also responsible for NAL approval.

There are two types of mandatory approvals in China:

• NAL — Network Access License approval  
• SRRC — Radio type approval

The SRRC certification is mandatory for wireless products only while NAL applies to any telecommunication equipment that is connected to a public telecommunication network whether it is wireless or non-wireless.

Network Access License (NAL) approval is mandatory for all telecommunications equipment covered by the NAL product categories announced by the MIIT. The MIIT’s “NAL Certification Centre” is the only authorised certification organisation.

The scope of China NAL approval includes 3 categories of equipment:

• Equipment used in network interconnection (such as: routers, access network equipment, IP gateways and gatekeepers, etc.)  
• Wireless communications equipment (such as: base stations, microwave communications equipment, etc.)      
• Telecommunications terminal equipment (such as: fixed telephones, mobile terminals, fax machines, etc.)

If a device includes RF function, it is required to obtain SRRC certification and then the NAL license. Apart from the NALicense, some telecommunications equipment also needs a CCC certification. However, the NALicense should be obrained before.

Each type of the approved product will receive a Network Access Identifier (NAI) with the certification number.

Certified products must be marked with the NAL label.

The State Radio Regulatory Commission (SRRC) is a certification body responsible for issuing the mandatory SRRC certificate.

There is no special product category for SRRC, all types of products (for domestic sale or using radio components and products) must be SRRC-approved if they have a radio transmitter function, Wi-Fi, Bluetooth, etc.

The testing must be conducted on the territory of China in a laboratory accredited by the MIIT and the State Radio Monitoring and Testing Center (SRTC).

Note that beside the SRRC approval some radio emission products also fall under the scope of the CCC certification and/or NAL approval.

Energy Efficiency approval

China’s energy efficiency labeling management system, also known as the China Energy Label (CEL) is an energy consumption label for products manufactured and imported into China. Manufacturers of specified electronic devices are obligated to attach the CEL label to their goods. This helps to inform Chinese consumers about the product’s energy efficiency. The label includes the product’s energy efficiency class (1-5) as well as information regarding its energy consumption.

The CEL programme establishes a mandatory requirement for manufacturers and importers to complete the CEL registration process with CELC and label products from CEL Catalogue before selling or importing products in the country. Mandatory labelling is required for certain products.

Anyway, along with the CEL, the Chinese government establishes the energy efficiency standards that sets us mandatory energy minimum standards for products to regulate the nation’s energy consumption. Minimum Energy Performance Standards (MEPS) are required for many products.

The China Energy Label Center (CELC) is responsible for developing the CEL Catalogue and managing the label registration system. The CELC is under control of the National Development and Reform Commission (NDRC), the General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) and the Certification and Accreditation Administration (CNCA).

Currently, the following product categories require CEL:

• Air conditioners  
• Air compressors  
• Motors  
• Washing machines  
• Refrigerators  
• Gas kettles  
• Flat-screen TVs  
• Photocopiers  
• Computer monitors  
• Copiers  
• Domestic cookers  
• Fans  
• Lamps  
• Power transformers  
• Water heaters, etc.

Safety Approval

The China Compulsory Certification (or CCC) is a systematic, independent product certification system responsible for safety and EMC issues and China’s national safety and quality mark.

The CCC Mark is a compulsory safety mark that must be affixed before products can be imported and sold in China.

The CCC certification system is mainly based on National Chinese Standards (GB-Standards) for products listed in the Catalogue of Products subject to Compulsory Certification. Each category of products has its own implementation rules. The rules indicate product scope, application method, required documents, testing factory inspection, and mark requirements.

The CCC scheme consists of:

• a certificate issued by a certification body appointed by the China government — in most cases the China Quality Centre (CQC).  
• a mark to be placed either on the product itself, its packaging or both.

Any product mentioned in the CCC Catalogue must comply with foregoing requirements of CCC scheme.

The Certification and Accreditation Administration (CNCA), under AQSIQ, is a regulatory body that manages both a voluntary certification system and a compulsory product certification system. The CCC Catalogue of CCC mandatory products is approved and released jointly by AQSIQ and the CNCA.

The China Quality Certification Centre (CQC) is a national certification body of China that responsible for administering the CCC mark. The CCC Certification is issued by the CQC including both safety and EMC testing for most of products.

The CCC Catalogue covers:

• Audio and video equipment;  
• Electrical wires and cables                
• Household and similar use appliances  
• Lighting  
• Low-voltage electrical apparatus  
• Telecommunication terminal equipment, etc.

The complete CCC certification process includes 7 steps:

1. application  
2. product testing  
3. initial factory inspection  
4. obtaining the CCC certificate  
5. marking (CCC mark is affixed to the product)  
6. annual follow-up factory inspection  
7. market surveillance

For some product categories, there is a specific certification mode called “the Self-Declaration Assessment Mode”. Manufacturers of such products can choose between two different certification modes in future: between the common CCC Certification Scheme and the Self-Declaration Assessment Mode.

The self-declaration procedure is governed by CNCA-00C-008: 2018 and includes two types of the declaration scheme:

• Type “A” (scheme allows choosing any laboratory for testing)  
• Type “B” (scheme requires to use only the laboratory accredited by the CNAS)

The following products can be subject to the self-declaration procedure:

• Low-voltage switchgears (type B)  
• Low power motors (type B);  
• Information technology equipment, audio- and video equipment with a nominal rated voltage equal to or less than 5V (Type A), etc.

Apart from the CCC certification, some products may need to meet other requirements and obtain other types of approval. EMC compliance is required where applicable.

The CCC mark takes the form of a physical sticker that is applied to individual products as a label. According to the Chinese regulations, a manufacturer has the right to choose a marking method. However, limitations or specific marking requirements may be applied to specific product groups.

Starting from March 20, 2018, the CNCA no longer needs to approve the application of the CCC mark and manufacturers are able to print and use the CCC mark without the CNCA’s permission based on the CACA regulations. However, this doesn't allow manufacturers to apply the CCC logo to products that don't complete the certification.

RoHS Approval

The China Restriction of Hazardous Substances (RoHS)’ was issued on July 1, 2016. It is a mandatory regulation for electronic and electronic products intended for manufacture, sale or import in the People’s Republic of China (except Hong Kong, Macau, and Taiwan).

According to the Regulation, electrical and electronic products are devices and accessory products with rated working electrical voltages that do not exceed 1500V direct current and do not exceed 1000V alternating current and function by means of current or electromagnetic fields and generate, transmit and measure such currents and electromagnetic fields. Batteries are also within the scope.

According to the Announcement № 15, the first batch of China RoHS 2 Compliance Catalogue contains the following product types that are subject to substance restrictions:

• Refrigerators (up to 800 litres)  
• Air conditioners (≤ 14,000 watts)  
• Washing machines (≤ 10 kg of dry clothes)  
• Electric water heaters  
• Printers (≤ A3, ≤ 60 pages / minute)  
• Copiers (≤ A3, ≤ 60 pages / minute)  
• Fax machines  
• Televisions  
• Monitors  
• Microcomputers (desktop with necessary peripherals, laptops, tablets)  
• Mobile communication devices  
• Telephones

The MIIT also set an exemption list, providing 39 exemptions on uses of the foregoing restricted substances in electrical and electronic products, such as fluorescent and incandescent lamps, heating, ventilation, air conditioning, and refrigeration equipment (HVACR), etc. Only one exemption is time-limited. The one for mercury in high-pressure vapour lamps (HPMV), which is set to expire on December 31, 2020.

Products listed in the Catalogue are subject to mandatory compliance with hazardous substance restriction limits.

China RoHS 2 restricts the use of the following six hazardous substances in electrical equipment (concentration limits):

• Lead (Pb) and its compounds (0,1%)  
• Mercury and its compounds (0,1%)  
• Cadmium (Cd) and its compounds (0,01%)  
• Hexavalent chromium (Cr6+) and its compounds (0,01%)  
• Polybrominated biphenyls (PBB) (0,01%)  
• Polybrominated diphenyl ethers (PBDE) (0,01%)

The "Conformity assessment system" has not been established yet but it will be defined by the government. For now, in phase one, where disclosure is all that is required, it is necessary to determine which hazardous substances are in the product. In phase two, where substance restriction becomes a requirement for products covered in the catalog, testing may be required. This is the next anticipated phase in the development of China RoHS 2 and will complete its evolution.

Requirements for the RoHS labelling

China RoHS 2 requires that all electronic and electrical products that are sold in the People’s Republic of China are marked with one of the two logos. The logo depends on whether a product contains any hazardous substances exceeding official concentration limits.

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A label defines whether or not the products contain any of the six hazardous substances. If they are present, the "Environment Protection Use Period" (EFUP) must also be determined and marked. The Date of manufacture must be marked on the product if the EFUP label is required.

SJ/T 11364-2014 “Marking for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Product” specifies detailed marking requirements for hazardous substances in electronic and electrical products, the environmental protection use period, and recyclability.

Once China RoHS 2 wil become effective, SJ/T 11364-2014 will come into force as well.

The full text of the Act you can find here.

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The information has been prepared by the GMA Consult Group team. ‍

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