Recently, the Shanghai Municipal Market Supervision Bureau published a report on the 2025 "Dual Random, One Public" supervision and inspection of certification activities on its official website.
The notification was addressed to district market supervision bureaus, the Lingang New Area Market Supervision Bureau, the Municipal Bureau's Law Enforcement Corps, the Airport Branch, and relevant certification bodies. The inspections were organized to implement national regulatory directives and the city's annual work priorities for certification and accreditation oversight. The focus was on a "dual random, one public" review of certification bodies, mandatory product certification (CCC) activities, and organizations certified under management system and organic product standards.
The basic details of the inspection are as follows. For the 2025 inspections, the authorities randomly selected 10 certification bodies, 90 CCC-certified enterprises, 10 manufacturers using the CCC self-declaration method, 100 management system-certified organizations, and 15 organic product-certified organizations through digital platforms. The inspections concentrated on three core areas: the compliance of certification bodies, the professional conduct of auditors, and the ongoing adherence of certified organizations to requirements. Key checks targeted violations such as fraudulent certification, trading of certificates, certification beyond scope, reduction or omission of required procedures, sale of CCC-covered products without certification, and the use of prohibited substances in organic products. The inspections involved over 800 personnel deployments. Problems were identified at 48 certification bodies, with 23 suspected of violations; an additional 12 CCC-certified or self-declaring enterprises were also suspected of non-compliance, with all relevant case leads referred for further action. The oversight aims to curb illegal activities in the certification industry and enhance its professional credibility.
The main problems discovered are categorized as follows. Regarding certification bodies, issues were found in internal management. Some bodies exhibited lax management, with inadequate contract reviews that failed to identify discrepancies in applicants' qualifications or business scopes. Audit planning lacked coordination, leading to mismatches in audit team expertise and insufficient allocation of audit days. Personnel competency evaluations were often perfunctory, allowing unqualified individuals to participate in certification activities. Audit process control was also weak. Implementation issues included incorrect sampling ratios for multi-site audits, omission of key branch locations, and incomplete coverage of critical processes like special procedures and outsourced management. Certification review and decision-making systems were poorly enforced, resulting in overly broad certification scopes and neglected risk control duties. Reporting to the "Certification Administrative Supervision System" was irregular, with delays, inaccuracies, or missing internal records. Post-certification supervision was inadequate. Surveillance audits were delayed without valid reason, and certificate cancellations or updates lagged behind actual enterprise changes. Specific CCC certification issues included ineffective tracking systems for certified organizations, insufficient product consistency checks, and incorrect archives or outdated standards. Organic certification problems involved missed checks on environment and inputs, along with insufficient surveillance audit coverage.
Problems with certification auditors were also noted. Audit execution lacked standardization, with significant deviations from planned schedules and personnel, and actual audit durations falling short of requirements. Some sampling evidence was fabricated or tampered with. A lack of professional technical competency hindered comprehensive identification and control of compliance risks during audits, undermining the effectiveness and reliability of the audit process. The quality of audit records was substandard, featuring vague descriptions, a lack of traceable objective evidence, and discrepancies with actual enterprise operations, raising doubts about their authenticity and accuracy.
Issues were identified among certified organizations as well. Many showed failures in management system operation and record-keeping. Some certified organizations did not effectively run their management systems, with internal audits and management reviews being mere formalities; records were poorly maintained, creating a disconnect between actual operations and certification requirements. Some organic product-certified organizations improperly mixed organic and conventional products, had irregular document management, lacked procurement ledgers for organic inputs, or maintained incomplete cultivation records. Key information changes were not reported as required. Alterations to business addresses or scopes were not communicated to certification bodies, causing a mismatch between the certified scope and reality. Some CCC-certified organizations failed to apply for certificate changes or extensions when modifying production processes or key components. Enterprises using the CCC self-declaration method sometimes submitted false application materials or did not update their self-declaration information as mandated. There was also non-standard use of certification certificates and marks, including poor management of certification marks and exaggerated claims about certificate scope in product promotions.
Subsequent measures will be implemented as follows. Legal enforcement will be strengthened. Certification bodies and certified organizations suspected of violations will be transferred to law enforcement departments for further investigation and handling. Rectification will be enforced. Rectification notices have been issued to 25 certification bodies with minor issues, mandating corrective actions within a set period. Industry self-regulation will be enhanced. Special lectures and seminars will be organized to reinforce the primary responsibility of certification bodies and solidify the foundation for compliant industry development. Information disclosure will be improved. Inspection and penalty results will be promptly published through the National Enterprise Credit Information Publicity System and the Municipal Bureau's portal website to facilitate public oversight and create a closed-loop regulatory mechanism.
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