CCC Ex Certification for China
These new CCC Ex-certification rules will apply to the Ex-production quality of manufacturing done inside China and to the Ex-production quality of manufacturing done outside China. Having a valid ATEX QAN and/or IECEx QAR is not sufficient, the audit must be performed by a qualified and listed CCC Auditor. The audits at the manufacturing location can only be done by CCC Ex-auditors that are appointed by the Chinese CCC Ex-Certification Bodies and that are recognised by the CCAA. ExVeritas are qualified in this regard and can conduct the necessary CCC Audits in parallel with our other Audit activities where necessary. The basic principles and requirements of the new certification rules are stated in document CNCA-C23-01:2019 – Compulsory Certification Rules – Explosion protected electrical Equipment (also called ‘CCC Ex’). The Ex-product must be marked with the ‘CCC’ Mark.
The CCC certification process
The CNCA-C23-01:2019 regulation requires that all Ex-products listed in the product catalogue, irrespective of the place of manufacture, must be assessed in a three-step CCC certification process:
- The Type Test (Ex-product evaluation, testing and certification)
- The Initial Factory Inspection
- The Post-Certification Supervision (Surveillance audits and Re-Assessment audits)
Until now, manufacturers that sold Ex-products inside China, but manufactured these Ex- products outside China, were exempt from CCC and thus exempt from steps 2 and 3, if they had a correct, valid QAN/QAR covering their Ex-product manufacturing quality. Under the new CCC rules, the full 3-step CCC certification process will apply also to them.
The Type Test (product evaluation, testing and certification)
This process remains largely unchanged in practice, because the basis of the product evaluation and testing will be the Chinese GB certification standards, which are derived from the IEC certification standards for Ex-products, as is the case at present. The CCC Ex- certificate is valid for 5 years and recertification must be initiated minimum 90 days before the expiry date. Normally ExVeritas will use the IECEx Certification (TR) for the Type Testing.
The frequency of the Post-Certification Supervisions is NOT in line with IECEx/ATEX production quality audit rules. Instead, the frequency of the Surveillance and Re-assessment audits depends on the Classification of the Company. A company is classified as a Type A, B, C, D company, based on the status of the quality system of the manufacturer. This classification is done by the CCC Ex Certification Body chosen by the manufacturer. The rules for this Classification of the Company are stated in document CNCA-00C-003-2014 – Compulsory Certification Implementation Rules – Manufacturer Classification Management, Selection and Determination of Certification Mode.
IECEx and ATEX audit cycles be aligned with CCC Ex Factory Inspections: for Class B manufacturers (the most common class), the audit frequency is 18 months, which could be synchronized with IECEx and ATEX audits. This means that for every three FIs, there is a reassessment (6 months in advance of the 5-year validity mark) that allows the audit schedule to be always aligned with the IECEx / ATEX schedule.