Product Compliance And Market Access Services In China

Scope and evidence must be confirmed before any paid tests or filings.

China market access is not a single certificate. Start with the product's intended use, technical functions, models and import/sales channel; only then identify the applicable authorities, compulsory standards and approvals.

This national route-selection guide distinguishes overlapping regimes. It does not replace product classification or promise that a CE mark, foreign test report or one Chinese approval clears every requirement.

Choose the regulatory route before commissioning tests

Use the matrix as a screening tool, not an exhaustive legal classification. Several rows may apply to the same SKU; whether a specific model is within a catalogue must be checked against its current scope definitions.

Product signal	First regulatory question	Next verification
Electrical goods, toys or regulated components	Is the exact model within today's CCC catalogue, and is its route third-party certification or permitted self-declaration?	Check CNCA scope and the current product rule; use the CCC execution or advisory page.
Wi-Fi, Bluetooth or other radio transmitters	Does the transmitter require MIIT radio type approval (SRRC), or fall within a specified exemption?	Identify bands, powers and radio module configuration; check the MIIT route separately from CCC.
Electrical and electronic equipment	Does China RoHS apply, including a 2026 catalogue entry, substance restriction, conformity assessment or information mark? Is an energy label also listed?	Match the precise category and phased effective requirements; review materials and energy data.
Medical devices or products with medical claims	Is the intended use regulated as a medical device, and what is its class?	Check NMPA classification: imported Class I filing versus Class II/III registration.
Cosmetics and personal-care formulas	Is the product a general or special cosmetic, and are any ingredients separately regulated?	Determine the NMPA filing or registration route and the China-responsible-party requirements.
Imported foods	Does the food category require overseas producer registration and other import controls?	Check GACC Order 280, effective 1 June 2026, and the product-specific import route.
Other or multifunction products	Could mandatory GB standards or another sector regime apply despite no obvious CCC match?	Record the product's primary function, claims and mandatory standards; do not infer free sale from 'not CCC'.

For food, Order 280 concerns overseas food production, processing and storage establishments. It expressly excludes establishments producing, processing or storing food additives and food-related products; other Chinese import and product rules must still be checked.

Check the 2026–2027 transition points

CCC: SAMR Announcement No. 57 of 2025, published 7 January 2026, moves 16 listed product types from self-declaration to a third-party CCC certificate. Applications under the new route opened 1 July 2026; affected continuing products must complete conversion by 31 December 2026, with certificate/mark requirements from 1 January 2027. The exception is limited to units that left the factory while a valid self-declaration was in force and are no longer manufactured; those units need no certificate conversion and may continue to be sold.

China RoHS: MIIT's 2026 compliance-management catalogue and exemption list took effect on 28 May 2026, replacing the 2018 first-batch catalogue. Product-specific dates for substance limits remain relevant: publication of the new catalogue does not mean every listed limit started on the same day.

The 2026 catalogue consolidates ten continuing categories and adds 23 categories. Existing conformity-assessment and reporting obligations for continuing categories remain in force. The 23 new categories, and newly extended product scopes, enter the catalogue conformity-assessment requirements on 1 August 2027, when mandatory standard GB 26572-2025 also takes effect. China RoHS substance-information and marking duties may apply to electrical and electronic products outside the catalogue; absence from the catalogue is not an exemption from all China RoHS duties.

Standards and catalogue scopes change. Verify the version effective for the planned import or sale date, not the date of an old test report.

Sequence the launch: five decision gates

Keep a written go/no-go record for each model; a pass at one gate does not resolve the next.

Freeze the intended use, product claims, technical variants, power source, radio features, target user and China sales channel.
Build a regime applicability sheet: in scope / out of scope / unresolved for CCC, SRRC, RoHS, NMPA, GACC, energy label and applicable GB standards.
Confirm the legally eligible applicant or responsible party, accepted laboratory/body and documentary format for each in-scope route before paying for tests.
Align design samples, Chinese labels/instructions and technical documents; complete any mandatory evaluation, filing or approval before the applicable market-entry point.
Release the shipment/listing only after checking the actual certificates/filings, markings, model coverage, customs documents and outstanding conditions; retain change-control ownership.

Assign owners and preserve evidence

Ask these questions in writing rather than assuming that the importer, manufacturer and certificate holder are interchangeable.

Role to confirm	Evidence / decision owner
Manufacturer	Controls model specifications, bill of materials, samples, factory records and subsequent design changes.
Chinese importer or seller	Checks import/sales documents, Chinese-market presentation and any duties assigned by the applicable product regime.
Registrant, filing entity or local responsible person (where required)	Confirm eligibility, appointment, dossier control and legal responsibilities under the relevant NMPA or other sector rules.
Testing laboratory or certification body	Confirm acceptance/designation and scope for the exact scheme; a foreign report is not automatically accepted.

For imported medical devices, an overseas registrant or filer must designate an enterprise legal person in China as its agent. For imported cosmetics, an overseas registrant or filer must designate an enterprise legal person in China as the domestic responsible person. These are distinct legal roles; identify the correct one before a filing or registration.

A useful pre-classification packet contains:

Model/SKU list with versions, product photos, intended users and intended claims.
Technical drawings, ratings, power supply, embedded transmitters, operating bands and power levels where relevant.
Materials/BOM, hazardous-substance declarations, battery and energy-performance details where relevant.
Manufacturer sites, supplier chain, proposed China importer/applicant and sales channel, including cross-border e-commerce if relevant.
Existing test reports, certificates, draft Chinese labels/manuals and a register of unresolved scope questions.

Know when to reopen the assessment

Repeat the route check when a change could affect scope or evidence:

new wireless module or frequency band
new material, supplier, battery or manufacturing site
new intended use, cosmetic/medical claim or model family
revised GB standard, catalogue, scheme or certificate validity

Move to the specialist workstream

This page owns cross-regime triage. Detailed execution, cost and technical testing belong to the following narrower pages:

Questions before importing or selling

Does a CE mark or CB test report allow immediate China sales?: No general equivalence exists. Map each applicable Chinese regime and ask whether that scheme accepts the particular evidence; approval, filing and China-specific marks may still be necessary.
If CCC does not apply, is my product unrestricted?: No. Other mandatory GB rules and sector-specific pathways can still apply, including radio, hazardous substances, energy labelling, medical devices, cosmetics or food.
Can CCC, SRRC and China RoHS apply to one connected appliance?: Yes, potentially. Assess electrical product scope, radio transmission and material/marking obligations separately; one certificate does not replace the other checks.
Which date matters for a product formerly using CCC self-declaration?: For the 16 affected categories in SAMR Notice 57/2025, check the 2026 conversion window and the 1 January 2027 certificate requirement, including the exception for units dispatched from the factory during the validity of their self-declaration that are no longer manufactured.
What should I send for a reliable first assessment?: Send models, specifications, functions and claims, radio data, materials where relevant, manufacturing location, intended importer and sales plan. If any classification is uncertain, hold testing or shipment until it is resolved.

Official starting points

Use the current official texts and implementation rules; these links are orientation points, not a substitute for a model-specific determination.