Certification of Ex products

Guidelines for CCC certification of Ex products in China

Author: Otto Walch

Introduction

Since 1st October 2019, new CCC certification rules have been in place for Ex products sold in China; these replace the previous National Production License System (NPLS). A transition period of one year was provided.

By 1st October 2020, most Ex products sold in China must be covered by a new CCC Ex product certification and mark.

Basic rules

The basic principles underlying the new certification rules can be found in the following regulation:

CNCA-C23-01:2019 – China Compulsory Certification Implementation Rules – Explosion-proof Electrical Products (also known as CCC Ex)

This regulation requires all Ex products featured in the product catalogue, regardless of their production site, to go through the following three-stage CCC certification process:

1. Conformity assessment (Ex product assessment, inspection and certification)

2. Initial inspection at the production site

3. Monitoring and recertification audit at the production site

Application area

Apart from the Ex devices, all products that must be CCC certified can be identified in the CCC catalogue using their customs tariff number (HS code).

Ex devices are identified using the associated description in the Range Determination Table (Table 1). Some products, such as Ex lighting, are currently not included in this table and therefore (initially) excepted from the new regulation.

Ex devices that do not fall into one of the 17 categories are excepted from both the CCC Ex requirements and the regular CCC requirements (SAMR CNCA Notice no. 17 2020).

However, a national Ex certificate is still required for exempt Ex devices of this type.

Table 1: Product categories and scope of application (from Appendix 1 of SAMR Notice no. 34, 2019, translated and provided by EuropElectro)
Product category and code	Scope of application
84. Explosion-proof motors (2301)	Motors with center height <160 mm or rated power <15 kW, motors with 160 mm < center height < 280 mm or 15 kW < rated power < 100 kW, motors with 280 mm < center height < 500 mm or 100 kW < rated power < 500 kW, motors with center height > 500 mm or rated power > 500 kW
85. Explosion-proof electric pumps (2302)	Electric pumps with rated power <15 kW, electric pumps with 15 kW < rated power < 100 kW, and electric pumps with rated power > 100 kW
86. Explosion-proof power distribution equipment (2303)	Distribution boxes (cabinets), power maintenance boxes, connection boxes, junction boxes, power supply (cabinets), filter (cabinets), power compensation devices, rectifier (cabinets), power converters (switching devices)
87. Explosion-proof switches, control and protection products (2304)	Switches (switch boxes and cabinets), buttons (button boxes), circuit breakers, control cabinets (boxes, devices, consoles), relays, operation (boxes, tables, columns), protectors (protection boxes), protection devices, driller consoles, release devices, driver controllers, speed control devices, breakers, remote control transmitters (receivers), choppers
88. Explosion-proof starters (2305)	Starters, soft starter, frequency converters (boxes), reactors
89. Explosion-proof transformers (2306)	Mobile substation, transformers (transformer boxes), voltage regulators, mutual inductors
90. Explosion-proof electric actuators and solenoid valves (2307)	Electric actuators, electric valve actuators, electropneumatic valve positioners, electric valves, solenoid valves, electromagnets, electromagnetic heads, electromagnetic coils, electric check valves, electric shut-off valves, control valves, electric/pneumatic converters, brakes, thrusters
91. Explosion-proof connectors (2308)	Electrical connectors, safety pins (including plugs and sockets), pin switches
92. Explosion-proof monitoring products (2309)	Cameras, tripod heads, monitors, monitoring stations (substations), repeaters, transmission interfaces, video servers, displays (display instruments, screens, boxes), computers, industrial control computers (including accessories), sound and light (language, speech, signal, static electricity) alarm devices
93. Explosion-proof communication and signaling equipment(2310)communication and signaling	Intercoms, loudspeakers (electric horns), telephones, players, calling stations, base stations, switches, optical transceivers, tandem switches, signal couplers, amplifiers, distributors, expanders, network (line) terminals, isolators, sound boxes, tappers, signaling devices, electric bells (electric whistles), communication interfaces, annunciators (instruments, boxes), indicators, network access devices, bridges, drivers, gateways, transmitters, receivers, signal (photoelectric, data) converters
94. Explosion-proof air-conditioning and ventilation equipment (2311)	Refrigeration (heating) air conditioners or units, dehumidifiers, fan-coil units, fans, fan heaters, electric fans
95. Explosion-proof electric heating products (2312)	Electric heaters, electric heaters, electric heating tapes, electric tracing bands, electric heating rods, electric heating plates, electric heating tubes
96. Explosion-proof accessories and Ex components (2313)	Threading boxes, distribution boxes, sealing boxes, flameproof enclosures, flexible connecting pipes, cable entries, stuffing boxes, plastic fans (blades), connection terminals, terminal lugs, pipe joints, insulators
97. Explosion-proof instruments and meters (2314)	Electric heaters, electric heaters, electric heating tapes, electric tracing bands, electric heating rods, electric heating plates, electric heating tubes
98. Explosion-proof sensors (2315)	Photoelectric sensors, speed sensors, temperature (humidity) sensors, state sensors, acoustic (optical) sensors, pyroelectric (infrared) sensors, tension sensors, smoke sensors, coal blocking (coal level) sensors, touch sensors, tear sensors, yaw sensors, damper sensors, voltage (current) sensors, inclination sensors, magnetic (Hall) sensors, feed sensors, proximity switches (sensors), delay sensors, on-off (emergency stop) sensors, material sensors, position (displacement, travel) sensors
99. Safety barriers (2316)	Zener safety barriers, isolation safety barriers, safety energy limiters (modules), safety couplers, intrinsically safe power supply
100. Explosion-proof instrument boxes (2317)	Instrument boxes, instrument panel, instrument cabinets, watt-hour meter boxes

Monitoring for devices produced outside China is performed by customs, i.e. when the goods are imported into China. CCC-liable Ex products are inspected to ensure that they are correspondingly certified and marked. If this is not the case, the products are returned to the supplier. If the mark is incorrect, penalties may be issued.

Note:
Apart from temperature sensors and material sensors, no measuring instruments for industrial process measurement technology in product category 2315 "Explosion-proof sensors". Material sensors include fill level limit switches (e.g. swing forks, capacitive limit switches).

Table 2: Factory Definition Code (from "Guideline of China Compulsory Certification Implementation Rule", provided by CNEX)

Product classification

The following table shows how Ex products are classified according to CCC. To do this, the four-digit "Factory Definition Code" (FDC) is introduced. The following table shows how this code is structured. The first two digits indicate the product category to which the Ex product belongs. The third digit indicates the device group (field in which the Ex product may be used). The fourth digit indicates the type of protection used.

Example FDCs:

0131: Enclosure-protected motor for dust environment

1524: Intrinsic safety sensor for gas environment

0461: Flameproof switch for gas and dust environment

It is possible for one product to have multiple FDCs. For instance, an electric pump protected by Ex d and Ex e is classified as 0221 and 0223.

Table 4: GB standards and associated IEC standards

Product certification according to CCC Ex rules

General

In order to obtain a CCC Ex certificate, proof of compliance with the relevant GB standards for explosion protection must be provided. The relevant GB standards are listed in Table 4 alongside their references to the IEC standard.

The conformity assessment (Ex product assessment, inspection and certification) remains largely unchanged in practice, since the underlying basis will still be the Chinese GB standards that are derived from the IEC standards for Ex products. The CCC Ex certificate is valid for five years; recertification must be initiated at least 90 days before the expiration date.

Important note: An existing valid IECEx certificate can be used for the conformity assessment. IECEx certificates that are issued in accordance with a newer standard can also be used.

Each CCC Ex certificate for a product applies exclusively to one production site, which is subject to production monitoring in accordance with section 5 by the Chinese test body that issued the CCC Ex certificate.

Converting existing Chinese Ex certificates to CCC Ex

A Chinese Ex certificate can only be converted to a CCC Ex certificate by the same test body that issued the original certificate.

The following documents, if they are not available at the test body, are required to convert existing Chinese Ex certificates to CCC Ex certificates:

Application form, e.g. online from the test body
Registration licence for the applicant, manufacturer, production site(s) (e.g. business licence, organisation code certificate, etc.)
Agreement between the applicant, manufacturer and production site(s)
Original certificate
Information about product marks (e.g. CCC logo, FDC, warning notes in Chinese, etc.)

Application for certification based on IECEx

IECEx certificates of conformity can be used as the basis for CCC Ex certificates.

The following documents, if they are not available at the test body, are required for the application:

Application form, e.g. online from the test body
Registration licence for the applicant, manufacturer, production site(s) (e.g. business licence, organisation code certificate, etc.)
Agreement between the applicant, manufacturer and production site(s)
IECEx certificate of conformity and ExTR
Technical documents (e.g. product drawings, technical requirements, operating instructions, list of components and materials important for explosion protection, etc.)
Information about product marks (e.g. CCC logo, FDC, warning notes in Chinese, etc.)

Direct application for CCC Ex certificate

The following documents are required for a direct application for a CCC Ex certificate:

Application form, e.g. online from the test body
Registration licence for the applicant, manufacturer, production site(s) (e.g. business licence, organisation code certificate, etc.)
Agreement between the applicant, manufacturer and production site(s)
Technical documents (e.g. product drawings, technical requirements, operating instructions, list of components and materials important for explosion protection, etc.)
Information about product marks (e.g. CCC logo, FDC, warning notes in Chinese, etc.)

Important note: A direct application corresponds to IECEx certification, for example. Accordingly, prototypes must be provided for type tests.

Quality control at production site(s)

General

Until the CCC was made mandatory for Ex products, a range of different quality control requirements applied for domestic and international manufacturers. The introduction of the CCC globally harmonised these requirements for all manufacturers.

According to the CCC rules, all production sites that manufacture products for which the CCC is mandatory are subject to quality control.

An IECEx QAR (Quality Assessment Report) is not accepted as proof of quality control in accordance with the CCC.

Quality control consists of:

Initial inspection (also known as Initial Factory Inspection, IFI)
Surveillance audit
Repeat audit

The initial inspection is initiated when the application for a CCC Ex certificate is submitted. The scope of this audit is the check whether a production site is capable of correctly producing the corresponding types of protection and products. The scope of the audit is determined by the FDCs (Factory Definition Codes) assigned to the product and thereby the production site, among other factors.

Travel has been restricted as a result of the COVID-19 pandemic. Since 18th June 2020, it has been possible to perform the required IFI as a document audit. This rule will remain in place for six months after the end of the pandemic. After this period, the manufacturer must apply to the corresponding test body for the initial audit.

The IFIs and surveillance audits may, based on the latest information from NEPSI and CNEX, also be performed by IECEx auditors once they are accredited for CCC by the corresponding test bodies. As well as the requirements set out in section 5.4, an IECEx auditor may only act on behalf of a single Chinese test body. To do so, they must be accredited as an auditor by this test body.

The frequency of the surveillance and repeat audits depends on the company classification.

Unlike in the IECEx or ATEX system, production site monitoring by one test body cannot be transferred to another test body. This means that the test body issuing the certificate must also perform the monitoring.

Note: The cycle of surveillance and repeat audits does not correspond to the audit rules according to the IECEx system.

Audit frequency

The defined cycle of surveillance and repeat audits is heavily dependent on the company classification.

The link between the quality management system, classification and audit frequency is set out below:

Performing audits

The test sequence during audits is determined in accordance with the company classification, as shown in Table 6.

The time and personnel required for an audit is 2–6 people/days for the initial inspection and 1–3 people/days for a surveillance or repeat audit.

The following performance regulation describes quality assurance for a manufacturer's production site:

CNCA-00C-005-2014 – Compulsory product certification and implementation rules – factory quality assurance capability requirements

The following performance regulation describes how a manufacturer's production site quality is assessed:

CNCA-00C-006-2014 – Compulsory product certification and implementation rules – General requirements for factory inspection

The various regulations can be found (in Chinese) at CNCA website.

Important note: Audits at the production site may only be performed by auditors who have been appointed by a Chinese CCC Ex test body and recognised by the CCAA. CCC Ex auditors can only be appointed by one CCC Ex test body and can therefore only be registered once with the CCAA.

NOTE: For manufacturers of Ex products who have CCC Ex certificates from a number of different Chinese test bodies, this means that each test body will perform its own audit. Reciprocal acknowledgement is not possible.

The FDC (Factory Definition Code) of the product to be certified determines whether a sample inspection or just verification will be performed. The test body has the right to perform the inspections at its in-house testing laboratory, if it so chooses.

For the initial inspection of a production site, at least one type sample for each FDC listed for this site must be available for testing.

An initial inspection is required for each FDC that is intended to be produced at a production site. This means that the number of FDCs will also influence the duration of the initial inspection.

During the initial inspection, the products will be tested in an exemplary manner to verify whether they comply with Chinese standards for Ex products (see Table 4).

If the initial inspection is successful, the CCC Ex certificate is issued for the products in the application.

In the case of a manufacturer with multiple production sites, this process must be performed for each site. It is possible to simplify this process if all production sites use a joint quality management system. According to SITIIAS and CNEX, one type test is then sufficient for each FDC, regardless of the site at which the product was manufactured (ODM).