Introduction
From December 1, 2026, companies selling certain industrial products online in China will face a more explicit evidence-and-listing regime under the State Administration for Market Regulation’s Order No. 110, the Provisions on Supervision and Administration of Quality and Safety of Key Industrial Products Sold Online.
For overseas brands, importers, sourcing companies and China-based sellers, the practical issue is not simply whether a supplier can send a certificate or test report. The evidence must match the exact product being listed, the seller must retain traceable purchasing and sales records, required licence, CCC or inspection-report information must appear on the sales page, and the platform itself has verification and ongoing monitoring duties.
The rules therefore create a useful pre-listing checkpoint: before committing inventory or launching a China e-commerce listing, make sure the product, manufacturer, certificate or report, standard, model and online disclosures all connect to one another.
What products are covered?
The rules apply to “key industrial products” sold through internet and other information networks in China. SAMR defines the covered group as industrial products subject to industrial-product production licensing, products subject to compulsory product certification (CCC), and industrial products involving personal health or life/property safety that are subject to mandatory national standards.
The rules exclude categories governed separately by other laws and regulations, including food, drugs, cosmetics, medical devices and special equipment. SAMR also manages the scope through a published Key Industrial Products List, so sellers should check the current list and the product’s actual regulatory status rather than assume every manufactured product is covered.
This scope point matters for overseas companies. A product may be manufactured in China but sold only abroad, or it may be imported into China and sold domestically. The Order No. 110 obligations discussed here concern online sales within China; they are not a universal export requirement for goods shipped from China to other markets.
Why the rule changes buyer due diligence
The new regime connects three evidence layers that sourcing teams often review separately: supplier-side product evidence, the seller’s online listing, and the platform’s verification process.
A document that is technically genuine can still fail commercially if it belongs to another model, another manufacturer or an obsolete product configuration. Conversely, a compliant product can face listing delays if the seller cannot produce the correct evidence or the sales page omits required information.
For a buyer or brand preparing to sell in China, due diligence should therefore begin before purchase orders are locked. The aim is to build a traceable evidence chain from the legal manufacturer and exact model to the applicable licence, CCC certificate or inspection report, and then to the information displayed online.
1. Confirm whether the exact product falls within the rule
Start with the product itself, not the supplier’s general statement that it is “certified.” Record the exact model, specification, intended use, manufacturer and China sales channel.
Then determine whether the product is subject to an industrial-product production licence, CCC management, or a mandatory national standard involving health or life/property safety and included in the managed scope. Product classification should be resolved before listing because the evidence required on the sales page differs by regulatory route.
Where classification is uncertain, do not solve the issue by choosing the easiest document the supplier already has. Obtain product-specific regulatory advice or confirmation from the relevant authority, certification body or competent professional.
2. Verify the manufacturer and model behind the evidence
Order No. 110 requires sellers to display core product identity information, including product name, producer name and address, model or specification, the implemented standard number and necessary warnings.
For sourcing teams, these fields should be matched against the purchase specification and the supplier’s evidence before inventory is committed. Check whether the legal producer named on the certificate or report is the entity actually manufacturing the product. If a trader, brand owner or affiliate is involved, map the relationship instead of assuming names are interchangeable.
Model identity deserves particular attention. If the supplier says one certificate or report covers a family of models, obtain the scope or technical explanation showing why the offered model is included. Private-label changes, electrical ratings, component substitutions, firmware differences or packaging changes can affect whether earlier evidence remains representative.
3. Check the correct evidence route: licence, CCC or inspection report
For covered products subject to industrial-product production licensing or CCC, the seller must display the relevant production-licence number, CCC certificate number or a link to that certificate information.
For covered products that are not subject to those two regimes but involve personal health or life/property safety and have mandatory national-standard requirements, the seller must display the product inspection report or a link to it. The report must at least include product information, the inspection basis and the inspection result.
The rules define the relevant inspection report as either a factory inspection report issued by the producer according to the mandatory national standard or a report issued by a legally qualified inspection and testing institution according to that mandatory standard.
A buyer should therefore avoid treating “test report available” as a sufficient checkbox. Identify why that report is the correct evidence for the exact regulatory route and product.
4. Match the listing to the certificate or report
The online product page is now part of the compliance evidence chain. Required information must be true, accurate and clear.
Before launch, compare the listing against the certificate or report line by line where relevant: manufacturer, product name, model/specification, standard number, certificate number, warnings and other required information. Marketing descriptions of quality, performance and function must also be truthful and comprehensive and must not be false or misleading.
This is especially important when a marketing team copies a global product page into a China marketplace. Claims that are acceptable in another market may not correspond to the China evidence file, and a platform’s automated or manual review may detect mismatches that a commercial team overlooked.
5. Build a three-year traceability file
Platform sellers must establish incoming-goods inspection and purchase/sales record systems. They must check product conformity evidence and the relevant licence, CCC certificate or inspection report, and truthfully record supplier identity and contact information, product name, model, quantity, purchase and sales dates and actual shipping address. Relevant records and supporting documents must be kept for at least three years.
For overseas brands using distributors or marketplace operators, contractually clarify who maintains these records and how they can be retrieved. A brand should not assume that sending a PDF certificate to a distributor once is enough.
A practical traceability file should connect the purchase order, supplier, manufacturer, exact model, batch or shipment where available, certificate/report, listing version and actual fulfilment source.
6. Expect the platform to verify evidence before and after listing
Order No. 110 gives e-commerce platforms active verification duties.
For products under production-licence or CCC management, the platform must verify certificate numbers, product types and related information against information published by market-regulation authorities. If the information does not match, the product may not be listed.
For covered products requiring inspection-report evidence rather than production licensing or CCC, the platform must verify that the seller has provided the report or a report link. Without it, the product may not be listed.
Platforms must also conduct daily checks of key industrial-product sales. Those checks include whether required product information is complete, whether displayed licences or CCC certificates are valid and consistent with the listed product, and whether inspection reports or links are consistent with the product-page information.
This means pre-listing approval should not be treated as permanent. Evidence can expire, models can change, and listings can drift away from the approved product configuration.
7. Control product changes after approval
One of the biggest sourcing risks is evidence that was valid for the original sample but no longer represents current production.
Create a controlled baseline for important products. Depending on risk, it may include the approved model, drawings, bill of materials, critical components, electrical ratings, firmware, labels, packaging, warnings and relevant certificate/report identifiers.
Require suppliers to notify the buyer before defined critical changes. If a component, factory, material, firmware version or model specification changes, determine whether the existing licence, certificate, test report and online listing remain valid before releasing the changed goods.
This change-control discipline is particularly important for private-label products, where commercial teams may request apparently small modifications without realizing that the regulatory evidence was generated for a different configuration.
8. Prepare for recall and regulatory-risk information
When a seller receives or becomes aware of defect-recall information for a covered product, it must stop selling the product, prominently publish the producer’s recall information and assist the producer with the recall.
Platforms also have duties to act on recall information and on quality-safety risks identified through supervision, risk monitoring and their own checks. They can be required to remove, block or disconnect problematic listings.
For buyers and brands, recall readiness should therefore be part of supplier selection. Confirm that product identity, production batches, distribution records and customer-facing listing data are sufficient to identify affected goods quickly. A supplier that cannot trace what it produced may create much larger commercial disruption when a quality issue appears.
9. Do not confuse platform acceptance with complete compliance
A listing going live is not proof that every legal or technical requirement has been satisfied. Platform verification is one control layer.
The product still needs to satisfy the underlying product-quality, licensing, CCC, mandatory-standard and consumer-protection requirements that apply to it. A platform’s check of a certificate number does not prove that current production remains identical to the certified configuration. Likewise, presence of an inspection report does not establish that every marketing claim is supported.
Treat platform acceptance as an operational milestone, not a substitute for product compliance and supplier quality management.
10. Use a pre-listing evidence matrix
Before inventory is committed, create a simple evidence matrix for each covered SKU. Record:
- Seller legal entity.
- Producer/manufacturer legal entity and address.
- Exact product name, model and specification.
- Applicable China regulatory route.
- Implemented standard number and edition.
- Production-licence number and status, if applicable.
- CCC certificate number, scope and status, if applicable.
- Inspection-report number, issuer, product/model and test basis, if applicable.
- Required warnings and listing disclosures.
- Purchase and fulfilment source.
- Evidence expiry or review date.
- Supplier change-notification requirement.
- Listing-review owner and approval date.
- Recall contact and traceability records.
This matrix turns scattered PDFs and marketplace fields into a controlled release decision.
Practical buyer workflow before December 1, 2026
Companies planning China online sales can use the remaining transition period to review their product portfolio now.
First, identify which SKUs fall within the key-industrial-product scope. Second, map each SKU to the legal manufacturer and the correct evidence route. Third, validate certificates or reports against the exact model and current production configuration. Fourth, prepare the mandatory listing fields and warnings. Fifth, establish the three-year purchase/sales evidence file and a process for ongoing certificate, report and listing checks. Finally, define who stops sales and coordinates a recall if a regulator, platform or producer identifies a quality-safety issue.
For products launching close to December 1, it is sensible to test the evidence package with the intended marketplace before a large inventory commitment. Platform implementation details may vary, but the underlying statutory information and verification duties should be treated as the baseline.
Limitations and uncertainty
This article summarizes SAMR Order No. 110 and its official interpretation as verified in September 2026. The rules take effect on December 1, 2026. Product-specific application depends on the current Key Industrial Products List and the exact licensing, CCC and mandatory-standard status of the product.
The regulation is focused on online sales in China. It does not replace destination-market requirements for goods exported from China, and it does not mean that every industrial product sold online requires CCC certification or a third-party laboratory report.
The inspection-report route described in the rules applies to the defined covered products that are not subject to production licensing or CCC but involve personal health or life/property safety and have mandatory national-standard requirements. The regulation expressly allows the relevant report to be a producer’s factory inspection report under the mandatory standard or a report from a legally qualified inspection/testing institution under that standard.
Platform-specific listing procedures may add operational requirements, but those procedures should not be confused with the underlying legal obligations.
Conclusion
Order No. 110 makes online product compliance more visible at the point of sale. For overseas brands and sourcing teams, the main lesson is that supplier evidence can no longer sit disconnected from the exact SKU and the online listing.
The strongest preparation is a traceable chain: correct product classification, verified manufacturer, model-specific licence/certificate/report evidence, accurate listing disclosures, controlled production changes, three-year transaction records and recall-ready traceability.
That approach does more than reduce listing friction. It helps expose mismatched certificates, obsolete reports, undocumented substitutions and weak supplier records before they become inventory or customer problems.
Sources / Research Notes
Primary official source: State Administration for Market Regulation (SAMR), Provisions on Supervision and Administration of Quality and Safety of Key Industrial Products Sold Online, Order No. 110, promulgated December 8, 2025, published December 22, 2025, effective December 1, 2026.
https://www.samr.gov.cn/zw/zfxxgk/fdzdgknr/fgs/art/2025/art_ed09580528e343ebb9a294a752ab97d0.html
Supporting official source: SAMR official interpretation of the Provisions, published December 22, 2025.
https://www.samr.gov.cn/zw/zfxxgk/fdzdgknr/xwxcs/art/2025/art_e00c81a745a94d1580307e291092ead3.html
Research ID: SCC-RES-2026-034
Story ID: SCC-INS-2026-024
