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How to determine whether the product belongs to the scope of the CCC certification catalog through the
Date:2020/8/19  Clicks:1485
In the daily supervision of certification and handling of reports and complaints, the most common question is how to define whether a product belongs to the scope of the CCC certification catalog? For example, do unmanned vending machines, steam beauty garment ironing machines, strap-on rearview mirror recorders, etc. belong to the scope of CCC certification? How to determine whether a product belongs to the scope of the CCC certification catalog through the comprehensive four evaluation methods of "product category description", "common product range listing", "applicable standard listing" and "exception item description"?

According to the "Regulations on Certification and Accreditation", products listed in the catalog (namely, the compulsory product certification catalog, commonly known as the CCC catalog), without CCC certification, shall not be manufactured, sold, imported or used in other business activities, and shall be subject to daily supervision of certification When dealing with reports and complaints, the most common question is how to judge whether a product belongs to the scope of the CCC certification catalog. The catalogue has undergone 4 revisions since it was first published in December 2001. The latest edition was published by the State Administration for Market Regulation on April 28, 2020 in the "Announcement on Optimizing Compulsory Product Certification Catalogue" (No. 18, 2020). Form release, including 17 major categories and 102 seed categories. The catalog mainly defines a certain category through four evaluation methods: “product category description”, “common product range listing”, “applicable standard listing” and “exception item description”. Whether the product belongs to the scope of CCC certification catalog.

In practice, the first thing we face is how to accurately classify the main functions of products. Especially with the continuous development of science and technology, various multi-functional new products are emerging in an endless stream. The preface of the CCC certification catalogue is specifically regulated. Multifunctional products with two or more products in the compulsory product certification catalog are classified according to their main functions and main purposes of use." In the following, the author takes several reports involving products as examples, and briefly talks about personal understanding of the product’s “main functions and purpose of use”.

1. Unmanned vending machine
It was reported to have "computer", "refrigerator" and other functions, but the whole was not certified.
Verification result: not within the scope of CCC certification

In recent years, the above-mentioned "unmanned vending machines" (sales of food, beverages, daily necessities, adult products, etc.) have gradually become popular all over the country. The main structure includes LCD screen purchase areas, storage areas and pickup ports (some with Refrigeration function), consumers can choose to purchase goods through the LCD screen, scan the code or pay for the goods with coins, and the goods will automatically fall to the pickup port.

First of all, according to the "refrigerator" category in the CCC certification catalog, the additional refrigeration function of some products does not belong to the category of "refrigerators" in the CCC certification catalog. The LCD screen Inside the shopping area is a touch-screen computer (computer) with interactive operation functions. The CNCA has commented on the "Notice on Compulsory Product Certification for Self-service Terminal Products" (National Certification [2008] No. 5) "Self-service terminal" has been defined, "refers to equipment operated by users themselves to provide services for themselves (for example: bank transfer, deposit/withdrawal, payment of telephone bills, water, electricity, gas, information inquiry, queuing, etc.), and its structure It usually includes monitors, computer hosts, printers, IC card readers, modems, etc. These parts can be independent products that become a system through wired connection or partial integration (such as display and host integration),...should be mandatory "The scope of certification for sexual products" refers to "computer" products that fall into the category of information technology equipment in the CCC certification catalog. From the perspective of "service provision" and internal structure configuration, "unmanned vending machine" does indeed meet the description of "self-service terminal", but why does it not belong to the scope of CCC certification? This embodies the principle of "products are classified according to their main functions and purposes". The CNC03 electronic expert group of CNCA explained this in the summary of the 2016 special seminar, "This type of vending machine has a special structure and involves many However, since its ultimate actual use function is a sales function, it is not a function that information technology equipment, audio and video equipment or telecommunications terminal equipment should have, so it is temporarily not considered to belong to the scope of self-service terminals in Announcement 4." That is, no matter from the product name or general purpose, the main function and purpose of the vending machine is only to sell goods. This principle is also applicable to "other main functions are only to transmit, place, sell or access physical products", such as library self-service terminals, supermarket self-service weighing terminals, self-service game coin vending machines, express cabinets, etc., TC03 Electronic Expert In 2019, the group issued a technical resolution specifically to clarify that although the above-mentioned products belong to self-service terminals, they do not need to obtain CCC certification as a whole.

In the same way, common shared bicycle smart locks, smart children's shoes and other products have functions such as "real-time positioning", "movement track recording and uploading" (all realized through mobile data communication functions), but from a conventional cognitive perspective , The main functions of the product itself are "control wheel operation" and "wear, walk, and protect". Additional additional functions cannot affect whether it belongs to the CCC certification catalog.

2. Steam beauty garment ironing machine
It was reported to have steam beauty function, and the product was not certified.
Verification result: within the scope of CCC certification

In recent years, a "steam beauty garment ironing machine" has appeared on the market. It can directly use 220V city power. It can be used by hand and sprayed with steam to iron all kinds of clothes. It can also be placed in a fixed position and steam on the face. The skin undergoes heating care. From the name point of view, the product is named "steam beauty garment ironing machine" by itself, and "(steam) beauty" and "(steam) garment ironing" are listed together (and beauty is arranged before garment ironing); from the manual, "Ironing" and "steaming face, beauty" are also described as the main purposes; from the physical structure, there are two different positions of "ironing" and "steaming face" at the product switch. In summary, it can be identified as a multi-functional product, including "steam beauty" and "ironing". There is a category of "skin and hair care appliances" in the "household appliances" category of the CCC certification catalog. The product description is "personal care appliances with electric heating elements for hair or skin care". The product list includes "facial saunas" ", exactly in line with the description of the "steam beauty" function; while the "ironing" function has a corresponding "electric iron" category in the CCC certification catalog, but this category of remarks has stipulated that "not including: fabric steam engine (steam iron brush )”, so after checking the two main functions, it is found that the former belongs to the scope of the CCC certification catalog, while the latter does not. It was finally determined that the above-mentioned "steam beauty garment ironing machine" belonged to the scope of CCC certification. But it should be noted that this conclusion is only applicable to "steam beauty garment ironing machines" that meet the above-mentioned nominal and structure.

Generally speaking, the main functions and uses of the product firstly depend on the various self-explanatory declarations of the product (name, manual, implementation standards, etc.), and secondly, it depends on the understanding of the main functions of the product (that can be achieved) under conventional cognition. Only when these two conditions are met and the relevant expressions are not self-contradictory can be accurately defined. For example, if the product name is "garment ironing machine" and the garment ironing machine GB4706.84 standard (the steam beauty instrument standard is GB4706.15), the body does not have a "steaming face" gear, even if the manual or sales promotion can "Steam beauty" can only be used as an additional additional function, and should not be deemed to be within the scope of CCC certification.

3.strap type rearview mirror recorder
Reported as having the functions of "car rearview mirror" and "audio and video storage and playback", the whole is not certified by CCC
Verification result: not within the scope of CCC certification

The back of the product has a camera and double-sided elastic straps, which can be stuck on the rearview mirror of the original car. Some areas on the front are pure mirrors, which can observe the rear view of the vehicle from the reflective surface; other areas are touch screens, which can be realized Play built-in audio and video files, driving video recording and playback, map navigation and other functions. From the perspective of name and structure, the main function and purpose of the product include "car rearview mirror" and "audio and video storage and playback". According to the function, they belong to the "vehicle and safety accessories" in the CCC certification catalog. , "Electronic products and safety accessories" two categories, then the assessment item by item.

First of all, the description and enumeration of "car mirrors" in the category of "vehicles and safety accessories" do include "inside mirrors", but for this special structure fixed by straps, CNCA TC11 Automobile And the component expert group has reached a consensus in the 2016 working meeting minutes. Taking into account the unstable installation structure and potential safety hazards, the strap-on rearview mirror has decided not to be included in the scope of CCC certification.

Secondly, for the category of "electronic products and safety accessories", considering the product's special shape and structure (approximately trapezoidal or elliptical rearview mirror shape, special mirror reflection field of view, strap-mounted installation structure), it is obvious that the common sound Video playback products (digital players, advertising players, etc.) are different. From the perspective of conventional cognition, I believe that most people will come to the conclusion that "the use of this product is more in line with auto parts". According to the preface of the CCC certification catalog, “For electrical and electronic products, in addition to vehicle-mounted mobile user terminals, explosion-proof electrical or special instructions, they are designed, manufactured and used for automobiles and motorcycles, trains, ships, and airplanes. Products with specially designed and installed structures are not within the scope of CCC certification.” It can be seen that audio and video playback products specifically used for auto parts are not within the scope of CCC certification. Combining the above two points, the final determination that does not belong to the scope of CCC certification can be made.

Summary: When assessing the "main functions and purpose of use", at least two aspects should be checked: one is to measure whether the product itself is comprehensive and accurate in its expression of its main functions and uses in various ways (excluding self-contradictory information. The second is from the perspective of conventional cognition and general understanding, to measure whether the product can achieve its nominal main function and purpose under normal conditions.

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