Brian --

Our experience is that CCC applies to various products according to their 
harmonized tariff code. The Chinese maintain a list of products, with their 
harmonized tariff codes, that fall under the scope of CCC.


Additionally in our experience, those same components, when shipped as part of 
a finished end product, do not fall under the scope of CCC.


Lastly, there is an exception for repair parts, but it seems to take some 
talking with local officials to implement this exception. Their stated concern 
seems to be wanting to ensure that calling them "repair parts" is simply not an 
excuse to import non-CCC parts and sell then to the broader market as component 
parts for new products. Our local employees in China had to work with local 
officials to implement this exception for some repair parts that we wanted to 
stock in China.


Mike Sherman

Graco Inc.

> On March 5, 2019 at 10:43 AM Brian Kunde <[email protected]> wrote:
> 
>     We received a strange request today from Hong Kong supposedly initiated 
> from Customs. 
> 
>     We were asked to provide CCC supporting documents for about a dozen 
> cooling fans used in some of our instruments (laboratory equipment).  I knew 
> CCC is required on household electrical fans but not small internal cooling 
> fans.  The list of fans is a mixture of 230Vac fans and 24Vdc fans.  
> 
>     Some of these fans were used in products that went obsolete 10 years ago 
> or longer.  We may still ship them as repair replacement parts, but I thought 
> service parts were exempt. 
> 
>     Is this a new requirement or do you think there is some kind of confusion 
> going on?  
> 
>     Regards,
> 
>     The Other Brian
> 
>     PS: How many active EMC-PSTC members do you think there are?  
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