China CCC Certificate Becomes Non-Negotiable: Lithium-Ion Batteries Must Now Carry the Mark to Move

China CCC Becomes Non-Negotiable: Lithium-Ion Batteries

1. Executive summary

   As of November 1, 2025, the Certification and Accreditation Administration of China (CNCA) has removed the final transitional waiver for lithium-ion batteries. Every standalone cell, module or pack, whether imported or domestically produced, must now bear the China Compulsory Certification (CCC) mark before it can clear customs or be offered for sale on the Chinese market. Factory audits, GB/T 31467 testing and post-market surveillance are mandatory. Shipments lacking valid CCC numbers are already being held at major ports, disrupting import export business workflows worldwide.

   
   

2. Regulatory scope in force

   Products captured:

a. Portable Li-ion cells & battery packs (IT, telecom, consumer devices)

b. Traction batteries for electric vehicles (passenger cars, buses, two-wheelers)

c. Stationary energy-storage systems ≤ 1.5 kV DC

Standards referenced: GB/T 31467.1/2/3 (performance & safety), GB/T 31485 (thermal abuse), GB 38031 (EV application), plus IEC 62133-aligned cell-level tests.

Certification elements:

a. Type-testing at CNCA-accredited labs (30–45 days)

b. Initial factory inspection—two auditors, two days, unannounced option every 12 months

c. Ongoing surveillance testing (random sampling from market or factory)

3. Timeline & transition logic

   Phase-in started 1 May 2024 with voluntary acceptance; CNCA Announcement [2024] No. 5 fixed 1 November 2025 as the hard deadline. There is no “sell-through” period: inventories produced after 31 October 2025 must already be certified, regardless of manufacturing location.

   
   

4. Commercial impact on imports and exports

a. Customs risk: bonded warehouses report 18 % of battery SKUs currently lack CCC records, creating bottlenecks for imports.

b. Lead-time inflation: lab capacity is booked through CNY holidays; new slots command a 20 % premium.

c. Platform delistings: T-Mall and JD.com automatically remove battery listings without valid CCC certificate numbers.

d. Recall exposure: State Administration for Market Regulation (SAMR) can mandate recalls if post-market surveillance finds non-conformance; penalties reach 5–10 × product value.

5. Six-step compliance roadmap (management consulting approach)

   Step 1: SKU rationalisation: Map every model, derivative and private-label variant against CNCA’s catalogue; minor casing changes often create new certification families.

Step 2: Design review & pre-testing: Conduct in-house abuse tests (thermal, short-circuit, over-charge) to uncover surprises before formal submission.

Step 3: Lab booking & sample dispatch: Reserve slots early; prepare bilingual test reports to accelerate CNCA document review.

Step 4: Factory quality assurance audit: Align production line records (traceability, incoming inspection, calibration) with CQC audit checklists; critical for multi-site manufacturers.

Step 5: Certification dossier submission: Upload via CNCA e-portal; include Chinese user manual, bilingual labels, and UN38.3 transport test summary.

Step 6: Post-certification surveillance: Update packaging artwork within 30 days; schedule annual surveillance tests; maintain change-control log for any design or BOM modification.

6. Common pitfalls observed

a. Assuming cell-level CCC covers pack-level requirements; both must be listed if sold separately.

b. English-only labels; Chinese safety warnings and recycling symbols are compulsory.

c. Incorrect factory address on certificate after relocation, triggers automatic suspension.

d. Confusing CCC with the voluntary CQC mark; customs only recognises the former.

7. Strategic outlook for import export business

Industry analysts forecast China will export 1.2 TWh of batteries in 2026; simultaneous CCC + CE + UL compliance will become a key differentiator. Early movers are already negotiating long-term supply contracts contingent on integrated certification packages, effectively locking out late adopters.

8. How SLV 360 delivers certainty

   As a specialised management consulting and business service provider, SLV 360 offers:

   
   

   a. Integrated testing bundle: CCC, UN38.3, CE, UL 2580 in one sample set, one logistics loop.

   
   

   b Bilingual technical file preparation reduces CNCA review cycles by an average of 12 days.

   
   

   c. On-site pre-audit with former CQC auditors—94 % first-time pass rate.

   
   

   d. Regulatory intelligence bulletin automatic update when GB/T 31467 revision drops (expected Q2 2026).

   
   

   e. Surveillance sampling service, we collect China-market samples, arrange retesting and upload surveillance reports on your behalf.

Email info@spheralink360.com with your battery specification sheet and projected shipment schedule.