NZ China EEEMRA. Topics:

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2 NZ China EEEMRA Topics: Mutual Recognition Agreements (MRAs) China Compulsory Certification (CCC) system EEEMRA Advantages of the EEEMRA Beyond the EEEMRA Peter Morfee Principal Technical Advisor EnergySafety Worksafe NZ May 2014

3 MRAs New Zealand has a number of MRAs that apply to Electrical and Electronic Equipment (EEE) These vary in complexity and implementation All of the MRAs are designed to reduce the compliance costs that are associated with Regulatory interventions and to allow testing and certification to be carried out in the country of manufacture

4 Simple MRAs The simplest MRAs cover testing and Certification They apply the Standards of the country of sale but allow the test labs and certification bodies of the manufacturer s country to be used and generally apply internationally (International Standards Organisation - ISO) based accreditation rules to the determination of testing facilities and certification body who can be used

5 High Level MRAs More complicated MRAs such as the TTMRA, allow the recognition of the Regulatory regime of the manufacturer s country to be applied These types of MRA are often referred to as a Market to Market MRAs

6 NZ China EEEMRA The NZ China EEEMRA applies a unique system It applies elements of both simple and high level MRAs and is asymmetrical in that the criteria for trade in one direction is different from that in the other direction The EEEMRA also addresses the complications caused by the differing languages and Standards of the two countries

7 CCC system The Chinese CCC regime can be best described as an ISO guide 67 type 5 system It requires products to be tested, their manufacture to be certified after the factory has been inspected by a qualified inspector who has verified that the factory is operating a quality assurance program complying with specified criteria All of these are based on international guidelines It was designed principally to control the safety of products manufactured by Chinese manufacturers

8 NZ Regime The NZ regime by comparison operates a type approval regime at ISO guide 67 type 1 level supplemented by supplier declaration provisions for both Safety and EMC This scheme is also closely aligned with the regime operating in Australia

9 CCC system The CCC system requires: All testing to be performed in a Chinese accredited test lab located in China All testing to be performed against a Chinese (GB) Standard Factory inspections to be carried out by a Chinese approved inspector against Chinese language quality assurance (CNCA) rules

10 Safety and EMC Most of the EEE products under the CCC system are required to meet Standards relating to: Safety EMC Harmonic interference The EEEMRA therefore covers all three requirements

11 Scope of the CCC regime The CCC marking regime applies to a wide list of products, ranging from medical electrical equipment to building products to motor cycle tyres The EEEMRA however only applies to products that are listed in one of the CCC electrical product categories, and does not include all of the EEE products covered by the CCC regime

12 CCC Regime Broadly speaking the CCC regime has a similar philosophy to the NZ Regimes in that it operates at a high level of intervention across those products recognised to create a risk to the population at large The EEEMRA creates a template by which trade between the two countries can be further facilitated

13 Applicable Standards Most of the applicable GB Standards are based in IEC Standards, however they are often one or two editions behind the latest editions that are being used for products destined for the NZ or Australian Markets It is important therefore for manufacturers who have an interest in the Chinese Markets to get testing performed and documented to both the current and the older versions of the applicable IEC Standards The NZ regulatory regime recognises IEC Standards with applicable NZ deviations

14 Scope of the EEEMRA Electrical Wires and Cables Switches for Circuits, Installation Protective and Connection Devices Low-voltage Electrical Apparatus Small Power Motors Electric Tools Welding Machines Household and Similar Use Appliances Audio and Video Apparatus Information Technology Equipment Lighting Apparatus (excluding the lighting apparatus with voltage lower than 36V) Most of the products included are those that are regulated in NZ under the high or medium risk declared article lists

15 Accredited Agencies At present we have two testing facilities accredited (one for EMC and Harmonics and one for Safety), and one certification body and one listed factory inspector The accreditations currently apply to only some of the categories covered by the EEEMRA with a focus on Audio, lighting and household appliances

16 EEEMRA features What the MRA does is to: Address the language differences and simplify compliance by allowing the IEC equivalent to the relevant GB Standard to be applied, with specified variations Allow the testing to be performed in a NZ test laboratory that has been accredited to translated Chinese rules, Allow the certification to be carried out by a NZ certification body that has been accredited to the Chinese rules

17 EEEMRA features Allow a NZ based and accredited factory inspector to carry out the factory inspection. Provide the quality control rules (CNCA Rules) in English through agreed translations. These factors lead to the product being listed and Authorised by the Chinese Regulatory agency to use the CCC marking

18 What the EEEMRA does not do: The MRA does not allow the use of a different IEC Standard to that upon which the GB Standard is based The MRA does not recognise any certification issued for sale of a product in NZ or Australia Does not reduce the regulatory interventions that are needed for sale of a product in China

19 Other benefits The MRA also: Reduces the delays caused by contracting factory inspectors to come from China Allows closer interaction with the testing and certification bodies Provides more confidence in the protection of IP

20 Rules of origin The MRA only applies to products significantly manufactured in NZ, however in determining the NZ content, any content originating in China is also included

21 Comments from a UK manufacturer The comments below were made by a UK supplier exploring whether they could use NZ s EEEMRA I am familiar with the CCC approval route we have 4 appliance ranges approved by the CCC (and the gas aspects approved by CCGAS) and a further 4 all electric / induction ranges in the approval process..near to the end..hopefully. But I have a number of new appliances to be submitted and suffice to say I was looking for an easier path for CCC mark..undertaking the approvals via the CQC has been the most challenging set of approvals we have ever undertaken.

22 Beyond the EEEMRA For exports China to it is critical to understand that the Chinese system is very precise Documentation has to exactly match the requirements, particularly if the documentation is in English For example, test exports to later versions of international Standards than those that GB are based on have no validity, as these Standards have no Chinese language versions, so cannot be compared to the current Standards used in China

23 In Scope It is important to determine exactly whether a product is actually subject to the CCC regime, or if slight modifications to the product, or its description, might move it out of the CCC scope

24 Or Out of Scope It is equally important to determine of the CCC compliance has a particular value for marketing the products in China One NZ manufacturer has voluntarily used CCC compliance for this purpose

25 Examples of trade with China

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