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Is it illegal to apply the CCC mark to an uncertified product?
Date：2022/4/21 Clicks：887
Can the CCC mark be applied to the products in the compulsory product certification catalogue before obtaining the certificate? Will the factory inspection determine that the factory inspection fails? Will there be administrative penalties after the law enforcement inspection finds out?
The CCC mark is printed/molded on the product, such as the molding mold of motor vehicle tires, the printing wheel of wire and cable, if the mold is modified and changed after the certificate is obtained, it will be time-consuming, labor-intensive and expensive, and it is not in line with the spirit of the State Council to reduce the burden on enterprises. , how does the enterprise need to manage and control to meet the certification requirements?
The CCC mark is applied when the parts factory is entrusted to process. For example, the CCC mark of the automobile lamp is injection-molded on the light distribution lens by the outsourcing factory. Does it meet the requirements and how to control it?
Can the CCC logo be printed on the outer packaging of the product before obtaining the certification?
When to apply the CCC mark
CNCA Announcement No. 10 in 2018 "Requirements for the Administration of the Application of Compulsory Product Certification Marks"
Article 2: "The products listed in the "Catalogue" must be certified and affixed with the CCC mark before they can leave the factory, import, sell and use in business activities."
Article 8: "The CCC mark can be applied to the outer packaging of the certified products. The CCC mark must be applied to the products produced overseas and certified before import; the products produced domestically and certified must be shipped from the factory. The CCC logo is applied before.”
The above two clauses clarify the timing of applying the CCC mark by domestic manufacturers: before leaving the factory. It only emphasizes two conditions for certified products to leave the factory: obtaining certification, applying the CCC mark, and whether the certificate has been obtained or not has no direct sequence relationship. Therefore, it is allowed to apply the CCC mark at any link before leaving the factory. Enterprises can pre-design molds with the CCC logo, entrust outsourcing to process parts and components with the CCC logo, or print the outer packaging with the CCC logo in advance.
However, allowing the CCC mark to be applied at any link before leaving the factory does not mean that the enterprise can apply it at any link before leaving the factory. The relevant normative documents for mandatory product certification have further control requirements for this. Wrong application of the CCC mark may lead to the conclusion that the certification body fails the factory inspection during the factory inspection, so that the certificate cannot be obtained or the certificate is suspended.
"Compulsory Product Certification Implementation Rules General Requirements for Factory Inspection" (CNCA-00C-006)
10. Special requirements for the application of the CCC mark
10.1 Requirements for applying the CCC mark in the production process
For those that need to apply the CCC mark in the production process, such as motor vehicle tires, wires and cables, etc., the certification body should focus on and control the following possible risks, and take appropriate and necessary measures to avoid their unintended use or delivery:
(a) Products with undetermined status between the application of the CCC mark and the routine inspection;
(b) Non-conforming products that have been marked with CCC.
10.2 Requirements for entrusting relevant parties to print and emboss the CCC mark
For factories that entrust relevant parties to print and mold the CCC mark, for example, a motor vehicle lighting manufacturer entrusts a photometric lens manufacturer to mold the CCC logo on the surface of the photometric lens, the certification body should focus on the following risks, and take appropriate and necessary measures. Measures to keep the risk under control:
(a) Whether the activities of relevant parties to apply the CCC mark are controlled and meet the specified requirements;
(b) Unintended use or delivery of non-conforming products bearing the CCC mark;
(c) Whether the qualified products with the CCC mark are only used for delivery to the production enterprise;
(d) Whether the products with the CCC mark printed and molded by the relevant parties are included in the compulsory product certification catalogue.
Risks that certification bodies need to focus on and control, which means that companies need to have clear control measures to prevent related risks for products that are marked with the CCC mark before certification, such as uninspected products with the CCC mark, semi-finished products, spare parts, For non-conforming products, not only need to formulate detailed control documents, but also need to have truthful use records.
"Management Requirements for the Application of Mandatory Product Certification Marks"
Article 9: "A certified enterprise shall establish a system for the use and management of the CCC mark, and truthfully record and archive the use of the CCC mark."
The regulations require companies to record and file the use of the CCC mark truthfully no matter when and where they apply the CCC mark. This clause is also the key content of the conformity and normative inspection of the use of the CCC mark by the certification body. During the factory inspection, if the use and management system of the CCC mark is unreasonable, or the relevant records cannot be provided truthfully, it is impossible to prove that the use of the CCC mark has been effectively controlled, and it is very easy to touch the "illegal use of the CCC mark". Factory inspection failed the red line.
"Compulsory Product Certification Implementation Rules Factory Quality Assurance Capability Requirements"
(CNCA-00C-005)”
3.11 CCC certificate and mark
The management and use of the CCC certificate and mark by the factory shall comply with the "Compulsory Product Certification Management Regulations", "Compulsory Product Certification Mark Management Measures" and other regulations. For the uniformly printed standard specification CCC mark or the CCC mark applied by printing, molding, etc., the factory shall keep the usage records. For the following products, the CCC mark or release shall not be applied:
(a) Products in the catalogue of compulsory product certification that have not been certified;
(b) The change after certification needs to be confirmed by the certification body, but the product has not been confirmed;
(c) Products beyond the validity period of certification;
(d) Products listed in the certificate that have been suspended, revoked or cancelled;
(e) Nonconforming Products.
Factory quality assurance capability is the certification rules that factories applying for CCC certification must abide by. The above clauses clarify the management requirements for the CCC mark and certificate. For the products that do not meet the certification requirements in the example, there are two restrictions on the management and control of the CCC mark, one is "not imposed", the other is "not released", Enterprises should formulate a management system for the use of the CCC mark according to the actual situation, and take appropriate control measures to meet the requirements of CCC certification. The focus of the certification body during the factory inspection is to first check whether the enterprise has applied the CCC mark to the products that should not be marked with the CCC mark; if the mark is applied, further check whether the enterprise has corresponding control measures and related records. , confirming that there is no risk or possibility of release. Finally, determine whether the use of the CCC logo of the enterprise meets the certification requirements.
The CCC mark is printed/molded on the product, such as the molding mold of motor vehicle tires, the printing wheel of wire and cable, if the mold is modified and changed after the certificate is obtained, it will be time-consuming, labor-intensive and expensive, and it is not in line with the spirit of the State Council to reduce the burden on enterprises. , how does the enterprise need to manage and control to meet the certification requirements?
The CCC mark is applied when the parts factory is entrusted to process. For example, the CCC mark of the automobile lamp is injection-molded on the light distribution lens by the outsourcing factory. Does it meet the requirements and how to control it?
Can the CCC logo be printed on the outer packaging of the product before obtaining the certification?
When to apply the CCC mark
CNCA Announcement No. 10 in 2018 "Requirements for the Administration of the Application of Compulsory Product Certification Marks"
Article 2: "The products listed in the "Catalogue" must be certified and affixed with the CCC mark before they can leave the factory, import, sell and use in business activities."
Article 8: "The CCC mark can be applied to the outer packaging of the certified products. The CCC mark must be applied to the products produced overseas and certified before import; the products produced domestically and certified must be shipped from the factory. The CCC logo is applied before.”
The above two clauses clarify the timing of applying the CCC mark by domestic manufacturers: before leaving the factory. It only emphasizes two conditions for certified products to leave the factory: obtaining certification, applying the CCC mark, and whether the certificate has been obtained or not has no direct sequence relationship. Therefore, it is allowed to apply the CCC mark at any link before leaving the factory. Enterprises can pre-design molds with the CCC logo, entrust outsourcing to process parts and components with the CCC logo, or print the outer packaging with the CCC logo in advance.
However, allowing the CCC mark to be applied at any link before leaving the factory does not mean that the enterprise can apply it at any link before leaving the factory. The relevant normative documents for mandatory product certification have further control requirements for this. Wrong application of the CCC mark may lead to the conclusion that the certification body fails the factory inspection during the factory inspection, so that the certificate cannot be obtained or the certificate is suspended.
"Compulsory Product Certification Implementation Rules General Requirements for Factory Inspection" (CNCA-00C-006)
10. Special requirements for the application of the CCC mark
10.1 Requirements for applying the CCC mark in the production process
For those that need to apply the CCC mark in the production process, such as motor vehicle tires, wires and cables, etc., the certification body should focus on and control the following possible risks, and take appropriate and necessary measures to avoid their unintended use or delivery:
(a) Products with undetermined status between the application of the CCC mark and the routine inspection;
(b) Non-conforming products that have been marked with CCC.
10.2 Requirements for entrusting relevant parties to print and emboss the CCC mark
For factories that entrust relevant parties to print and mold the CCC mark, for example, a motor vehicle lighting manufacturer entrusts a photometric lens manufacturer to mold the CCC logo on the surface of the photometric lens, the certification body should focus on the following risks, and take appropriate and necessary measures. Measures to keep the risk under control:
(a) Whether the activities of relevant parties to apply the CCC mark are controlled and meet the specified requirements;
(b) Unintended use or delivery of non-conforming products bearing the CCC mark;
(c) Whether the qualified products with the CCC mark are only used for delivery to the production enterprise;
(d) Whether the products with the CCC mark printed and molded by the relevant parties are included in the compulsory product certification catalogue.
Risks that certification bodies need to focus on and control, which means that companies need to have clear control measures to prevent related risks for products that are marked with the CCC mark before certification, such as uninspected products with the CCC mark, semi-finished products, spare parts, For non-conforming products, not only need to formulate detailed control documents, but also need to have truthful use records.
"Management Requirements for the Application of Mandatory Product Certification Marks"
Article 9: "A certified enterprise shall establish a system for the use and management of the CCC mark, and truthfully record and archive the use of the CCC mark."
The regulations require companies to record and file the use of the CCC mark truthfully no matter when and where they apply the CCC mark. This clause is also the key content of the conformity and normative inspection of the use of the CCC mark by the certification body. During the factory inspection, if the use and management system of the CCC mark is unreasonable, or the relevant records cannot be provided truthfully, it is impossible to prove that the use of the CCC mark has been effectively controlled, and it is very easy to touch the "illegal use of the CCC mark". Factory inspection failed the red line.
"Compulsory Product Certification Implementation Rules Factory Quality Assurance Capability Requirements"
(CNCA-00C-005)”
3.11 CCC certificate and mark
The management and use of the CCC certificate and mark by the factory shall comply with the "Compulsory Product Certification Management Regulations", "Compulsory Product Certification Mark Management Measures" and other regulations. For the uniformly printed standard specification CCC mark or the CCC mark applied by printing, molding, etc., the factory shall keep the usage records. For the following products, the CCC mark or release shall not be applied:
(a) Products in the catalogue of compulsory product certification that have not been certified;
(b) The change after certification needs to be confirmed by the certification body, but the product has not been confirmed;
(c) Products beyond the validity period of certification;
(d) Products listed in the certificate that have been suspended, revoked or cancelled;
(e) Nonconforming Products.
Factory quality assurance capability is the certification rules that factories applying for CCC certification must abide by. The above clauses clarify the management requirements for the CCC mark and certificate. For the products that do not meet the certification requirements in the example, there are two restrictions on the management and control of the CCC mark, one is "not imposed", the other is "not released", Enterprises should formulate a management system for the use of the CCC mark according to the actual situation, and take appropriate control measures to meet the requirements of CCC certification. The focus of the certification body during the factory inspection is to first check whether the enterprise has applied the CCC mark to the products that should not be marked with the CCC mark; if the mark is applied, further check whether the enterprise has corresponding control measures and related records. , confirming that there is no risk or possibility of release. Finally, determine whether the use of the CCC logo of the enterprise meets the certification requirements.
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