Our ref: ITC/AF/TS/066 18 August 2010
Ms Maria Kwan Director-General of Trade and Industry Trade and Industry Department Trade and Industry Department Tower 700 Nathan Road, Mongkok Hong Kong
Dear Maria
Re: Liberalization Measures of Technical Testing & Analysis and Product Testing Under CEPA Supplement VII
The growth of the Chinese economy and trade has created increasing demand for inspection and certification services. The Hong Kong General Chamber of Commerce has been advocating greater recognition of Hong Kong's accreditation services by the Mainland authorities, and greater access of our testing and certification industry to the Mainland market under CEPA. We are very glad that our recommendations are covered by the Seventh Supplement to CEPA, among 35 liberalization provisions in 19 sectors.
Under CEPA Supplement VII, testing organizations in Hong Kong are allowed to cooperate with designated Mainland Organizations to undertake testing of products for the China Compulsory Certification (CCC) system on a pilot basis, for selected products listed in the CCC Catalogue and processed in Hong Kong. While the testing and certification sector is excited about the new market opportunities, we hope that the Trade and Industry Department would help clarify a few issues concerning the detailed implementation regulations and facilitate the ongoing CEPA discussion with the Mainland Government, as follows:
1. The technical requirements of testing organizations are clear as the eligibility is tied in with the present accreditation schemes, i.e. Hong Kong Accreditation Service (HKAS). However, the scope of product applicability seems ambiguous, and it is necessary to expound the legal meaning of "products processed in Hong Kong".
2. While most testing companies in Hong Kong are in the R&D and product development disciplines, we hope that CEPA Supplement VII will also cover goods designed and developed in Hong Kong.
3. Hong Kong’s laboratories will be able to apply for Approved Test Labs (ATLs) after HKAS’ endorsement. The next issue to be clarified is the acceptance from the designated certification bodies in the Mainland over ATLs.
4. Hong Kong’s testing organizations are required to cooperate with designated Mainland organizations, but the exact form of cooperation is not specified.
We sincerely hope that the above questions could be relayed to the Mainland authorities through your Department, and we shall be grateful to host a meeting with you or your representatives to discuss the issues in depth.
Thank you very much, and I look forward to hearing your reply in due course.
Yours sincerely,
Alex Fong CEO
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