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What is CCC Self-Declaration?

The China Compulsory Certificate Self-Declaration is a mandatory certification for certain specific products in China. It is a different format of the CCC certification and requires a different certification process than the standard CCC certification process. It is important to note that CCC Self-Declaration is only possible for certain types of product categories and is not interchangeable with products that require CCC. Also, products that are required to have CCC Self-Declaration cannot apply for the standard CCC certification. They are two different types of certifications and have separate processes. The CCC Self-Declaration is also often known as China Self-Declaration, CCC Declaration of Compliance (DoC), CCC Supplier Declaration of Conformity (SDoC), CCC Self-Declaration of Compulsory Product Certification, CCC Self-Declaration Certification. With the CCC Self-Declaration, the manufacturer declares that their manufactured products comply with the GB standards and that product conformity is continuously ensured and maintained in accordance with Chinese regulations. Products subject to CCC Self-Declaration may be sold or used in the Chinese market only after the Self-Declaration has been issued.

The CCC SDoC is like a slimmer format of the standard CCC certification with applications, supporting documentation and testing. Unlike the standard CCC certification initial factory audits and annual audits are not required for CCC Self-Declaration. Due to this, manufacturers and applicants have a significantly higher risk since product conformity is not continuously monitored by the authorities. Simple “non-conformities” or regulation changes can be identified by the authorities during spot checks and may stop production and imports or even cause revocation of the certificates. OEMs and manufacturers will often require third party oversight by a recognized certification body such as the CCAP or CQC to prove initial and annual compliance to the Chinese regulations with an additional voluntary CCAP or voluntary CQC certification. In the automotive industry this oversight is often required to be shown as part of their vehicle Type Approval.

Another difference between CCC Self-Declaration and standard CCC is that the applicant for CCC Self-Declaration must be a company registered in China. This company can be a subsidiary, the OEM or the importer. The Chinese company will take responsibility for the products. The CCC Self-Declaration is registered and issued via an online portal of the CNCA (Certification and Accreditation Administration of the People’s Republic of China). CCC Self-Declaration can be complex. Many manufacturers choose to have a competent independent service provider who accompany them in the certification process.

A Chinese Applicant is required for CCC Self-Declaration:

The CCC Self-Declaration is registered with the Chinese certification authority Certification and Accreditation Administration of China (chin.: 中华人民共和国认证监督委员会, in short: CNCA) through an online system. It is required that the applicant must be a company registered in China. Manufacturers who do not have a subsidiary or company that can serve as an applicant in China have the possibility to contract a Chinese company as the applicant. The Chinese partner can then serve as the applicant for the CCC Self-Declaration and submit the necessary documents for the application. Through this applicant, several production plant locations can then be registered for the CCC Self-Declaration.

MPR China Certification offers their clients the a Chinese entity that is a technically appropriate applicant via its CCC Applicant Service. This service is aimed for those companies who do not have a registered company in China that could act as their applicant. Please contact us if you need support in this topic.

CCC Self-Declaration Product Categories

Products that fall under CCC Self-Declaration are divided into two types: Type A and Type B. The type distinctions are important for product testing. They distinguish whether the product tests must be conducted in a self-selected test laboratory or in a specified accredited test laboratory in China.

For which products does the CCC Self-Declaration/ Supplier Declaration of Conformity (SDoC) apply?

List of automotive products that fall under the self-declaration obligation:

List of general industrial products that fall under the Self-Declaration obligation:

CCC Self-Declaration Certification Process

There are two ways to obtain a CCC Self-Declaration:

• CCC Self-Declaration (only)
• CCC Self-Declaration in combination with a voluntary CQC / CCAP certification.

In each case, before applying for the CCC Self-Declaration, an internal audit of the quality management system should be carried out to check whether it can be assured to continuously meet the requirements of the CCC certification with regards to product conformity to Chinese GB standards and guidelines.

Process of a CCC Self-Declaration only

Unlike the standard CCC certification, the China SDoC does not require a factory inspection. Due to this there is no factory code issued. Instead, the manufacturer must independently enter all required information into an online system and continuously monitor compliance themselves. In addition, the CNCA does not carry out any checks on the correctness of the application documents. It is very important that everything is 100% correct and up to date to avoid problems or certificate cancellations.

Further notes regarding the interaction between CCC Self-Declaration and the voluntary CCAP and CQC certification: 

Ensure product conformity:

Since there is no ongoing monitoring with the CCC Self-Declaration, it is advisable to conduct a voluntary CQC certification or voluntary CCAP certification in addition to the CCC Self-Declaration. The CCC Self-Declaration in combination with the voluntary certification enables manufacturers to take a safer, more risk-adverse approach by allowing third party oversight in cooperation with the Chinese certification authorities. The voluntary certification ensures ongoing compliance and up to date conformity to the relevant Chinese standards. Customers or OEMs (Original Equipment Manufacturers) often request or require voluntary certification, as it allows them to minimize their risks and/or maintain proof of continued compliance.

Unfortunately, not all products for which a CCC Self-Declaration is required can obtain a voluntary certification. For all common automotive categories, a voluntary certification is available.

Liability in case of non-conformities:

It should be noted that with this new SDoC procedure structure, the manufacturer and the applicant are more responsible and liable than before. Some common non-conformities are: Implementation of a material change and or material supplier without prior approval by CNCA, Changes to part name, part number or revision level, part not marked correctly, incorrect unit classification, change of production process without approval by CNCA, relocation of the component without approval by CNCA, parts not updated to GB Standards or Implementation Rule changes, etc.

Due to the nature of the CCC self-declaration, significantly higher penalties and sanctions can be expected in case of deviations. Increased controls on the import of the products and on the complete vehicles (harbour checks) by the Chinese authorities are to be expected. In addition, controls may still take place in the Chinese market (for example during the distribution of components).

Process of a CCC Self-Declaration/ SDoC with Voluntary Certification:

If a manufacturer completed the CCC Self-Declaration in combination with a voluntary CQC certification or voluntary CCAP certification, the certification process will first be done according to the standard certification process of the voluntary certification. See voluntary CCAP and CQC certification. 

After obtaining the voluntary CCAP or CQC certificate, the Chinese authority links the voluntary certificate with the CCC Self-Declaration. All information provided in the voluntary certification will be transferred to CNCA’s online system.

CCC Self-Declaration Marking

After a successful CCC Self-Declaration, the manufacturer must mark the certified products with the CCC logo. The CCC logo may be applied only after receiving a valid CCC Self-Declaration.

Certain requirements apply regarding the diameter and size of the logo. Incorrectly marked products can lead to problems when importing the products into China.

Risks of the CCC Self-Declaration Procedure:

If a manufacturer decides they will apply for CCC self-declaration only, manufacturers are held more accountable for their product compliance. Possible changes to the standards (GB standards and CNCA Implementation Rules) can easily be overlooked. Manufacturers will not be notified of changes and must make sure their product compliance is up to date themselves. The manufacturer’s own change management must be consistent since every change to the product itself and as well as changes in the factory must be approved in advance by CNCA. This is particularly critical in the case of homologation of complete vehicles, since the conformity of production (CoP) of all relevant components to the GB standards must always be ensured by the vehicle manufacturer. The CCC Self-Declaration alone cannot guarantee this, so creates additional risk to the vehicle manufacturer.

Combining the CCC Self-Declaration with voluntary certification is a good way to minimize risks, as the Chinese authorities annually audit the manufacturer as part of the certification process.

Of course, there are other ways to ensure compliance. For example, in addition to the annual tests the manufacturer should also conduct internal audits on their own. For example, in addition to the annual tests the manufacturer should also conduct internal audits on their own. The Chinese company that will act as the applicant for CCC Self-Declaration will be required to register their “Social Credit” number as part of the application. Introduced in 2014, the social credit system can lead to risks in form of reduced social rating scores if violations of Chinese regulations are found.

The applicant for the CCC Self- Declaration must be a company registered in China. This company must submit its commercial register excerpt including social credit number when submitting the CCC Self-Declaration application. The applicant is therefore at risk with their rating if there are any non-conformities in the products. Serious violations can lead to the revocation of the Chinese company business license in addition to cancellation of the CCC Self-Declaration certificate and any further legal actions.

Your One-Stop Certification Solution.

Our complete package for product certifications for China.

Personal support by one of our experienced consultants

Application preparation and communication with the authorities and test labs

Providing a Chinese applicant (CCC application service in combination with additional voluntary certification)

Preparation and support of the factory audit (only in case of conducting a voluntary certification)

Organizing the required product tests

Consulting for the marking of your products

Organization of the follow-up certification (in connection with additional voluntary certification)

Updates on product-specific regulatory changes

CCC Self-Declaration Overview

CCC Self-Declaration FAQ

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