Passing Used Machinery Through the Chinese CCIC Customs Import Test

As a matter of procedure, all used machinery imports into mainland China must pass a full CCIC inspection by a registered CCIC body in the country of supply. This includes imports from Hong Kong and other neighbouring countries and is a much more stringent test than similar inspections used by other countries such as SGS, Veritas or Intertec. Whereas these alternative inspections check only very basic details such as the serial numbers against the machine documents and commercial invoices, the Chinese CCIC inspection officers test the machine functions, comment on the cosmetic condition, safety features and any damaged parts or leaks. Any of which can result in a fail of the inspection and a refusal to issue a certificate. There is very little information available in the public domain as to the bounds of the inspection and what constitutes an acceptable level of machine quality to pass the test.  The CCIC personnel in each country also vary in their standards and are generally uncooperative when trying to obtain this information.  Having exported many machines to China and having passed many and varied units through the CCIC process, Sigma Plantfinder is well experienced in the rigours of inspection. There is a certain amount of work that if undertaken before the inspection can improve the chances of a pass certificate being issued and if the inspector does fail, there is a way to carry out rectification and present these at a later date to obtain a pass certificate without the need for reinspection. The CCIC inspection process starts in China and is generated by the import company that is commissioned by the consignee to import the machinery into China when it arrives at the Chinese border.  There is an inspection fee which is paid in China, normally in USD by the import company. Once this has been paid, CCIC will request many documents relating to the machine that can include:

1. Commercial invoices
2. Maintenance history and repair history of the machine
3. A letter from the manufacturer confirming the manufacturing age of the machine or alternatively a photo or scan of a serial number book showing the relevant serial number series and the date of manufacture.
4. Full and detailed photographs of the machine including the photos of the serial number plate and chassis stamp, photo of the engine serial number plate and engine block stamp. Full exterior and interior photos of the machine must also be submitted.
5. Operational manual for the machine model in question
6. Location address and contact details on site to arrange viewing

Once this information has been supplied to the CCIC body in China, they will transfer the file to the local CCIC office that is closest to the machine location.  When arranging inspections on machinery in countries that do not have a CCIC officer such as South Africa and South America, CCIC will arrange to send one of their representatives from another location, normally Dubai.  This will incur an extra cost to cover the travel fees.  The local CCIC office is meant to arrange a date and time to inspect, however in our experience they do not do this and generally just arrive when it suits them with no warning. Whilst on site they require the machine to be fully assembled, they require an operator to demonstrate the machine to them and they require hard standing to inspect the machine on.   As stated earlier, the rigour of the inspection varies dramatically between inspectors and local CCIC offices, however some of the issues that have been highlighted to us in the past include:

1. Warning stickers not written in Chinese
2. Oil leaks from hydraulic systems
3. Machine not being cleaned
4. Safety guards and handrails damaged or partially missing
5. Damaged undercarriage parts in the case of tracked machinery
6. Rubber bungs missing from windscreen shields
7. Damaged switches inside the cabin or operating platform
8. Ripped or torn seat covers
9. Missing radio speaker covers in cabin doors or cab interiors
10. Missing door latch or retaining hook
11. Missing decals or scratched paintwork
12. Missing or damaged cabin access steps
13. Cracked windshield glass
14. Side locker hinges or latches missing or damaged

Although these items may seem unreasonable and not related to the performance of a used machine, CCIC will not negotiate or argue the point in any way. They are extremely difficult to communicate with and their view is that if you do not want to conform or carry out the rectifications that they deem as appropriate then you can exercise your option not to import the unit to China. Once the faults have been picked up, the local CCIC office will submit a list of the faults to the import company and normally to the contact at the viewing site as well. This is normally in the form of a spreadsheet outlining the issues and sometimes includes photos of the articles in question. CCIC will then expect full rectification to be made on all points with no exceptions.  Photos of the rectified parts should then be loaded onto the spreadsheet along with a description of the completed rectification and then resubmitted to the CCIC office by the party that has carried out the work.  CCIC may then come back with extra questions and request more details and images, however as long as everything they have outlined has been completed to what they deem to be an acceptable standard then they will issue you with a pass certificate. This process of rectification is not fast.  CCIC steadfastly refuse to give any kind of timescale when considering the evidence of rectification and excessive pressure from the import company can result in a blanket refusal as a matter of principle.  It is important to understand that they are operating a monopoly and that they must be worked with on all points at all times.  This is different to other inspection bodies used by other countries which are largely independent and unbiased third parties. The CCIC inspection body is a government run department and is therefore subject to the slightly unusual Chinese rules and precedents that regulate such an organisation. There are however a few short cuts that you can take to ensure the machine passes the inspection on the first round before the inspection takes place.  Items that we have worked on prior to the CCIC visit include the following and give a taste of how the system can be overcome.

1. Guard rails missing or damaged. The CCIC inspectors are not at all au fait with the technical details of each unit and do not know if a handrail is missing or not.  When a handrail or access platform is damaged or partially missing, we have had some success in entirely removing the damaged parts in full so that the inspector is not aware that there should be an item there. For instance, if on a large excavator there is a part of the handrail missing, on the top of the superstructure, you can remove the entire rail all the way round thereby making the inspector unaware that there should be an item there in that place.
2. The same would apply with damaged working lights on the machine. If you simply remove the light in it’s entirety, the inspector has now ay of knowing that there was an object there and therefore cannot fail it on this point.
3. You should always wash and steam clean all machinery properly before inspection with particular regard to the engine and hydraulic compartments. If an inspector sees old oil in the bottom tray of an engine compartment he will automatically assume that it is a current oil leak and fail the machine.
4. Ensure the seat in the cabin is not torn, the cab interior is complete with no missing panels and if there is a switch missing from a console leaving a hole, fit a rubber bung in to block the hole.
5. Likewise, any cabin class should be repaired up front, including exterior mirrors. If a mirror casing is damaged, you can remove the mirror entirely which means the inspector will not pick it up.
6. Fill in any scratches in paintwork with touch up paint.

This is just a summary and example of how to the pass the CCIC inspection. It may seem an unreasonable level of inspection to carry out on a used machine that can be up to 20 years old, however it is important to remember that the CCIC body does not work on a common-sense basis, they are part of the Chinese government and their job is to restrict the volume of machinery imported across the Chinese border to protect the domestic manufacturing factories.   They are therefore not subject to the normal bounds of reasonability and in their view, must be complied with at all costs.  By understanding the system however, it is possible to bypass some of the irregularities and inconsistencies and to work the system to your advantage.