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Laboratory testing is not the only way but the most popular way to be sure that your product is compliant with all applicable regulations – and, the most direct and clear way to prove that to be the case to the CIQ in China
In this Q&A with Amanda Lau of CIRS in Hangzhou, you will learn the following:
- For which products lab testing in China is mandatory
- When you need to use an accredited laboratory
- If you can test your product abroad (or only in China)
- Other mandatory documents when selling to China
Amanda, please introduce yourself and what you do at CIRS in Hangzhou
I am working as technical support engineer for a CIRS affiliate called C&K Testing lab. I joined in the testing lab back in 2014.
I studied Chinese consumer products laws, regulations, standards and other requirements for more than 3 years, giving technical advices and solutions to my colleagues and our customers.
I also provide our customers with trainings regarding to related Chinese compliance requirements.
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Is lab testing generally mandatory when exporting to, or selling in, China?
All products placed on [export to] the market for sale in China must comply with Chinese standard, taking them to a lab and get tested will be a direct way to demonstrate the compliance.
But not all products be required to be tested during customs clearance. Products in the LIST OF ENTRY-EXIT COMMODITIES SUBJECT TO INSPECTION AND QUARANTINE OF ENTRY-EXIT INSPECTION AND QUARANTINE AGENCIES (hereinafter referred to as the List), such as nappies and diapers for the baby, toys, vehicles, and most of electrical and electronic products must be submitted to the Entry-exit inspection and quarantine bodies getting tested and gain an inspection and quarantine clearance certificate.
While non-listed commodities only need to address the random inspection, test reports not always needed.
But sometimes the CIQ and AQSIQ releases some additional requirements to the customs to require the import products, different customs may have different requirements.
Also China Compulsory Certification (hereinafter referred to as CCC) is a compulsory scheme based on National Chinese Standards (GB-Standards) for the products listed in the Catalogue of Products subject to Compulsory Certification (hereinafter referred to as Catalogue).
Such products like electric tools, automobiles, children cars, toy products usually need to conduct type-test.
What kind of different tests are required?
It depends. For example, a toy, will be required to test for mechanical and physical properties, flammability, chemical properties, including migration of heavy metals, phthalate content, and other hazardous substances.
If the toy is electrically powered, electrical properties test will be also necessary. But textiles usually do not proceed electrical properties test.
The test items are according to the standards which the products are covered, we advise you to ask a lab or your buyer in China.
When exporting to China, should the lab testing be done in China, or can it take place in Europe or the US?
As I mentioned before, products on the List must be tested in the Entry-exit inspection and quarantine labs. Also, products subject to CCC certification can only be tested in the designated labs inside China.
Non-listed and out of Catalogue products can be just tested in everywhere you like, given that the lab performance based on the good laboratory practice and has the ability to test according to GB standards.
If you want to make sure that your products are complying with GB standards, it is better to send your products to have a pre-test.
The labs in the EU or US can seldom perform GB standard, as many GB standards do not have an English language official version.
Some labs also send the samples to their branch lab, which is located in China to hold the GB standards testing. Another way, you can also choose a China located lab to be your supplier.
Are only authorized companies allowed to issue lab test reports for the Mainland China market?
You can issue a test report by your own factory lab when just test for formulation analysis, quality control, or get some research data, and you want to know it yourself instead of proving it to public. Or another lab without authorization will be okay.
But when you test to provide notarial data for the community, used for getting trade certification, product quality assessment, achievement appraisal and be of legal benefit, then labs with a CMA and/or CNAS certification shall be chosen.
There are lists of labs bare CNAS and CMA accreditation, you can see it in the Administration of quality and Technology Supervision and CNAS website.
And CCC product, only designated labs should be chosen. They are published in the Certification and Accreditation Administration of the China website.
Do you have any lab test cost examples?
Test cost will differ from test items, such as 19 heavy metals only cost US$85, but a PAH singly will charge roughly US$180 when test according IP 346.
Usually inorganic [i.e., plastics and metals] test will be much cheaper than an organic materials test.
A electronically powered plastic toy will expend approximately US$550, taking account of mechanical and physical properties test, flammability test, chemical properties test, and electrical properties test.
In addition to test reports, are there any other documentation requirements?
Necessary documents vary by product but may include standard documents such as a bill of lading, invoice, shipping list, customs declaration, insurance policy, and sales contract as well as more specialized documents such as an import quota certificate for general commodities (where applicable), import license (where applicable), inspection certificate issued by the General Administration of Quality Supervision, Inspection, and Quarantine (AQSIQ) or its local bureau (where applicable), and other safety or quality licenses.
Food contact materials and products are also required a DoC.
Cosmetics filing documents or administrative permissions are essential. A certification shall be submit when concerning CCC products. Exporters should better check the custom requirements before import.
Thank you Amanda. How can you help our readers with lab testing?
C&K Testing lab has been accredited by China National Accreditation Service for Conformity Assessment (CNAS) and China Metrology Accreditation (CMA).
Our independent 3rd-party testing lab focuses on product testing and certification, covering industries such as environment, consumer products, industrial goods and chemicals, which can fulfil the relevant regulatory requirements of regions and markets around the world.
We also provides our customers with professional regulation consulting, training, supply chain management and intelligence delivery, issuing customised solutions for each partner.