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CCC certification requirements for assembled computer sales
Date:2020/10/22  Clicks:1296
In the domestic personal computer market, there have long been two categories of products, original brand machines and assembly compatible machines. The CCC certificates of original brand machine manufacturers are generally relatively complete; the latter are often merchants in the computer city. According to the customer's purpose and budget needs, the purchasing agent is different. Computer accessories with brands and parameters are assembled into a variety of computer hosts or complete machines with different configurations in the shop, but generally they are not advertised with any brand, and few merchants apply for CCC certificates for assembled computers.

CCC certification requirements for assembled computer sales

At the beginning of 2018, consumers purchased a "SEXXX Number Zero U-PC" desktop computer host through company J in a flagship store on an e-commerce platform. After the delivery, they found that the CPU, motherboard, hard disk, Accessories such as power supply and radiator, but no memory module (the store does not sell memory modules) and graphics card (shipped together but not installed). The consumer failed to request the CCC certificate of the above-mentioned computer, so he lodged a complaint with the supervisory authority where the J company is located.

In the investigation, J Company pointed out that what it sells is not a finished product, because it lacks memory and does not have a graphics card installed, so it is only a combination of accessories and cannot be turned on without CCC certification.

The law enforcement officials requested instructions from the CNCA through the provincial bureau, and the CNCA replied that "the computer host mentioned in the letter is a product in the CCC catalog and cannot be shipped, sold, imported or used in other business activities without certification." Accordingly, company J was punished in accordance with the law.

Personal computers (microcomputers) belong to the first batch of products to be certified by CCC. Products that have not been certified since May 1, 2003 shall not be shipped, sold, imported or used in other business activities. The description is "an entity with an independent structure composed of computing modules, storage modules, power supply modules, and operating systems. This entity can be connected or built-in peripherals to form an information processing system" (first seen in the 2007 version and continued in the future), see the catalog The microcomputer in only refers to the host computer, and does not include peripherals such as monitors, printers (both belong to the CCC catalog), keyboards, and mice.

In the domestic personal computer market, there have been two categories of products: original brand computers and assembled compatible computers for a long time:

former

A regular computer manufacturer purchases various accessories, mass-produces and assembles a number of fixed-configuration computer hosts in the factory, and sells them together with displays and peripherals according to consumer needs, using their own brands (such as Lenovo, Dell, etc.) ) Publicity, the CCC certificates of original brand machine manufacturers are generally more complete;

the latter

Businesses in the computer city often purchase computer accessories of different brands and parameters according to customer usage and budget requirements, and assemble them into computer hosts or complete machines of various configurations in the shop, but generally do not use any brand promotion. There are also very few businesses that apply for CCC certificates for assembling computers.

In theory, there is no obvious difference between the original brand machine and the assembled compatible machine in terms of usage, configuration, quality requirements, etc., and both should be CCC certified; but taking into account the special circumstances of the assembled computer (the operator is small, the configuration is diverse, only Provide assembly services, etc.), the CNCA issued the National Certification Letter (2003) No. 196 "Notice on the Relevant Regulations of On-site Assembly Computer Certification Law Enforcement Inspection" in September 2003, stipulating that if the assembled computer meets the following conditions, the It is regarded as a business that provides technical services for assembling computers for consumers. At this time, assembling computers do not need to apply for CCC certification:

1. The assembly location must be in the business premises rented or purchased by the computer accessories and component distributors, and the assembly personnel are the computer accessories and component sales personnel of the business premises.

2. The target of on-site assembly machine technical services is individual consumers (limited to a single computer), rather than enterprises, institutions, organizations, other computer sellers, and purchasers for business activities.

3. The assembly work should be completed and delivered to the customer within the day after the accessories and parts are purchased. The products that are pre-assembled into a complete machine and sold to customers are not included.

4. The assembled whole machine shall not be marked with any brand or model, nor shall it be promoted or sold by any brand or model.

5. In the process of assembling the whole machine, it is not allowed to use counterfeit and inferior products, smuggling and other products that are expressly prohibited from sale, and the use of microcomputer accessories listed in the compulsory product certification catalog must have corresponding certification certificates and certification marks.

The promulgation of the above-mentioned "unbinding" regulations did bring some convenience to computer operators and individual consumers at the time, and also promoted the rapid development of the DIY computer industry in the computer city. But for business operators, the second point above is still "limited to individual consumers and a single computer at a time." If the conditions are still not met when the computers are assembled in batches or directly supplied to enterprises or units, they still need to apply for CCC certification.

Because this regulation is difficult to meet, some operators simply "different ways", trying to circumvent product attributes, assembling and supplying to schools, Internet cafes and other units do not install hard disks in computer hosts, but work through the network to share server hard disks. It is sold under the name of "network computer", and it is assumed that not installing a hard disk means that there is no "memory module", which does not conform to the definition and description of microcomputers in the CCC catalog. For such products, the CNCA clearly explained in 2005 in the "Reply on Whether Network Computers Are Products in the Compulsory Product Certification Catalog" (National Certification Letter [2005] No. 190), "Although the host of network computers is not It is equipped with hard disk, optical drive, floppy drive and expansion slot, but it contains main board, CPU, internal memory, power supply and other components. It should belong to the "microcomputer" product in the "Catalogue of the First Batch of Products Subject to Compulsory Product Certification".

Seeing that this is not possible, some operators changed their minds. Although the previous "network computer" did not have a hard disk, it could still be turned on and run on the Internet, so it would be regarded as a finished product; then if only assembled into a "semi-finished product" that cannot be turned on ( For example, if the graphics card is lacking, and the consumer is self-provisioning), can CCC certification be avoided? This method is also not feasible. The CNCA further explained in the 2015 "Reply on Issues Concerning Compulsory Certification of Computer Products for Online Sales" (Certification Han (2015) No. 193), "Computer products without graphics cards in the letter Comply with the description of microcomputer products in the "Compulsory Product Certification Catalog Description and Definition Table", which is composed of computing modules, storage modules, power supply modules, and operating systems. It is an entity with an independent structure and can be connected or built-in peripheral equipment to form information Processing system, such products should fall into the scope of compulsory product certification", it can be seen that "semi-finished products" still violate the regulations.

In recent years, the sales locations for assembled computers have gradually shifted from physical stores in the Computer City to third-party e-commerce platforms, and the transaction method has also changed from "both parties on-site one-handed delivery and delivery" to "online payment without face-to-face transactions, express delivery ". Under the traditional brick-and-mortar store purchase model, it is relatively easy to distinguish whether it is an individual consumer; but under the online sales model, it is difficult to distinguish individual consumers, enterprises, and unit customers based on information such as the customer's order and delivery address. In 2015, when a provincial bureau asked the CNCA for instructions, “With the rapid development of the e-commerce industry, the traditional on-site assembly of computers to deliver customers has changed to display recommended configurations through e-commerce platforms, and change or replace according to the individual needs of consumers. The relevant hardware is added or reduced, and delivered to consumers through logistics. Therefore, the 2003 "Notice" can no longer cover this new form of assembly and sales mode." However, the CNCA responded after studying the "Compulsory product certification for online sales in the letter. If microcomputers cannot meet the conditions specified in the "Notice on the Relevant Regulations on the Enforcement and Inspection of Computer Certification on Site Assembly", they shall be sold only after obtaining the compulsory product certification." This emphasized again that the 2003 "Notice" is valid and Online sales and assembly of computers still apply, and the specific requirements have not been relaxed over time or changes in transaction methods.

On the contrary, the online sale of assembled computers has brought new obstacles that are insurmountable to the delivery of products. Item 3 of the above-mentioned "Notice" in 2003 must "assemble and deliver to customers on the same day after purchase", which is very difficult under traditional trading methods. It's easy to do, but for online sales, "deliver to customers on the same day" in the second half of the sentence is difficult to achieve. There is a point of view that if an e-commerce operator can complete the assembly on the day of receiving the order and contact the express delivery or logistics door-to-door pickup, it is regarded as "same day delivery", but the author does not agree. On the one hand, there is no extended explanation of the meaning of the term “delivery” in the current laws and regulations, and the above viewpoints do not conform to the general conventional understanding; on the other hand, the CNCA clearly stated that “not yet Promulgated documents related to the assembly of computers sold through the Internet and delivered to the express delivery on the same day, which is equivalent to the assembly work described in the Certification Letter [2003] No. 19, which should be completed and delivered to the customer within the day after the parts and components are purchased", CNCA Nor does it support this view.

In summary, the current CCC certification system has always had strict requirements for assembling personal computers (microcomputers). As a business, if you want to operate legally and compliantly, there are only two options:

1. Apply for one or more CCC certificates for personal computers in accordance with the regulations, and provide consumers, enterprises, or units with customized assembled computers within a certain configuration range allowed by the certificate, and at the same time, it can also be branded and promoted;

2. It does not provide any assembly services, but simply sells accessories. According to the customer's order requirements, the chassis, CPU, motherboard, memory, hard disk and other accessories are packaged and shipped together in the original packaging, and it can only be reflected in the store promotion and sales receipts. It sells accessories, not a host, and it cannot be promoted under its own brand.

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