Discussion on the direction of CCC certification reform from the new version of implementation rules for automobiles

Date：2020/7/21　　Clicks：1351

In recent months, the State Administration of Market Supervision (CNC) has made continuous major moves in the reform of the compulsory product certification (CCC) system. The most important of these is the “Regarding Optimization In the form of the Announcement of the Compulsory Product Certification Catalog, a new version of the "Compulsory Product Catalog Description and Definition Table" (ie CCC Catalog) was released. In the same period, new versions of the implementation rules for CCC certification for four categories of products, namely automobiles, toys, baby carriages, and automobile brake linings, were intensively released. The first three categories are revisions to the old rules, and the last category is for newly produced products. The license is converted to the new rules specially formulated for CCC certified products.

According to the regulations, the CNCA will formulate and publish the corresponding "Certification Implementation Rules" for the products in the CCC catalog according to the category. Each certification body that has obtained the CCC certification qualification will further elaborate and formulate on the basis of the implementation rules of the CNCA. Issue the "Certification Implementation Rules" for various products. In general, the above rules (details) should specify the following content: certification scope, certification standards, certification models, certification unit division, certification entrustment, certification implementation, and post-certification Supervision, certification certificates, certification marks and other regulations.

When the CNCA released the new version of the implementation rules for certification of automotive products, the revised principles were stated to "further improve the design of the certification system, simplify application requirements, optimize implementation procedures, enrich evaluation methods, and increase the degree of convenience in the implementation of CCC certification." In the following, the author will briefly discuss the direction and new measures of CCC certification reform in the future based on the above-mentioned new rules.

01"Authentication Mode" Fast

"Certification mode" is the basic process that must be followed in CCC certification activities. The traditional CCC certification process is roughly as follows: the enterprise applies to the certification body online-preliminary review of the data-mailing the data after acceptance-the certification body assigns the inspection agency-mailing samples to make a pattern Test-arrange factory inspection after passing the audit-issuing certificate after passing the audit-regular supervision after the certificate is issued.

In the past, CCC certification was most easily criticized for its slow efficiency and long time. It often took several months to get the certificate. In fact, the time is mainly consumed in the two links of waiting for inspection and waiting for factory audit, and inspection and factory audit are often It is not easy to pass at one time, and subsequent rectification and rescheduling will cause time-consuming.

In order to improve the above situation, as early as September 2013, the CNCA issued the certification rules of "Classification Management of Production Enterprises, Selection and Determination of Certification Modes" (No.: CNCA-00C-003), which divided the products in the CCC catalog into For general risk products and higher risk products, it is clear that the certification model for the former can be considered to be simplified. Only one item can be selected for evaluation in the type test/initial factory inspection (certificate can be issued after the inspection); the latter is more For high-risk products, it is still necessary to maintain a comprehensive assessment of the traditional certification model (after inspection, the factory is first reviewed and the certificate is issued).

According to the author’s statistics, among the current 37 effective CCC certification implementation rules, 14 have the certification model simplified to "type test + post-certification supervision", which are concentrated in general risk products such as electronic appliances, toys, and small household appliances; There are 22 certification models that maintain the traditional "type test + initial factory inspection + post-certification supervision", which mainly involve higher risk products such as vehicles and accessories, building materials, and fire-fighting equipment, and special cases such as body reflective markings are "initial Factory inspection + type test + supervision after certification" (first inspection of the factory before inspection and then certification).

Taking the above four latest implementation rules as an example, the reform of toys is the most thorough, "certificate is issued after inspection", and whether the subsequent factory audit is determined by the agency, it also stipulates that "for a small number of single batch of factory/import toys, Exemption from post-certification supervision” to further reduce the burden on enterprises; although the baby stroller still “reviews the factory before issuing the certification”, for a small number of single-batch ex-factory/imported products, the initial factory inspection and post-certification supervision are also exempted There is a similar situation in the automobile category. When a certified company relocates or establishes a new production site, it is also possible to "certify first and then audit the factory"; the only strict implementation of "certification before the factory is issued" is the automobile brake lining. Products that may be transferred from the production license to the CCC system management, such as electric bicycles, gas appliances, and explosion-proof electrical appliances, are all regarded as higher risk products.

02 Broadening of "authentication unit division"

The principle of "certification unit division" is an important part of the certification rules, which directly affects the cost and efficiency of CCC certification for enterprises. To put it simply, if the principle of "certification unit division" is specified in detail, then a certain type of product of an enterprise cannot be placed in the same product unit due to differences in specific models and parameters. You must apply for multiple CCC certificates or even one for each model. Each certificate must go through the entire certification process and pay multiple times; if it is not specified so detailed, a certain type of product of the company is likely to belong to the same certification unit, and it can be included in a CCC certificate. List multiple models, go through the process and pay once.

The author also made statistics. Of the 37 currently effective CCC certification implementation rules, 24 of the rules directly stipulate diagrams of more detailed unit division principles, such as automobile brake linings (below);

The other 13 only give the basic principles of unit division, which are also concentrated in general risk products such as electronic appliances, toys, and small household appliances, but also include gas appliances and explosion-proof electrical products with higher risk. Such rules are The right to refine the principle of unit division is given to each certification body.

For example, the implementation rules for toys only say "In principle, the certification unit should be divided according to the main material, structure, function, intended play mode, applicable age, etc. of the toy. The certification body should specify the specific certification unit in the certification implementation rules Requirements", and for the consideration of catering to customer needs and improving convenience, the certification body is likely to move towards "broadness" when formulating the principles for the division of certification units. Another example is the new version of the automotive certification rules. On the basis of the method of issuing certificates according to product units, the method of issuing certificates according to product series has been added. Enterprises can freely choose to realize the maximum coarsening of the classification of automobile CCC certificates, which will greatly reduce the existing tens of thousands of CCC certificates, and The certification declaration parameters are reduced by 40%, reducing the burden on enterprises.

In addition, as for the division principle of certification units for OEM/ODM foundry products, the four latest certification implementation rules also reflect the trend of further "broadness".

The early certification rules basically strictly stipulated that "products of different manufacturers or different manufacturers cannot be used as a certification unit." This leads to the fact that if an OEM manufactures the same product for multiple clients at the same time (only the brand is different), Or if a brand party finds multiple foundries to produce the same product at the same time, they must apply for certification certificates separately for products of different brands and different foundries, requiring repeated type testing and payment.

In recent years, when the certification rules were revised, some requirements have been relaxed. It stipulates that “the same product produced by the same manufacturer or different manufacturer, or the same product produced by different manufacturers and the same manufacturer, may be considered only on the sample of one unit. For testing, other manufacturers/producers’ products need to provide materials for consistency verification", that is, although multiple certificates need to be issued separately, only one type test can be performed, and other certificates only need to provide paper data for verification. Consistency is fine.

And new changes can be seen in the four latest certification rules mentioned above. For example, the new rules for toys and strollers (item 4) all say "the same product produced by the same manufacturer, different manufacturers, or different manufacturers, The same products produced by the same manufacturer can be divided into the same certification unit.” From the textual understanding, it means that when new OEM products apply for CCC certification in the future, one certificate can list more than two manufacturers (clients) Corresponding to one manufacturing company (foundry), or listing a manufacturer (consignor) to more than two manufacturing companies (founding factories), instead of having to apply for multiple certificates separately as before, so from the certification process, payment Further reduce the burden on enterprises.

03Facilitating "type testing"

According to regulations, type testing must be completed by a third-party inspection agency with legal qualifications approved by the CNCA. The traditional mode is generally that the company applies for certification to the certification agency. After the data is reviewed, the company mails samples to the inspection agency assigned by the certification agency. , The enterprise itself has less power to choose.

It can be seen from the above four latest certification rules that enterprises are gradually being given more discretionary powers. For example, the new rules for toys and strollers (item 6.1.4) stipulate that “the certification client can first carry out type testing, and then Submit a certification request to the certification body", that is, you can do the type test in advance and then apply for certification, and "the certification client can choose the laboratory designated by the CNCA to complete the type test", the enterprise can be in the designated agency announced by the CNCA Evaluate efficiency and service, choose the best, without waiting for the certification agency to assign.

For another example, the new automobile rules (item 7.1.5) stipulate that “certification bodies shall specify a unified type test report format”, by which some certification bodies have already made a decision and all or part of the companies adopting the Ministry of Industry and Information Technology’s automobile announcement The content of the inspection report is used as the type test report (because there are not many qualified automobile inspection agencies, they often undertake the inspection business of the Ministry of Industry and Information Technology's automobile announcement and CCC certification, and the two system inspection items are highly overlapped).

In addition, taking into account the auto companies’ own scale and strong inspection capabilities, the auto rules (item 7.1.4.1) also stipulate that “if the manufacturer has the requirements for the use of inspection resources and other certification results of the manufacturer of the mandatory product certification implementation rules” and For the testing conditions required by the certification standards, the certification body can use the testing resources of the production enterprise to implement sampling testing (or witness testing) at the production site, and the designated laboratory will issue a testing report" to further facilitate.

04 Standardization of "Certificate and Mark" management

Previously, the official CCC certificates were all paper versions, which were mailed to the enterprise by the certification body, and there were certain inconveniences in the issuance, filing, storage, modification, and withdrawal of the certificate. 

With the outbreak of the new crown epidemic at the beginning of this year, the General Office of the Municipal Supervision Administration issued in February the "Notice on the Implementation of Quality Certification during the Prevention and Control of the Novel Coronavirus Pneumonia Epidemic". Some certification agencies (such as China Quality Certification Center CQC) In order to "support the production and operation activities of relevant enterprises during the war against the'epidemic' period, effectively provide facilitation services to certified enterprises and the public, and improve the time limit for certificate application", mandatory products have been fully launched since February 14 The certification (CCC) electronic certificate (hereinafter referred to as "electronic certificate") is used, and the paper certificate and the corresponding electronic certificate are issued to the certification client at the same time.

At the CNCA level, the legal status of the electronic version of the certificate has been established in the newly released new automotive certification rules. Item 9.6 stipulates that “the certification body shall comply with the requirements of relevant laws and regulations and may provide the electronic version of the certificate to the certification client, and Ensure that the electronic version of the certificate is consistent with the paper version, and should have the ability to verify the certificate online".

With the continuous popularization of the "Electronic Signature Law", I believe that this content will be added when other certification rules are successively revised. This measure will facilitate enterprises to quickly provide effective certificates during law enforcement inspections, import verification and other links, and optimize certification services. It is also a typical measure at the practical level of certification internationalization.

In addition, regarding the use of the CCC certification mark, because the relevant management regulations have been revised before, the CCC mark styles with category symbols such as "S" and "E" have been deleted from the 4 new certification rules mentioned above, and they have been changed to non-category standards. Logo:

 
And it clearly stipulates the specific location where the CCC mark should be affixed or marked, and the new rules for toys and strollers have also deleted the requirement that the manufacturer's code should be marked at the same time.