China’s Compliance Requirements for WLAN Products

An international EMC compliance expert explains how to achieve access to today�s Chinese WLAN market.

The adoption of a Chinese wireless local area net-work (WLAN) standard known as GB15629.11-2003 (AQSIQ/SAC 2003 Notice 110) was announced jointly on Nov. 26, 2003, by the General Administration of Quality Supervision, Inspection and Quarantine of the People�s Republic of China (AQSIQ) and the Standard Administration of China (SAC). As of Dec. 1, 2003, all WLAN products sold in China must comply with this standard created by the China Broadband Wireless Internet Protocol Standards (BWIPS) group.

On Dec. 1, 2003, the AQSIQ and the Certification and Accreditation Administration of the People�s Republic of China (CNCA) jointly issued the implementation of the compulsory product certification on WLAN products AQSIQ/CNCA 2003 Notice No. 113. When in force, all WLAN products cannot leave the factory or be imported, sold, or used in business activities without obtaining a China Compulsory Certification (CCC) certificate and affixing a CCC mark. The manditory CCC, scheduled to become effective on June 1, 2004, has been postponed as of the writing of this article.

Implementation Rules
The CCC approval process is governed by rules issued by the CNCA. At the time of this writing, 51 rules have been promulgated.

An implementation rule for WLAN products, CNCA 2003 Notice No. 18, was published on Dec. 15, 2003. CNCA�11C�048: 2003 Implementation Rules for Compulsory Certification of Wireless LAN Products and applies to computer networks with WLAN function, covering the following:

  • Stand-alone WLAN equipment such as access points, network adaptors, network bridges, routers, gateways, authentication servers including access control servers, and other equipment with authentication and privacy infrastructure.

  • Integrated or internal WLAN products such as PCs, notebook computers, PDAs, digital cameras and camcorders, plotters, projectors, scanners, copiers, printers, televisions, and DVDs.

  • Software products with WLAN authentication and privacy infrastructure (WAPI).

Submitting an Application
The CCC approval process for WLAN products is the same as for other products. Beginning Jan. 1, 2004, an applicant or its agent must submit an application to one of the designated certification bodies (DCBs): the China Quality Certification Centre (CQC), the China Certification Center for Electromagnetic Compatibility (CEMC), or the China Electronics Standardization Institute (CESI).

Application Documents
The following documents are required when applying for CCC approval:

�Application Form

�Certificate of Incorporation or Business License

�Declaration of Conformity

�Factory Questionnaire, if the factory is applying for the first time

�Letter of Agency, if applicable

�Product Description

�Proof of Trademark, if applicable

�CB Test Report, if applicable

�Electrical Diagram and/or System Block Diagram

�List of Electrical Safety/EMC key components and/or Bill of Materials and explanation

�List of key components and explanation for components that affect the WAPI

�Maintenance Manual and User�s Manual (User�s Manual must be in Chinese)

�Nameplate and Warning Label(s) in Chinese

�Variation(s) among models, if applicable

�Other document(s) required by the test laboratory

Test Laboratories
A test laboratory is assigned by the DCB after an application has been accepted. An applicant has no control over the choice of a test laboratory. There are more than 100 designated testing bodies (DTBs) covering CCC applications. All DTBs are in China since in-country testing is required.

For WLAN products, the State Radio Monitoring Center is the only DTB.

Test Standards
Table 1
lists the test standards for WLAN products. The safety standard GB4943, well known for information technology equipment, is equivalent to IEC 60950. An IEC 60950 CB report is acceptable; however, some deviation is required.

The EMC standard GB9254-1998 is identical to the international standard CISPR 22: 1997. The equipment under test is configured in a nontransmitting mode for GB9254 radiated and conducted emission testing. GB17625.1-2003 is identical to IEC 61000-3-2: 2001.

The GB15629.11-2003 WLAN standard is similar to ISO/IEC 8802-11:1999 used by most other countries. The only exception is a security protocol known as the WLAN Authentication and Privacy Infrastructure (WAPI) that is not compatible with the Wired Equivalent Privacy (WEP) security protocol used by 802.11.

Table 1. WLAN Standards for China
* = Chapter 8, Section 14.6.2, Section 14.6.3, Section, Section, Section, Section, and Section 16.3.3 are mandatory requirements. All other chapters and sections are voluntary requirements.
** = Section, Section, Section, and Section are mandatory requirements. All other chapters and sections are voluntary requirements.

Factory Inspection
Factory inspection is part of the CCC approval process. The initial factory inspection only needs to be conducted once for each type of product. A follow-up inspection is conducted in 12 months. To save costs for facilities located outside of China, a certification center will inspect several factories during the same trip. This arrangement could cause a significant delay in the certification process, especially if visas for several different countries are required for the inspectors.

It may take a couple of months to schedule an inspection. To avoid a long wait, an applicant can request an individual factory visit. However, by doing so, the applicant is responsible for all the traveling cost for the inspectors.

CCC Mark

Figure 1. CCC Logo for WLAN Products

A CCC mark includes a logo and a factory code. A typical CCC mark is shown in Figure 1. The I located to the right of the CCC indicates WLAN products. For reference, a CCC mark with an S&E letter reference is used for products subject to both safety and EMC requirements. A CCC mark with an S letter reference denotes products subject to safety requirements.

A factory code must be added under the logo. It includes a letter followed by six digits.

No deviation from the CCC mark is allowed. A certificate holder may affix standard-size marks (labels) printed by the CNCA or print or mold the CCC mark on the nameplate. A printed or molded label must be approved by the mark-issuing office.

A CCC mark must be affixed prominently on the main body of a product. For WAPI software products, the CCC mark can be affixed to the package. If a software product does not have a package, a statement must be added to the license agreement indicating that the product has been CCC certified.

After the WLAN standard became effective on Dec. 1, 2003, a grace period was granted if the product was imported or manufactured before Dec. 1, 2003. Parts for re-exported products are not bound to the CCC requirements.

For integrated or internal WLAN modules/products such as notebook computers, projectors, and printers permitted to use a CCC S&E mark, the following transition rule applies: If the certificate holder knows that the product(s) meets the GB15629.11-2003 and GB15629.1102-2003 requirements, the certificate holder must apply for and obtain CCC certification and affix the CCC I mark before the certification becomes manditory to have the product leave the factory or be imported, sold, or used in business activities.

Vendors that want to sell WLAN products in China must comply with the CCC requirements. Since the CCC approval process may be time-consuming, vendors are encouraged to apply for approval as early as possible to avoid delivery delays.

The author wishes to thank Mr. Feng, Ms. Wang, and Ms. Xu of CESI; Mr. Yuan of the State Radio Monitoring Center; and Mr. Wu of CQC for their contributions to this article.

About the Author
Grace Lin, a senior EMC engineer at SIMCOM International Holdings, has worked for compliance test laboratories for more than 10 years. She is a CNCA certified agent and works with various compliance certification programs in China, Taiwan, and the United States. Ms. Lin graduated from Syracuse University with a master�s degree in electrical engineering. SIMCOM International Holdings, 6111 Peachtree Dunwoody Rd., Atlanta, GA 30328, 908-647-6398, e-mail: [email protected]

August 2004

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