1、 What is mandatory product certification
Compulsory product certification, also known as CCC certification, is a product evaluation system implemented in accordance with laws and regulations to protect national security, human health or safety, animal and plant life or health, and the environment. It requires that products must comply with national standards and relevant technical specifications, and mandatory testing and factory inspection shall be carried out for products listed in the catalog by formulating the product catalog for mandatory product certification and the implementation rules for mandatory product certification.
All products listed in the compulsory product certification catalogue shall not be allowed to leave the factory, sell, import or be used in other business activities without obtaining the certification certificate issued by the designated certification authority and without adding certification marks as required.
In accordance with the provisions of the Law of the People's Republic of China on Import and Export Commodity Inspection and the Provisions on the Administration of Compulsory Product Certification, the customs shall implement the administration of entry verification for the imported products listed in the catalog, check the certification certificates, certification marks and other supporting documents, and check whether the certificates are consistent. If the products fail to pass the verification, they shall be dealt with in accordance with relevant laws and regulations, and the imported products listed in the catalog shall be subject to subsequent supervision.
2、 Convenient Measures for Bonded Processing Enterprises to Import the Commodities in the Catalogue of Compulsory Certification Products
For bonded processing enterprises that import parts and components by processing with imported materials or supplied materials for the purpose of full export of complete machines, China has formulated preferential and convenient policies for exemption from compulsory certification if the parts and components are included in the compulsory certification product catalog because their products are not sold in the domestic market. The enterprise can obtain the Certificate of Exemption from Compulsory Product Certification (hereinafter referred to as the Certificate of Exemption) upon application approval.
Relevant laws and regulations
Article 3 and Article 5 of the Announcement of the General Administration of Market Supervision and the General Administration of Customs on the Arrangement of Exemption from Compulsory Product Certification (Announcement [2019] No. 13):
From April 1, 2019, the market supervision department will undertake the work related to the exemption of compulsory product certification.
For imported goods that fall within the supervision scope of compulsory product certification and meet the relevant conditions for exemption from compulsory product certification, the applicant shall obtain the certificate of exemption from compulsory product certification before handling customs declaration.
The Notice of the State Administration of Market Supervision on Clarifying the Requirements for Exemption from Compulsory Product Certification (GSJZH [2019] No. 153) stipulates that the conditions for exemption from CCC are met:
（1） Products and samples required for scientific research, testing and certification testing. The term "scientific research" as mentioned in this paragraph refers to scientific research on the product to develop and produce products needed for related products, not to scientific research equipment needed for research; The test referred to in this paragraph refers to the product that is necessary for testing the product to obtain test data, or testing part of the performance of a product (for example, developing and testing a certain model of printer software requires importing a small number of printers of that model); The certification test mentioned in this paragraph refers to the samples of type test conducted by CCC certification.
（2） Parts/products directly required for end user maintenance.
（3） Equipment/parts (excluding office supplies) required for the factory production line/complete production line.
（4） Products for commercial display only but not for sale.
（5） Parts imported for the purpose of exporting the whole machine.
（6） Other circumstances where compulsory product certification is exempted for special purposes.
3、 Common misunderstandings of bonded processing enterprises
It is common for bonded processing enterprises to sell imported parts and components domestically, and they will generally go through the formalities of taxation for domestic sales according to regulations. However, some enterprises have misconceptions about the understanding of the parts and components products in the domestic import compulsory certification catalogue: due to the particularity of bonded processing, only the Exemption Certificate needs to be applied for when importing, and only the domestic sales tax needs to be paid. Some enterprises are clear about the necessity of certification, but they are lucky to escape supervision. The above situations have caused the quality and safety risks of products in the CCC catalog that have not been certified to flow into the domestic market.
One of the preconditions for bonded processing enterprises to apply for the Exemption Certificate is that imported parts are imported for the purpose of exporting the whole machine. If the parts are to be sold in the domestic market, the compulsory product certification shall be handled first, otherwise the parts imported with the Exemption Certificate cannot be sold in the domestic market. In the absence of mandatory product certification, the enterprise sold the parts, which is illegal.
4、 Measures taken by the customs
In strict accordance with relevant laws and regulations and the requirements of the Announcement of the General Administration of Market Supervision and the General Administration of Customs on the Arrangement of Exemption from Compulsory Product Certification, the customs strengthened the supervision on the use of CCC exempted products and the verification management when transferring them to domestic markets. At the same time, it increased the investigation and issuance of products listed in the CCC directory that are sold without certification, so as to maintain the regulatory order of products subject to compulsory certification and the quality and safety of China's commodities.
