Kafkaesque import certifications for masks and the Chinese way to understand it

Euro-China share trade problems during COVID-19 Outbreak : urgency, temptations of quick profit and, mostly, problems of PPE-CE certifications for the Schengen area. European mass media stigmatize China’s « failures ». But some supposed « Certification organizations » are also popping up in Europe ! Here some explanation from Chinese standpoint.

We rush, we look for quick money, we order in Chinese factories without paying much attention to the certificates and then, if there are problems we accuse our partners !


But the very reliable European Safety Federation (ESF) website is aware about this problem :« Unfortunately, we are informed from different sources about ‘certificates’ used as basis for CE marking of PPE (including FFP2/FFP3 masks and eye protection), while these ‘certificates’ have no legal value and can not be used as conclusion of conformity assessment. It is not clear if these documents have actually been issued by the organisations mentioned themselves or if they are fake…..” (1) and in a special section : « As we were informed recently about some fake and misleading certificates for PPE… » (2)

ESF stated in the announcement that for any products imported from outside the EU to the EU, a declaration of conformity (Declaration of Conformity, or DoC) must be provided and checked.

The importer must ensure that the manufacturer has performed a conformity assessment in accordance with PPE Regulation (EU) 2016/425. If they have questions about DoC, or if there is no DoC available or imported from outside the EU, it is necessary or even necessary to check the certification.

The Kafkaesque rules and the 23 « Certification organizations » !

This means that conformity assessment includes:

1. The type inspection conducted by the notified body ( NB) will be issued the “EU Type Inspection Certificate”, or Module B certificate for short.

2. Production tracking or random spot check or system audit conducted by the notified body, referred to as Module D certificate or Module C2 certificate.

Only after obtaining the Module B + Module D or Module B + Module C2 certificate can the CE mark be used. The number of the notified body is displayed next to the mark. This statement must be attached to the product instructions (or instructions can be found on the ESF website).

In order to avoid more export enterprises of masks and other anti-epidemic materials in the CE certification process, the European Safety Federation (ESF) also listed 25 non-compliant certification organizations and institutions in the announcement. 16 non-compliant institutions are based in China. But … let’s see precisely the following list of certification organizations and institutions named by ESF.

Fake certification organizations in Europe listed by ESF

​•​ICR Polska

​•​CELAB – see statement on their webpage https://celab.com/en/coronavirus/

​•​ISET (Instituto Servizi Europei Technologici) – on their website they have a page with false certificates – see http://www.iset-italia.eu/index/service/fal.html

​•​ECM (Ente Certificazione Macchine) – also a picture of a mask with identification number of the notified body ECM 1282 next to CE – ECM is not a notified body for PPE, so this marking is certainly not valid)

​•​NPS

​•​Amtre Veritas

​•​STS Inspection and Certification

​•​VIC Testing and Certification

​•​BSI : we have also added an example of a ‘certificate of compliance’ issued by ‘BSI, London’ which is clearly not issued by the Notified Body for PPE BSI and this is confirmed by the Notified Body BSI – so this one is not a valid EU Type Examination certificate.

In China

​•​CIC (Shenzhen CIC Testing Technology)
​•​Huaxun (Shenzhen HX Detect Certification)
​•​ENC (East Notice Certification Service)
​•​HTT (Shenzhen HTT Technology)
​•​ITC (Shenzhen ITC Product Testing)
​•​BTK (Guangzhou Bestek Testing Services)
​•​Micez (Shanghai MICEZ Testing & Technical) – 14/04/2020 : Micez informed that the example on this page is not issued by Micez and thus fake !
​•​Huawin (Shenzhen Huawin Testing Certification)
​•​LTT (Shengzhen LTT Testing Technology)
​•​JZ-CERT (Shanghai Yan Zheng Network Technology)
​•​OCT Technology Testing
​•​ACT Testing Technology
​•​XW-CERT (Shenzhen XinWei Certification Service)
​•​ATL (Shenzhen ATL Testing Technology)
​•​TMC (TMC Testing Services (Shenzhen))
​•​YouBest Testing Technology
​•​Shenzhen Tian Hai Test Technology


More in China than in Europe ? Yes, but the market is huge in China and they « recovered » before us.

But this is not a competition between dishonest and greedy companies. However we can stress here that European mass media didn’t mention this facts and figures… They do prefer the pure « China -bashing »

ESF wrote a special article to verify the certificates by analyzing the size and style of the characters written inside it. (3)

So for China AND Europe, the European Union has announced a series of establishments authorized by the European Union for unified supervision and certification qualifications, which they call Notified Body NB establishments, and has assigned each establishment a unique four-digit code, this is i.e. the ad number. And issued by the agency authorized by the advertisement number. Please read (4)

But China also makes effort ! Who speaks about this in mass medias ?

China Imposes New Export Restrictions for COVID-19 Medical Products

On 31 March 2020, the “Ministry of Commerce, General Administration of Customs and the National Medical Product Administration (NMPA) issued Notice No. 5 of 2020 – Notice on the Orderly Conducting of Medical Materials Export” (“Notice”). Taking effect from 1 April 2020, the Notice imposed export controls on Chinese manufactured COVID-19 medical products (5)

We Europeans easily criticize China but the European administration and the Chinese administration are both complex ; however, if we pay attention to the way of ruling and deciding, Chinese government is undoubtedly faster and more efficient than in the Schengen area.

So, let’s promote more transparent communication on both sides and more efficient and reliable Euro-China connections.


(1) https://www.eu-esf.org/…/4513-covid-19-suspicious-certifica…

(2) https://www.eu-esf.org/…/4370-misleading-and-fake-certifica…

(3) https://www.eu-esf.org/q-a/q-a/4369-q0088

(4) https://ec.europa.eu/growth/tools-databases/nando/index.cfm…

(5) https://www.twobirds.com/…/china-imposes-new-export-restric…

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