Starting from January 1, 2027, mandatory product certification for luminaires and ballasts will fully switch to the new implementation rules. For manufacturing enterprises in the industrial chain, the time left for "old-rule inertia" is only the transition period before the end of 2026.
I. Policy Background: Why Change the Version Now?
Luminaires and ballasts bear directly on building lighting safety and electrical safety in public spaces, and have always been a high-risk category in the CCC catalogue. In this revision, the Certification and Accreditation Administration of China (CNCA) issued the Mandatory Product Certification Implementation Rules — Luminaires (Trial) (CNCA-C10-01:2026) and the Mandatory Product Certification Implementation Rules — Ballasts (Trial) (CNCA-C10-02:2026). The core logic can be summed up in one sentence: turning "principled requirements" into "verifiable specific requirements", and directing supervisory resources precisely to high-risk links.
II. Rule Structure: From "Combined" to "Separated"
Comparison Dimension | Old Rules | New Rules |
Number of rules | Luminaires and ballasts shared one single rule | Luminaires and ballasts each have an independent rule, two in total |
Supporting documents | One set of certification implementation details | Details abolished; 10 annexes issued together with the rules |
Chapter volume | 13 chapters in total | 20 chapters each |
The direct effect of the structural split is that the granularity of unit division, key component definition and key process control is significantly increased, and the differences in enforcement standards among different certification bodies will be further narrowed.
III. Certification Modes: No Longer "One Size Fits All"
Ballasts retain a single mode: type test + initial factory inspection + post-certification supervision. Luminaires are divided into three modes according to product characteristics. Enterprises should first identify which applies to them, then plan their certification pathway:
Mode | Applicable Products | Certification Pathway | Key Notes |
Mode 1 | General luminaires | Type test + initial factory inspection + post-certification supervision | Standard pathway |
Mode 2 | Large luminaires | Design appraisal + type test of some items + initial factory inspection + post-certification supervision | Drawing review and mechanical calculation may replace some destructive tests. Threshold criteria (meeting any one is sufficient): weight > 100 kg; both length and width > 1.8 m with height > 1.0 m; diameter > 1.8 m with height > 2.0 m; diameter > 1.0 m with height > 4.0 m |
Mode 3 | Single-batch luminaires | Type test + 100% factory inspection | Certificate is "single-use": issued before leaving the factory, cancelled after delivery acceptance; validity no longer than 6 months; no change, extension or renewal supported; if uncertified products of the same model are found outside the certified batch, all CCC certificates of that category held by the producer and the manufacturing enterprise will be revoked |
Note! Mode 2 is a targeted response to the practical problem that large-scale, heavy-duty luminaires "cannot be brought into the laboratory as a whole unit"; the convenience of Mode 3 is exchanged for the strictest boundary constraints.
IV. Enterprise Responsibilities: From "Soft Requirements" to "Hard Constraints"
The new rules impose systematic and rigid requirements on the internal management of manufacturing enterprises. Enterprises are advised to conduct item-by-item self-checks:
Appoint a certification quality officer: both the producer and the manufacturing enterprise must have one, who may concurrently serve as the quality safety director and bears full responsibility for certification quality;
Implement the "two audits and two checks": no fewer than 2 internal quality audits and 2 product consistency self-checks each year, covering all valid certificates;
Direct payment of fees: certification fees must be paid directly to certification bodies and laboratories, cutting off the room for improper intervention by intermediary links;
Prohibit multi-channel certification: for products of the same model from the same producer and the same factory, violations will result in the revocation of all certificates;
Tiered record management: general records shall be kept for no less than 5 years; type test reports, factory inspection reports, certificate status information, and procurement records of key components shall be kept for no less than 10 years; Reconstruction of key component management: A/B class parts are no longer distinguished, and notification and changes are handled uniformly through the laboratory channel; key components listed in the CCC catalogue shall obtain certification first.
V. Post-Certification Supervision: Denser Sampling, More Substantive Means
Obtaining certification is not the end. The combined supervisory measures under the new rules include:
A higher proportion of flight inspections, with surprise and unannounced checks becoming the norm;
Sampling moved forward: sampling tests and consistency checks are preferentially conducted at the market circulation stage (including e-commerce platforms); ballasts are preferentially sampled at luminaire manufacturing enterprises;
Laboratory rotation: two consecutive supervisory tests may not be conducted in the same laboratory;
Process traces: designated laboratories must deploy video surveillance, and some type test items must be fully recorded;
Classified supervision: supervision frequency is tied to enterprise category — Category A once every 2 years, Category B once a year, Category C twice a year, Category D three times a year. Quality management level directly determines the cost of facing inspections. In addition, unit division has been upgraded from a "principle" to a "requirement". Taking fixed general luminaires as an example, they may be classified into the same unit only if they simultaneously meet 11 conditions including installation method, light source type, shock protection type and enclosure protection rating, and have the same structure; large luminaires must also list the model, specification and material grade of important load-bearing components such as hooks, wire ropes and bolts.
VI. Timeline and Enterprise Action Checklist
Transition period: from now until December 31, 2026, enterprises may voluntarily choose the old or the new rules to apply for certification; valid certificates already issued remain in use and transition naturally through product changes, renewal upon expiry and other means. Enterprises are advised to proceed in the following order during the transition period:
Benchmark study: organize quality, R&D and procurement teams to study the new rules, with emphasis on thoroughly understanding the consistency control clauses;
Gap identification: conduct internal self-checks against requirements such as the "two audits and two checks" and record retention periods;
Document version change: revise quality manuals and work instructions to stay consistent with the new rules;
Personnel in place: designate the certification quality officer and strengthen the competence of inspection personnel;
Certification planning: select the certification mode according to product type and reserve time for type testing and factory inspection, to avoid congestion caused by concentrated certificate renewal in 2027.
This version change is not a simple replacement of documents, but an extension of the certification supervision philosophy from "access gatekeeping" to "full life-cycle control". For well-managed enterprises, classified supervision means lower-frequency supervision costs; for enterprises that are inadequately prepared, the risk of certificate revocation is already written into the clauses. The transition period is the window period — benchmarking early and changing versions early is the only way to respond calmly when the new rules fully take effect on January 1, 2027.
