Standards and Compliance EU SME Topics

Regardless of whether a product is imported or produced domestically, it is often required to obtain specific certificates, marks or licenses in advance in order to be granted market access. Certification, marks and licensing schemes in China are based on various technical standards, and generally involve factory, production and quality management systems. These could be:

• Vertical, i.e. applying to specific sectors or products only, such as the Radio Type Approval / SRRC for telecoms equipment; cosmetics registration certificate; SAMR registration certificate for infant formula and health food; etc.
• Horizontal, i.e. applying for certain features or characteristics of products found across many industries, such as the China Compulsory Certification (CCC), China Energy Label, China RoHS II, etc.

Certificates, marks and licenses are generally mandatory: goods cannot be sold without obtaining them. There are, however, a number of certification schemes that are voluntary (e.g., China’s Green Product Certification), yet they are strongly recommended as they often constitute the basis on which government incentives and subsidies are granted, or public procurement decisions made; and they are also a strong driver for marketing activities.

In general, electronic and energy-consuming products face the highest requirements, together with those products targeted for and used by children. But it must be kept in mind that, even within a sector, specific products or subcategories may be exempted from such certification or subject to lighter procedures (e.g. self-declaration rather than third-party certification). EU SMEs must examine in detail all the technical requirements applicable to their products and usage. Finally, relevant producers will also need to comply with other relevant standards, e.g. in terms of labelling, packaging, limits of hazardous substances, etc.

EU SMEs can visit the website of the Seconded European Standardisation Expert in China (SESEC)), a project co-funded by the EU providing information on Chinese standards and technical regulations.

Finding relevant Chinese standards for one product is not an easy task: it requires knowledge of China’s standardisation system and Chinese language. We strongly suggest working with professionals in this field, or to visit the website of the Seconded European Standardisation Expert in China (SESEC)), a project co-funded by the EU providing information on Chinese standards and technical regulations.

A preliminary search can be done through the National Public Service Platform for Standards Information: http://std.samr.gov.cn/.  Users may try to type in the query tool the key words in English, as for each standard issued and published on the platform, the translation of the standard’s name in English is always provided. However, translations are not always entirely accurate. Alternatively, the ‘advanced search’ tool can be used for a more targeted search based on various criteria. The full text of Chinese standards is usually published, in Chinese language, only for mandatory (GB) standards, on the dedicated platform: http://openstd.samr.gov.cn/bzgk/gb/index.

It is very rare that official translations in English of Chinese standards are produced, and if so, it is limited to Chinese standards which are being strongly pushed by the government to become the basis for new international standards, or for standards in countries where its exports are strong (e.g. electric vehicles in Belt and Road countries). In some occasions, unofficial translations in English are done by foreign embassies or chambers of commerce in China. There are also unofficial databases for certain sectors, especially food and beverage.

Many types of products and services may require government approval before they can be imported in the Chinese market. One of these compulsory requirements is the China Compulsory Certificate (CCC) scheme, which applies to certain products and systems that are sold in China and that present health, safety and environmental protection risks. This is regardless of whether the product/system has been produced domestically in China, or has been imported. Any product or system that requires the CCC mark must undergo an inspection, testing and certification procedure.

As of 23 September 2025, CCC is required for 109 items under 17 product categories, namely: (i) wires and cables; (ii) circuit switches and electrical devices for protection and connection; (iii) low-voltage apparatus; (iv) low power motors; (v) electrical tools; (vi) electric welders; (vii) equipment for household and similar uses; (viii) electronic products and safety accessories; (ix) lighting appliances; (x) motor vehicles and safety accessories; (xi) agricultural machinery; (xii) fire products; (xiii) building material products; (xiv) children products; (xv) explosion-proof materials; and (xvi) household gas appliances, and (xvii) electric vehicle conductive supply equipment. In general, it can be said that products and systems requiring CCC mark are consumer products for personal/domestic use; industrial products for commercial use usually do not require CCC mark (but must comply with other factory- or work safety-related regulations). Products with low safety risks are also generally exempted from CCC mark – such as those with low-voltage (generally <12 volts).

To obtain the CCC certification, there are currently two different conformity assessment procedures in place. The first step, therefore, is to identify within the CCC Catalogue the specific procedure applicable to the product, after ensuring that the product fully meets all the required technical standards.

• Third-party certification: for products with high safety risks and close contact with final consumers.
• Self-declaration: for products with stable quality and low safety risk. This method is, in turn, further divided into method A (allowing type test to be done in any labs recognised by CNAS or members of ILAC + self-declaration), and method B (requiring type test to be done in specifically designated CCC labs + self-declaration). The first step is to check the CCC Catalogue to determinate which specific procedure applies to the concerned product.

The main difference between the two methods thus relates to the stricter and longer procedure for third-party certification, which involves factory inspection as well as technical evaluation by a certification agency. The entire process for third-party certification may take several months, with costs depending on various factors such as product’s components, selection of models, variations in critical components, use of spare parts and consumables, and fees if working with intermediary agencies.

Certification in China ensures compliance with local standards through factory audits, technical documentation, and product testing. Only officially registered TIC (Testing, Inspection, and Certification) bodies in China can conduct conformity assessments, and must necessarily obtain China Metrology Accreditation (CMA) certification. Therefore, conformity assessment results obtained from overseas testing, inspection and certification (TIC) bodies are generally not recognised by the Chinese authorities or certification bodies.

At the same time, even TIC bodies legally established in China must be accredited in order to be allowed to conduct testing or issue certification. In practice, most certification schemes in China can be released only by a limited number of officially accredited bodies, which usually do not include foreign TIC bodies legally established in China; these, however, may accept test results from different laboratories in China, which may or may not include foreign ones legally established in China. For instance, CCC certification can only be released by 35 officially recognised certification bodies – none of them is foreign-invested; these certification bodies might accept test results from 243 officially recognised laboratories, 6 of which are foreign-invested. Still, some Chinese TIC bodies may have – out of their own initiative – established partnerships with European laboratories and mutually recognise test results; a number of Chinese TIC bodies have also established subsidiaries in the EU and may offer their services there.

Among Chinese labs, there is strong preference from Chinese customers and even customs enforcement authorities for reports released by Chinese labs which have obtained CNAS accreditation (which, in most cases, is voluntary, with the exception of CCC self-declaration B and third-party certification).

In general, according to China’s Consumer Rights Protection Law (Art. 23) and Product Quality Law (Art. 40), it is the responsibility of the operators, which includes the importer and/or distributor, as well as the manufacturer.

The Chinese consumer (buyer) seeks compensation from the operator which is legally based in China (usually, the importer or the distributor), through different means such as amicable negotiations, or legal action/arbitration if necessary (incl. through consumers’ rights protection associations and relevant market supervision authorities). Eventually, the operator (importer or distributor) will seek compensation from the manufacturer, through means which are normally regulated in the sales contract in place. This includes possible legal action/arbitration. If the manufacturer has no legal entity (or any assets) in China, of course it will be difficult for Chinese consumers and courts to enforce their decisions, they have to go through courts where the manufacturer has a legal entity or has assets.

In any case, if the manufacturer refuses to cooperate, its future sales/operations in China will be negatively affected (e.g. products not cleared at the customs; inclusion in negative lists of relevant market supervision authorities, etc).