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9月17日中美合格评定项目会议纪要
  opening remarks

 

CNCA DDG Huang Shoyun stated that CNCA leadership including Chief Engineer Liu Weijun and Vice Minister Sun Dawei attach great importance to the CAP, and welcome the participation from CQC experts.

 

Senior International Trade Specialist Bryan O’Byrne from the U.S. Department of Commerce noted that concrete results were achieved through past CAP roundtables and thereby avoided the need to escalate issues to the WTO. Mr. O’Byrne, with support from U.S. Embassy Standards Attaché Dale Wright, further expressed his hope that this dialogue would continue such positive progress.

 

ANSI Director of International Development Elise Owen and U.S.-China Business Council (USCBC) Manager of Business Advisory Services John Lenhart stressed the private sector’s commitment to these dialogues and thanked CNCA and DOC for their leadership. ANSI further expressed its hope that a similar dialog could be organized in Washington, DC for Chinese companies to discuss their questions regarding conformity assessment in the U.S.

 

 

cnca presentation on ccc developments

 

§  Removal of products from CCC catalog

CNCA Announcement 117 (August 13, 2012) indicates 8 products to be removed from CCC catalog including certain electronics, vehicle parts, audio/video equipment, satellite and TV receivers.

 

§  Adjustment of certification model

CNCA announced that in response to comments from stakeholders that the CCC process lacks flexibility, it will undertake a risk assessment. As a result, CNCA is contemplating rating different products in the CCC catalog by risk, with some having a streamlined certification process and others with national security or health and safety implications remaining as is. In some cases, CNCA is contemplating simplifying the certification process. In some cases the initial factory inspection requirement may be removed and replaced with increased market surveillance. If companies are found to be non-compliant in post-market surveillance, then the inspection and certification process could become more rigid.

 

§  U.S. Industry Follow-up Questions

 

­   Will there be a transition period for Announcement 117?

­   How will inventory produced before Announcement 117 be treated? (Should it have a CCC mark or not?)

­   Will CNCA coordinate with Customs to ensure that they are aware of changes to the catalog?

 

­   Will the time cycle for CCC certification be reduced for companies in good standing?

 

CNCA responded that there will not be a transition period for Announcement 117. If the product is placed on the market after August 13, 2012 (date of Announcement 117), no CCC mark is required. If companies have already applied for CCC certification that is no longer necessary, they can request a refund of related fees. CNCA will coordinate with Customs to avoid unnecessary confusion for companies. These changes should reduce the time required for CCC certification of lower-risk products.

 

§  U.S. Response to CNCA presentation

The U.S. praised CNCA for these positive developments, and recommended that CNCA publicize this work by notifying the WTO Secretariat of the changes. The U.S. noted that China had made commitments to streamline the CCC process at China’s final WTO transitional review mechanism (TRM) and noted that these developments are positive progress towards fulfilling this commitment. The U.S. further suggested that China consider making a statement about the changes at the next meeting of the WTO/TBT Committee in November 2012.

 

 

questions and discussion with u.s. industry

 

§  Due to globalized production, the factories where companies manufacture parts are often not in the same location where the products are assembled. How can companies determine which facilities need to be inspected, and which facility should be listed on the CCC label?

 

CNCA noted that this is a common problem faced by foreign companies, and requested that CQC issue guidance to clarify the CCC process in these cases.

 

§  In many cases, CCC labs have different understandings of the implementing procedures. Is there a way this difference can be resolved?

 

CNCA recommended that CQC issue guidance on this.

 

§  The CCC regulation requires that final products become certified before an original design manufacturer (ODM) is certified. This is feasible when a new application is submitted, but creates problems during the renewal process because ODM certification may be delayed or even suspended. How can this be resolved?

 

CNCA indicated that there is a need to look into this further.

 

§  When the national GB standards on which CCC is based are revised, there is often an adjustment period of 3 months or longer before designated laboratories are able to test to the new requirements, causing delays in the type test process. Additionally, when new standards are issued, there are often differences in interpretation between the test labs, CQC and companies. How can these issues be resolved?

 

CNCA responded that CNCA and CQC are users of standards, and currently do not receive advanced copies of new and revised GB standards. Therefore it is difficult to avoid the adjustment period and differing interpretations in initial stages of implementation.

 

§  China Customs identifies a product’s HS code and compares it to the CCC catalog. Because the CCC catalog is based on a completely different classification system than HS codes, each port currently makes its own interpretation of whether or not a product requires a CCC mark. This results in different implementation of CCC requirements at different ports, leading to delays and confusion.

 

CNCA responded that  Notice #9 (2007) includes a classification of the products in the CCC catalog, and there is currently a working group of CNCA and CIQ experts undertaking work to add clarification to the document. This should help reduce delays and confusion at Customs. Once this effort is complete, suggestions and comments from companies will be welcomed.

 

§  Would it be possible for CNCA to notify CCC implementing procedures to the WTO Secretariat?

 

CNCA responded that they currently notify the WTO when there are major changes to CCC implementing procedures, but not when the changes are minor or when changes make the process less burdensome for companies. CNCA will consider notifying positive changes to procedures in the future.

 

 

follow-up questions from prior roundtables

 

§  What is the current status of allowing test reports to be submitted electronically rather than sending paper copies through China Post? This would reduce time-to-market by several weeks.

 

CNCA responded that electronic test reports have been developed and a pilot for electronic submission will soon begin for two selected products. Upon successful completion of the pilot, electronic submission of test reports will be available for all the other products in the CCC catalog.

 

§  What is the current status for allowing simultaneous type testing and factory inspection? This would significantly reduce time-to-market.

 

CNCA responded that simultaneous type testing and factory inspection is currently in place and companies may submit their request to CNCA. In these cases, the factory inspection will be considered informal until the type test is approved. If the type test is not approved, companies will be required to repeat the factory inspection, adding cost and time to market. CNCA also noted that the initial factory inspection requirement is being phased out for certain lower-risk products, as noted in their presentation above.

 

§  What is the current status for allowing foreign companies to participate in CNCA technical committees?

 

CNCA responded that currently its technical committees include 30-40% industry participation from domestic and foreign companies. Of the 300-400 people sitting on CNCA technical committees, up to 50 are representatives of non-Chinese companies. These representatives have full voting rights on their respective committees. CNCA stated that foreign expertise and participation is very welcome and that they are trying to maintain the ratio of foreign participation on their technical committees. One U.S. company confirmed that one of its local representatives serves as a leader of a CNCA sub-committee.