China Compulsory Certificate

The China Compulsory Certificate mark, commonly known as CCC Mark, is a compulsory safety mark for many products sold on the Chinese market. It became effective on May 1, 2002. It is the result of the integration of China's two old compulsory inspection systems, namely "CCIB" (Safety Mark, introduced in 1989 and required for products in 47 product categories) and "CCEE" (also known as "Great Wall" Mark, for electrical commodities in 7 product categories), into a single procedure.

Applicable products

The CCC mark is required for both domestically manufactured products and products imported into China, such as:

• Electrical wires and cables
• Switches for circuits, Installation protective and connection devices
• Low-voltage Electrical Apparatus
• Small Power motors
• Electric tools
• Welding machines
• Household and similar electrical appliances
• Audio and video apparatus
• Information technology equipment
• Lighting apparatus
• Telecommunication terminal equipment
• Motor vehicles and Safety parts
• Motor vehicle tires
• Safety Glasses
• Agricultural Machinery
• Latex Products
• Medical Devices
• Fire Fighting Equipment
• Detectors for Intruder Alarm Systems
• Wireless Local Area Network (WLAN) systems
• Toys

Administration

The CCC mark is administered by the CNCA (Certification and Accreditation Administration). The China Quality Certification Centre (CQC) is designated by CNCA to process CCC mark applications and defines the products that need CCC.

The certification process usually takes sixty to ninety days and includes the following steps:

1. Submission of an application and supporting materials
2. Type Testing. A CNCA-designated test laboratory in China will test product samples
3. Factory Inspection. CQC will send representatives to inspect the manufacturing facilities
4. Evaluation of the results
5. Approval of the CCC Certificate (or failure and retesting)
6. Annual Follow-up Factory Inspections by Chinese officials

IT security products

On 27 April 2009, China announced 13 categories of products, so called "IT security products" should conform CCC (China Compulsory Certificate) implement regulation and it apply from, only a few day ahead, 1 May 2009. In view of security measure of China, there would be highly possible that China request disclosure of source code of program run on these products. The disclosure of source code is the big concern among countries U.S., Japan, EU and South Korea, and asking China to take back and opposing the implementation plan to come. The certification agent shall be limited to the organization or entity within China, but this restriction also arise other concerns that source code and secret of product know-how leaked to private sectors. In respond to such concern, China altered Compulsory Certificate implement from apply to all these type of product import into China to apply to only government procurement products and postponed implementation date to 1 May 2010.^[1][2][3] China has also commented that the number of product categories is not expanded to more than 13.

List of IT security products

13 categories or type of products are:^[4][5]

1. Secure operating system product
2. Safety isolation and information exchange product
3. Secure router product
4. Security supervising product
5. Secure database system product
6. Countermeasure product for spam (trouble/nuisance) mail
7. Firewall product
8. Invasion detect system product
9. Data backup/recovery product
10. Network secure isolating LAN card/switching hub product
11. Network vulnerability scanning product
12. Web site recovery product
13. Smart card COS product

Opposition for discriminate foreign-made products and IT security products procurement policy

The timeline of the opposition acts against to be settled policy of foreign IT security products procurement into Chinese government operations by other countries.

• 4 May 2009 - Ron Kirk (USTR) and Toshihiro Nikai (METI) meet in Washington, D.C., and coincide with opposing CCC that "CCC is not consistencies with international standard (Common Criteria) on 13 types of IT security products which was announced on 27 April 2009" as the communiqué. Nikai said that each country to work on China to take back the plan with sharing information among Japan and U.S. in news conference^[6][7]
• 13 May 2009 - Editorial of Yomiuri Shimbuneditorial viewed that concession of China to apply only government procurement products is derived from opposition of government and industries of Japan, U.S. and EU claimed the certificate is invasion for Intellectual property right. CCC would force Japanese and other manufacture suppress to export high technology products to China, hence China would not be indebted to these products.^[8]
• 19-20 May 2009 - Ministry of Industry and Information Technology of the People's Republic of China, Chinese Ministry of Commerce and METI Japan had the meeting of ministry permanent vice-president class in Beijing. Japan asked to take back the plan, but China expressed to consider the dual aspect of secirity of China and protection of intellectual property right of manufactures, and postpone to implementation to 1 May 2010.^[9]
• 21 May 2009 - 13th conference of WSC (World Semiconductor Council) in Beijing, participate delegation from Japan, U.S., EU, South Korea, Taiwan even China, declared the big concern for new CCC implementation for disclosure of core technologies information such as source code and others.^[10]
• 7 June 2009 - Wang Qishan (Chinese Vice-Premier), Hirofumi Nakasone (Japanese minister for foreign affairs) and Nikai had China-Japan High-Level Economic Dialogue, Nikai again asked China to take back the plan which forces exporting manufacture to disclose the source code of IT security products, however, China repeated to proceed with additional of CCC program from 1 May 2010 as planned.^[11][12]
• 8 September 2009 - Fujio Mitarai (chairman of Japan Business Federation) and Ryoji Chubachi (中鉢良治, Chūbachi Ryōji^?) (vice chairman of Sony) had meeting with cadre from Chinese Ministry of Commerce in Beijing. In spite of asking to take back the plan, China quoted to implement plan as scheduled from 1 May 2010, and the plan apply to only government procurement products, so that technology information leak to third parties shall not occure. Japan expressed the concern that coverage of products of government procurement is not clear.^[13]
• 30 December 2009 - Yomiuri Shimbun reported as the news from Washington, D.C. that, learned on 29th, China is seemed showing concession to apply the rule for only government agency procurement, not to apply to Chinese government-owned corporation procurement. Japan, however, still request China to abolish the rule itself further.^[14] USTR Website indicated as of 29 October 2009, that "China confirmed in working group discussions ..... apply only to products procured by Chinese government agencies", and this fact seems in backup the same in interpretation as Yomiuri Shimbun reported.^[1]
• 11 April 2010 - Yomiuri Shimbun learned that USTR Deputy Ambassador Demetrios Marantis visit China on April 12, and it seems that he will request further postpone beyond 1 May 2010. USTR concerns that recent concession of China may be lesser the applicable product types, however China interpretation of CCC rule may be taken a broad view.^[15][16]

• 14 April 2010 - Chinese government seems to retract some rules of the CCC implementation plan for IT security products and Chinese government-owned corporation procurement. China official web site updated with date of 10 April, as the new rule is to be, contextually,"Foreign enterprise should have intellectual property or trademark for the product and must obey and conform Chinese rules or regulations." from "Firstly in China, foreign enterprise should have intellectual property or trademark for the product and must obey and conform Chinese rules or regulations." The revising on web site eliminated wording "Firstly in China". This retraction seems China's concession to opposing reaction by other countries since April 2009. Based on the such movement, Japan, US and European authorities will study further political direction against Chinese position.^[17][18][19]

• 19 April 2010 - The Japanese Chamber of Commerce and Industry in China (中国日本商会) announced the proposal to Chinese government for improvement on the facing problem of Japanese enterprises in China. The proposal points out that Chinese government is still planning the regulations with discriminate against foreign products even if it seemed to retract on 10 April 2010.^[20][21][22]

• 25 May 2010 - China promised to improve the policy toward better to opposing foreign countries for discriminate foreign-made products on Chinese government agency procurement. ^[23] Ron Kirk (USTR) responded to interview, during 2nd U.S.-China Strategic and Economic Dialogue in Beijing, that China is improving the policy but still concern remains to discriminate U.S. made products.^[24][25]
• 21 July 2010 - Yomiuri Shimbun solely interviewed Demetrios Marantis (USTR Deputy Ambassador) on 19 July and reported, he is commenting that China presented some improvement for government procurement in May 2010, but serious concerns still remains. Chinese government procurement system under planning is typical example to exclude the foreign products. U.S. and other major countries requests China to be the parties of Agreement on Government Procurement of WTO for further improvement from Chinese position which exceptionally rule out local government procurement and other factors.^[26]
• 20 August 2010, Yomiuri Shimbun reports, under the slogan of Indigenous Innovation (自主創新), low cost WPS Office is used instead of Microsoft Office in 60% of Chinese government and local government agency. Business Software Alliance is becoming recognizing the fact and claims the slogan seems narrowing business opportunity into Chinese market, according to Demetrios Marantis.^[27]

See also

• Common Criteria
• National Development and Reform Commission

References

1. ^ ^{a b} "Information Security, U.S.-China Joint Commission on Commerce and Trade". USTR. 2009-10-29. http://www.ustr.gov/about-us/press-office/fact-sheets/2009/october/us-china-joint-commission-commerce-and-trade. Retrieved 2009-12-31. 
2. ^ "China, CCC Certification News Update". nemko.com. 2009-09-10. http://express.nemko.com/portal/page?_pageid=34,277901&_dad=portal&_schema=PORTAL. Retrieved 2009-09-18. 
3. ^ "Chinese certification of information security products". nemko.com. 2009-08-28. http://express.nemko.com/portal/page?_pageid=34,276946&_dad=portal&_schema=PORTAL. Retrieved 2009-09-18. 
4. ^ Note that product naming is literal translation from China published wording to Japanese by several number of Japanese industrial associations, then further literary translated to English.
5. ^ "中国CCC 強制認証対象品目一覧表2009 年版 [List of CCC applicable products, 2009 edition]" (in Japanese) (PDF). Shibuya, Tokyo: JET:Japan Electrical Safety & Environment Technology Laboratories (電気安全環境研究所). p. 9/10. Archived from the original on 2009-08-28. http://www.s-jet.com/data/cooperation/dl/ccclist_20090828.pdf. Retrieved 2009-09-18. 
6. ^ "Statement from U.S. Trade Representative Ron Kirk and Japan Economy, Trade and Industry Minister Toshihiro Nikai". USTR. May 2009. http://www.ustr.gov/about-us/press-office/press-releases/2009/may/statement-us-trade-representative-ron-kirk-and-japan-e. Retrieved 2010-04-11. 
7. ^ Yomiuri Shimbun 6 May 2009, Ver.13S page2
8. ^ Yomiuri Shimbun 13 Sept. 2009 ver.13S page 3
9. ^ Yomiuri Shimbun 21 Sept. 2009 ver.13S page 9
10. ^ Yomiuri Shimbun 22 Sept. 2009 ver.13S page 11
11. ^ Yomiuri Shimbun 8 June 2009 ver.13S page7
12. ^ "中日ハイレベル経済対話の第2回会合が開催 中国から3提案 [2nd China-Japan High-Level Economic Dialogue opened, China proposed three offer]" (in Japanese). People's Daily Japanese edition. Archived from the original on 2009-06-08. http://j.peopledaily.com.cn/94476/6673862.html. Retrieved 16 September 2009. 
13. ^ Yomiuri Shimbun 9 Sept. 2009 ver.13S page 9
14. ^ Yomiuri Shimbun2009-12-30 Ver. 13S p.1
15. ^ Yomiuri Shimbun, 11 April 1020, ver13S page 2
16. ^ Yomiuri Online Yomiuri Online 10 April 1020
17. ^ Yomiuri Shimbun, 14 April 1020, ver13S page 9
18. ^ Yomiuri Online Yomiuri Online 13 April 1020
19. ^ China's IT certification not a threat Wednesday, March 24, 2010 (The Japan Times)
20. ^ 中国、外国製品を差別…ＩＴ優遇撤回後も (lit. China, discriminate foreign products... even after retract Chinese IT products is treated in priority) Yomiuri Shimbun 20 April 2010, ver 13S page 9
21. ^ "《中国经济与日本企业 2010 年白皮书》（概要） [White paper 2010: Chinese economy and Japanese enterprises (Summary)]" (in Chinese) (PDF). Beijing: The Japanese Chamber of Commerce and Industry in China. 20. Archived from the original on 2010-04-23. http://www.cjcci.biz/public_html/100420-1.pdf. 
22. ^ "「中国経済と日本企業2010 年白書」（要訳) [White paper 2010: Chinese economy and Japanese enterprises (Summary)]" (in Japanese) (PDF). Beijing: The Japanese Chamber of Commerce and Industry in China. 20. Archived from the original on 2010-04-23. http://www.cjcci.biz/public_html/100420-1.pdf. 
23. ^ Yomiuri Shimbun, 26 May 2010, ver13S page 1
24. ^ USTR claim to resolve trade barrier to China on 2nd U.S.-China Strategic and Economic Dialogue (Reuters) (in Japanese)
25. ^ China and U.S. each claim gains on yuan in talks (Reuters)
26. ^ Yomiuri Shimbun 21 July 2010 Ver.13S. Page 2, Parties to Agreement on Government ProcurementWTO, Yomiuri Online, Japanese article on 21 July 2010
27. ^ Yomiuri Shimbun, 2010-08-20 Ver 13S page 1, Series column Mega China

External links

• China Compulsory Certification (CCC) China-Britain business council

• Some certification agents:
  • CCC China Compulsory Certification
  • CCC Catalogue
  • China-Certification CCC
  • CCC US OFFICE
  • CSA/CCIC Customer Service Center
  • TÜV Rheinland Group
  • TÜV SÜD America Inc.
  • SIQ Ljubljana, Slovenia
• Standardization Administration of the Peoples Republic of China
• Chinese certification of information security products
• Full list of CCC applicable product, in Japanese 28 August 2009 Edition (In Japanese) web site of JET:Japan Electrical Safety & Environment Technology Laboratories (電気安全環境研究所)
• Foreign-made, intellectual and IT security, products procurement policy
  • USTR Releases 2010 Special 301 Report on Intellectual Property Rights
  • ABC NEWS - Geithner to Press China on Trade Barriers, Yuan 7th paragraph; "American companies are very concerned that this approach has the potential to discriminate against foreign-made products and could disadvantage American exporters and investors as they compete with Chinese firms," Geithner said. "We share these concerns." (May 18, 2010)
  • Strategic and Economic Dialogue Closing Statement, Treasury Secretary Tim Geithner, Beijing, China As Prepared for Delivery on May 25, 2010 (United States Department of the Treasury)