News: CCC for Ex

CCC certification for Ex products in China

(Last update: 23 June 2020)

Latest information:

Postponement of the October 1, 2020 deadline for the implementation of the CCC Ex certification rules will be decided and communicated by CNCA in September 2020, according to sources related to CNCA. 

 

Per June 18th, 2020, CNEx in China allows for non-Chinese Ex-product manufacturers, that the mandatory Initial Factory Inspection can be covered in three ways:


Option 1. 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, or


Option 2. By having CNEx Inspectors do the part remote inspection (by video meeting tools) covering only quality system aspects, or

Option 3. By the manufacturer submitting the following documentation:

1. a copy of the valid IECEx QAR that covers the manufacture of the products to be CCC Ex
certified by CNEx, and

2. a filled-out checklist, which confirms the compliance of the manufacturer quality system with the quality system requirements of the CNEx Guideline on Implement Rules for CCC-Ex - Annex 3.


Important Notes:
The Inspection per Option 1 is valid for the complete duration of the CCC Ex product certificate.
The Inspections per Options 2 and 3 above, are valid only for the duration of the COVID-19 crisis plus 6 months. After the COVID-19 crisis is declared to be over, the manufacturer shall seek to arrange the mandatory onsite CCC Ex IFI audit by CNEx (per Option 1), to be completed within 6 months (thus the onsite CCC Ex IFI audit would need to be conducted no later than in the 5th month).

Latest Questions and Answers from CNEx, Nanyang, China:

10.
Question: Must all Ex components/parts that are to be installed in CCC Ex certified equipment, also be CCC Ex certified themselves?


Answer: YES.
But, for CCC Ex motor certifications of IECEx certified motors, initiated at CNEx before the formal CCC Ex implementation deadline (now at Oct. 01, 2020), the following applies:
Installed components/parts that are covered by an IECEx certificate and for which the necessary IECEx test reports are available, need NOT be CCC Ex certified at the time of the CCC Ex certification of the Ex motor, but must get that CCC Ex certification soon afterwards. The supplier of the components/parts must confirm that the CCC Ex certification of his supplied components/parts will be initiated.

9.

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.

8.
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 GB3836.4, 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 GB3836.4 standards, the product may not have an explicit Ex marking (IEC60079-11 Clause 5.7 and GB3836.4 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.

7.

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 GB3836.4, 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 GB3836.4 standards, the product may not have an explicit Ex mark (IEC60079-11 Clause 5.7 and GB3836.4 Clause 5.7). In that case it is not necessary to obtain the CCC certification.

6.
Question: Must equipment in explosion protection ‘constructive safety Ex h’, for non-electrical equipment, be CCC Ex certified?

Answer: NO. There are only 14 standards (GB3836.1~9, GB12476.1~5) for products subject to CCC Ex certification. GB25286 non-electrical standards are not included. Therefore, 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.

5.
Question: Must Ex ec equipment be CCC Ex certified?
Answer: YES. If the product using Ex ec (equal to GB standard Ex nA type), is included in the scope of the CCC list, then the product must be CCC Ex certified.
However, if the product is not included in the scope of the CCC list, CCC Ex certification is not required.

4.
Question: Must ‘self-declared’ Category 3 ATEX electrical equipment, and/or Category 2/3 ATEX non-electrical equipment, be CCC Ex certified if that equipment is to be used in China?

Answer: YES. The 14 standards of CCC Ex certification (GB3836.1~9, GB12476.1~5) have no ‘self-declared’ certification option. If the product is included in the scope of the CCC list, the product must be CCC Ex certified.
However, for non-electrical equipment, it is not necessary to apply for CCC Ex certification (refer to point 4 above).

3.
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.

2.
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.

1.
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 be CCC Ex certified.

Basic CCC Ex information:

Per October 01, 2020, most Ex-products sold in China have to be covered by a new CCC Ex-product certification.

This new regulation applies to all products listed in the existing catalogue from the Production Licence procedure. Some products, like LED lighting apparatus, are not included in this catalogue and therefore exempt (for now) from this new regulation.

Most important change:
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!

Basic Rules
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 audits and Re-Assessment audits)

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 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.

Important change:
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 (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

NB 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. 

Depending on the Classification, the audit covers the following inspection content:

Classification Inspection Content
A                       Supervision inspection, or sample tests or inspection at the production site
B                      Supervision inspection and/or sample tests or inspection at the production site
C                      Supervision inspection and sample tests or inspection at the production site
D                      Supervision inspection and sample tests or inspection at the production site

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. The IECEx ExTL and ExCB CQST in Nanyang is also 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
The above stated GB standards are derived from the IEC certification standards for Ex-products. The Gb standard versions are in most cases technically equivalent to (the previous version of -) the current IEC standards.

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 standards for Ex-products.

In the same way as an ATEX certificate is mandatory for Ex-products marketed and sold in Europe, a Chinese Ex-certificate is mandatory for Ex-products marketed and sold in China.

Important change: The Ex-product must be marked with:

Classification of Ex-products in (17) Categories 

Category

Product

Category

Product

1

Ex motors

10

Ex communication, signal devices

2

Ex pumps

11

Ex air conditioning, ventilation system

3

Ex power distribution devices

12

Ex electrical heating devices

4

Ex switches, control and protective device

13

Ex accessories, Ex components

5

Ex starters

14

Ex instruments

6

Ex transformers

15

Ex sensors

7

Ex actuators, valves

16

Safety barriers

8

Ex plugs and sockets

17

Ex instrument cabinets

9

Ex monitoring devices

 

 

 

 





Previous Questions and Answers from CNEx, Nanyang, China:

1. What new legislation is going to apply for Ex-products in China?

Regulation CNCA-C23-01: 2019.

2. When will the new Regulation become law?

It will become Chinese Law per October 01, 2019.

3. Does it apply to Ex-products manufactured inside China?

Yes, it applies to all Ex-products listed in the Product Catalogue for Ex-products in China.

4. Does it apply to Ex-products manufactured outside China?

Yes, see answer 3 above.

5. When will all Ex-products in China have to comply with the new Regulation?

Per October 01, 2020.

6. What has changed under the new Regulation, compared to the previous Ex-product certifications?

The new CCC Ex Regulation for Ex-products is a mandatory conformity certification activity, applicable to all Ex-products listed in the Product Catalogue, sold in China.

7. What has changed under the new Regulation, compared to the previous Ex-production quality  certifications?

The new CCC Ex Regulation for Ex-products now specifically includes initial audits and follow-up audits, applicable to all Ex-products  listed in the Product Catalogue, sold in China. The certification module is:

Ex-Type Examination + initial audit + follow-up audit

8. Are there Ex-products exempt from this new Regulation?

Yes, those Ex-products that are not listed in the Product Catalogue (for example: Ex LED lights).

9. How / where can we find more information or guidance to this new Regulation?

A guideline will be published after the Regulation becomes effective. Details will then be added on the CNEX-Global website.

10. We have an existing valid CNEx certificate. Do we need a new Ex-product certificate to comply with this new legislation?

Yes. However, an existing valid CNEx Certificate could be accepted by CNEx as the Ex-type Examination Report for the new CCC Ex certificate.

11. We have a valid IECEx QAR and/or ATEX QAN for our production quality. Do we need a new Ex-production quality certificate to comply with this new legislation?

Yes.  The audit team will check the production quality at the manufacturer according to the requirements of the regulation:

CNCA-00C-005-2014 - Compulsory Certification Implementation Rules – Factory Quality Assurance Ability Requirements.

12. We have a new Ex-product that we want to sell in China. What should we do?

Apply for the new CCC Ex certification of the product according to the new regulation. An Application Form for this can be downloaded from our website at:

www.cnex-global.com.

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