Published on

August 26, 2026

Last updated on

August 26, 2026

China Requires Manufacturers to Convert CCC Self-Declaration Certificates Before Jan 1st, 2027 Deadline

Worker inspects automotive safety glass

On July 15, 2026, the TC07 CCC Technical Expert Group released the “Technical Resolution on Implementing the Conversion of CCC Evaluation Methods from Self-Declaration to Third-Party Certification for Products Including Fuses (TC07-2026-01).”

The resolution provides the technical framework for implementing State Administration for Market Regulation Announcement No. 57 of 2025, a landmark policy shifting 16 product categories away from enterprise self-declaration and back to mandatory third-party oversight.

Critical Deadline: Companies that miss the December 31, 2026 conversion deadline risk losing legal market access in China. As of January 1, 2027, self-declarations will no longer satisfy compliance requirements for these 16 product categories.

At a Glance

  • 16 Product Categories: Transition from self-declaration to third-party CCC certification. Eligible self-declarations must be converted to CCC certificates by December 31, 2026. From January 1, 2027, affected products must hold a valid CCC certificate and bear the CCC mark.
  • Conversion Pathway: Authorities will recognize valid historical self-declaration results to avoid forcing manufacturers to restart the process from scratch, provided documentation withstands technical review.
  • Third-Party Oversight: Conformity assessments shift from internal company platforms to independent bodies handling type-test verification, product consistency reviews, and certificate lifecycle management.
  • Mandatory Factory Audits: Certification bodies must complete full factory quality assurance inspections within three months of issuing a converted certificate, and no later than June 30, 2027.
  • Action Required: Prioritize certificate conversions and compile technical documentation immediately – Contact Cisema for support.

Affected Product Scope

The technical resolution establishes uniform implementation requirements for certification bodies managing the transition across these 16 product categories:

  1. Fuses
  2. Small-power electric motors
  3. Electric drills
  4. Electric grinders
  5. Rotary hammers
  6. DC arc welders
  7. TIG arc welders
  8. MIG/MAG arc welders
  9. Plasma arc cutting machines
  10. Automotive safety glass
  11. Automotive safety belts
  12. Vehicle lighting and signaling devices
  13. Indirect vision devices
  14. Vehicle seats and head restraints
  15. Vehicle driving recorders
  16. Vehicle retroreflective markings

CNCA Announcement No. 10 of 2026 authorized specific bodies and laboratories for this transition. Notably, CQM has been appointed as the designated certification body for fuse-links, small-power motors, power tools (including electric drills, electric grinders, and electric hammers), and welding equipment (including DC, TIG, MIG/MAG, and plasma arc cutting machines).

Conversion Framework: Two Compliance Models

1. Enterprises Holding a Valid CCC Self-Declaration (“Conversion Model”)

Pursuant to SAMR Announcement No. 57 of 2025, certification bodies will actively accept an enterprise's valid self-declaration evaluation results to manage risks while expediting approval.

  • Documentation Requirements: The enterprise must submit a certification entrustment form, business license, product description, original self-declaration certificate, and supporting technical documents.
  • Laboratory Verification: Designated laboratories will verify the original type test report and product information, supplementing with difference testing where necessary.
  • Approval & Audit: Upon passing verification, the certification body directly reissues a standard CCC certificate. The body must then conduct a full-scope factory inspection within three months.
  • ODM Models: For Original Design Manufacturer (ODM) conversions, the brand owner may apply for a derived certificate under new implementation rules only after the original manufacturer completes its certificate conversion.

2. Enterprises Without a Valid CCC Self-Declaration

Enterprises lacking an active self-declaration must follow the standard initial certification procedures under new CNCA implementation rules:

  • Direct Application: The enterprise submits an initial application directly to a designated certification body.
  • Full Type Testing & Initial Factory Inspection: Because historical self-declarations cannot be accepted, samples must be submitted to a designated laboratory for full-item type testing. Concurrently, the certification body must conduct an initial factory inspection covering all elements of the quality management system.
  • Market Entry: Certificates are issued only after both type testing and factory inspections are fully passed. Because this route carries longer lead times, enterprises must initiate it immediately to avoid market exclusion.

Compliance Timeline

  • July 1, 2026: Designated certification bodies began accepting applications to convert eligible self-declarations into CCC certificates.
  • December 31, 2026: All eligible self-declarations must be converted to CCC certificates, and the corresponding self-declarations should be voluntarily cancelled.
  • January 1, 2027: Products covered by the new requirements must hold a valid CCC certificate and bear the CCC mark before they can be manufactured, imported, sold, or used in China.
  • June 30, 2027: Certification bodies must complete post-certification factory quality assurance inspections for converted certificates.

Recommended Actions for Affected Manufacturers

For overseas manufacturers, importers, and brand owners supplying the Chinese market, the transition presents both operational and timing challenges. Early preparation will be essential to maintain uninterrupted market access.

1. Review Existing Self-Declarations and Set Conversion Priorities

With only a six-month window running from July 1 to December 31, 2026, companies managing large product portfolios face intense pressure to complete filings on time. CQM, for example, has confirmed it will actively recognize valid historical self-declaration results to control risk and maintain certification quality.

To capitalize on this, companies must immediately audit their self-declarations and sequence high-volume or business-critical lines first, particularly those with complex model variations.

2. Prepare Complete Technical Documentation

For new CCC applications the application dossier review and completeness of technical documentation is key, documentation readiness dictates conversion success. Applicants must verify that product descriptions, type test reports, consistency records, labels, and user instructions are complete, current, and consistent before submitting an application.

This diligence is vital: where laboratory type testing fails, accredited certification bodies for CCC will reject the application. A rejection forces companies to submit a brand-new application and undergo the full, lengthier initial CCC certification process, risking missed deadlines and severe market disruption.

Holders of valid CCC certificates who are required to update their certification to the new revision once it comes into force must follow the instructions issued by the relevant certification bodies. Depending on individual circumstances, there may be ways to expedite and simplify the application process.

3. Coordinate Early, Especially for ODM Products

Early engagement with designated certification bodies helps prevent bottlenecks as application volumes surge toward the deadline.

For Original Design Manufacturer (ODM) products, planning is particularly important. Under CQM procedures and CNCA-00C-002:2009 (Supplementary Provisions on the ODM Model in the Implementation Rules for Compulsory Product Certification), the original manufacturer's certificate must be converted before the brand owner's ODM certification can proceed.

Brand owners should therefore coordinate closely with their manufacturing partners to avoid unnecessary delays.

4. Prepare for Post-Certification Factory Inspections

Securing the certificate is only the first phase; mandatory factory quality audits follow closely behind, requiring full inspection within three months and no later than June 30, 2027.

Manufacturers certified in accordance with the CCC implementation rules that are still in force should use the transition period to review changes in the regulation applicable to quality management systems, with a particular focus on key processes to maintain product conformity, such as supplier controls, production processes, change management, and product traceability.

Organizations operating under ISO 9001 or comparable quality management systems and seeking CCC certification may already have many of the required controls in place, making early internal audits based on newly revised regulation an effective way to prepare for certification body inspections.

Final Thoughts

China's return to third-party CCC oversight for these 16 product categories marks a major shift in regulatory enforcement. While authorities have established a pragmatic conversion pathway, the compressed timeline leaves no room for delay.

Market continuity for overseas manufacturers depends entirely on early planning, audit-ready technical documentation, and close coordination with designated certification bodies ahead of the December 31, 2026 deadline.

To help you secure uninterrupted access to the Chinese market, Cisema supports manufacturers through every phase of this transition — offering expert regulatory strategy, quality management support, factory readiness assessments, and end-to-end liaison with designated CCC bodies.

If your products are affected by China's revised CCC requirements, contact Cisema to assess your conversion eligibility, prepare compliant documentation, and ensure your business meets the mandatory deadlines with confidence.

Further Information

References

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