CCC certification for Ex products in China
Per May 1, 2023, the CCC Ex certification standards have changed
The applicable GB/T 3838-xx certification standard versions are now aligned with the latest editions of the IEC 60079-xx standards.
The new GB/T 3836-xx certification standard editions are mostly version 2021.
These new GB/T 3836-xx-2021 standard versions can be found at www.chinesestandard.net Link
Questions and Answers regarding CCC Ex certification
1. Will CCC Ex certificates issued before 1 May, 2023 remain valid for the 5 year period mentioned on the certificate?
Yes, but only if they have been issued based on the valid GB/T 3836.xx-2021 standards.
CCC Ex certificates based on the previous GB 3836.xx-2010 standards are not valid anymore after 1 May 2023. These certificates will be suspended for a period of 3 months and subsequently revoked, unless the certificate holder applies for an update or cancellation of these certificates during the 3 month period while they are suspended. Please note, after being revoked, a new certificate can only be applied for again after a period of 6 months. After cancellation, a new certificate can be applied for at any time.
2. CCC Ex certificates issued after 1 May, 2023 and based on existing IECEx certificates must comply with the latest / current IEC standards, correct?
Yes, correct:
Either, the IECEx certification must be based on the latest IEC standards,
Or, an additional product evaluation is necessary to determine the product compliance with the latest / current IEC standards.
3. CCC Ex certificates issued after 1 May, 2023 and based on existing ATEX certificates must comply with the latest / current EN standards, correct?
No, only partially correct:
Either, the EN standards applied must be based on the latest IEC standards,
Or, an additional product evaluation is necessary to determine the product compliance with the latest / current IEC standards.
Note:
The CCC Ex certification based on ATEX certification is only possible for ATEX certificates that were issued by an ATEX NB that CNEx/CQST has a bilateral cooperation agreement with.
4. The mandatory CCC Ex Factory Inspection can be covered by a valid IECEx QAR, correct?
No, CCC Ex Factory Inspections must be done on site at the manufacturer's location.
Notes:
- Part of the quality system requirements for CCC Ex Factory Inspections can be covered by a valid IECEx QAR.
- The latest complete IECEx QAR audit report is one of the documents that must be submitted to CNEx.
5. Will China-Ex (non-CCC) certificates issued before 1 May, 2022 remain valid for the 5 year period mentioned on the certificate?
Yes, China-Ex certificates for products not in the CCC catalogue will remain valid for the stated 5 year period.
6. Changing a manufacturer’s legal entity does not require a new Factory Inspection, correct?
Yes, correct, if the manufacturer only changes his legal entity, a new Factory Inspection is not required, but the CCC Ex certificates need to be updated for the new manufacturer name.
General information on CCC Ex certification
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 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:
1. The Type Test (Ex-product evaluation, testing and certification)
2. The Initial Factory Inspection
3. The Post-Certification Supervision (surveillance inspections and re-assessment inspections)
Regarding point 1. The Type Test (Ex-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/T 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.
Important note: A valid CNEx product certificate can be used to cover this Type Test.
Regarding point 2 and point 3:
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 mandatory Initial Factory Inspection must be covered by having CNEx Inspectors do the complete onsite inspection covering quality system and production quality aspects per CNEx Guideline on Implement Rules for CCC-Ex - Annex 3.
Important change:
The frequency of the Post-Certification Supervisions is NOT necessarily 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 (see below).
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.
Auditing frequency
The mandatory frequency of Surveillance Audits and Re-Assessment audits is linked to the Company Classification.
The relation between Quality Management System, Classification and audit frequency, is as follows:
Quality System Audit Frequency
A Once every two years
B Once every 1.5 years
C Once a year
D Twice a year
IECEx and ATEX audit cycles can 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.
The rules for the production quality at the manufacturer’s facilities are covered in the document
CNCA-00C-005-2014 - Compulsory Certification Implementation Rules – Factory Quality Assurance Ability Requirements.
The rules for the assessment of the production quality at the manufacturer’s facilities are covered in the document CNCA-00C-006-2014 - Compulsory Certification Implementation Rules – General Requirements for Factory Inspection and Auditing.
See link to CNCA website (in Chinese only): Link
Important change:
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.
The audits are an integral part of the product certification, thus the audits MUST be done by the SAME Chinese ExCB that does the product certification. CNEx in Nanyang is a leading CCC Ex-Certification Body.
The sample tests or inspections at the production site should cover the Ex-types and product types of the product to be certified. If deemed necessary, the selected samples can be tested/inspected at the designated testing laboratory.
Non-Electrical (parts of-) Ex products
Non-electrical (parts of-) Ex products are not covered in CCC Ex and require NO CCC Ex product certification.
See link to China National Standards website: Link
Notes
An Ex-product that is certified to the current IEC standards for Ex-products, will in most cases also comply with the technical requirements of the GB/T standards for Ex-products.
Classification of Ex-products in (17) categories
see the Product Catalogue document.
Latest Questions and Answers from CNEx, Nanyang, China:
7. Question: Should gas detectors be CCC Ex certified?
Answer: NO, gas detectors do not require CCC Ex-certification, but should be certified to the relevant Chinese Ex-standards.
8. Question: Should low voltage equipment and components/parts, with a rated voltage of <36V, be CCC Ex certified?
Answer: YES. The product scope of the CCC Ex certification does include rated voltages <36V. Such as for products in category 2315, the product voltage could be less than <36V.
9. Question: Can mechanically operated electrical switches, that are powered from an intrinsically safe voltage source, be considered to be ‘simple apparatus’ conform the IEC 60079-11 and GB/T 3836.4, so that they do therefore NOT need to be CCC Ex certified?
Answer: YES. If the mechanically operated electrical switch powered by an intrinsically safe power supply, is defined as a "simple apparatus " according to the IEC60079-11 and GB/T 3836.4 standards, the product may not have an explicit Ex marking (IEC60079-11 Clause 5.7 and GB/T 3836.4 Clause 5.7 have provisions). In that case it is not necessary to obtain the CCC certification.
However, if the product is clearly an Ex switch, it is recommended for customers to apply for CCC Ex certification.
10. Question: Can all resistive temperature sensors (for windings, bearings and air temperature measurements), that have no internal ignition source, be considered as ‘passive’ simple apparatus conform the IEC 60079-11 and GB/T 3836.4, so that they do therefore NOT need to be CCC Ex certified?
Answer: YES. If the temperature sensors are defined as a "simple apparatus" according to the IEC60079-11 and GB/T 3836.4 standards, the product may not have an explicit Ex mark (IEC60079-11 Clause 5.7 and GB/T 3836.4 Clause 5.7). In that case it is not necessary to obtain the CCC certification.
11. Question: Must equipment in explosion protection ‘constructive safety Ex h’, for non-electrical equipment, be CCC Ex certified?
Answer: NO, non-electrical equipment is not required to be CCC Ex certified.
However, for electric + non-electric combination products, if the electric product is included in the scope of the CCC list, CCC Ex certification is required. For example, the oil & gas recovery pump (2302), the Ex marking is usually Ex d h, and the CCC certificate issued by CNEx will indicate that the non-electric part (Ex h) is excluded.
12. Question: Must Ex ec equipment be CCC Ex certified?
Answer: YES. If the product using Ex ec (equal to GB/T standard Ex nA type), is included in the Product Catalogue for CCC Ex, then the product must be CCC Ex certified.
However, if the product is not included in the Product Catalogue for CCC Ex, then CCC Ex certification is not required.
13. Question: Must ‘self-declared’ Category 3 ATEX electrical equipment be CCC Ex certified if that equipment is to be used in China?
Answer: YES. CCC Ex certification has no ‘self-declared’ certification option. If the product is included in the Product Catalogue, the product must be CCC Ex certified.
14. Question: Equipment that is not specifically named in the CCC Ex Product Catalogue (like ‘Flow meters’), does NOT need to be CCC Ex certified?
Answer: NO. The product " Flow meters " is not included in the scope of the CCC product list, and thus they need not be CCC Ex certified.
15. Question: Can products be ‘Unit Verification’ certified under the CCC Ex regulation? (thus without the Factory Inspections?)
Answer: NO. The CCC Ex certification model does not include " Unit Verification " at this stage. Products that have an IECEx / ATEX Unit Verification certificate, will be handled as normal CCC Ex certifications, including the mandatory Factory Inspection of the production.
16. Question: Are (signal-) Transmitters and (ring-core) current transformers necessary to be certified for CCC Ex?
Answer: NO/YES.
NO: The product " (signal-) Transmitters " is not included in the scope of the CCC product list, and thus they need not be CCC Ex certified.
YES: The product " (ring-core) current transformers " is included in the scope of the CCC product list, and thus they need to be CCC Ex certified.