According to a report by Lianhe Zaobao on 8 September: “US regulators announced on Monday (8 September) that they had initiated proceedings to revoke the certification of seven testing laboratories alleged to be owned or controlled by the Chinese government, citing national security concerns. This move prohibits these laboratories from testing US electronic products. Reuters reported that the US Federal Communications Commission (FCC) had voted in May to finalise a ruling barring Chinese laboratories deemed a threat to US national security from testing electronic devices sold in the US, such as smartphones, cameras and computers. The FCC announced on Monday that the accreditations for four additional Chinese laboratories had expired in May and would not be renewed, including two that had applied for extensions. The commission stated it would take action against multiple companies, including the National Vehicle Internet Product Quality Inspection and Testing Centre (CQC Internet of Vehicles Technical Service Co), CVC Testing, and TÜV Rheinland-CCIC Ningbo Co.
This news report highlights geopolitical risks within the electronics certification sector amid the current international climate—the US Federal Communications Commission (FCC) has revoked the certification qualifications of multiple Chinese testing laboratories for US electronic products on national security grounds. This incident serves as a wake-up call for Chinese electronics manufacturers reliant on a single certification pathway, particularly within the Printed Circuit Board Assembly (PCBA) production sector. This article systematically analyses how to establish a dual-backup strategy for certification bodies within PCBA production practices, ensuring smooth product market entry while effectively mitigating similar policy risks.
Dramatic Shifts in the International Certification Landscape and Challenges for the PCBA Industry
On 8 September 2025, the US Federal Communications Commission (FCC) announced the revocation of accreditation for seven Chinese testing laboratories and the rejection of renewal applications from four others. This decision, based on purported ‘national security concerns,’ signifies profound changes in the global electronics certification environment. Affected laboratories include prominent institutions such as the National Vehicle-to-Everything Product Quality Inspection and Testing Centre, V-Care Testing, and TÜV Rheinland-CCIC (Ningbo). These facilities previously provided essential certification testing services for electronic devices entering the US market, including smartphones, cameras, and computers [News Source].
This policy shift has immediate repercussions for PCBA manufacturers:
– Supply chain disruption risk: The sudden loss of FCC-approved testing facilities directly prevents products from obtaining timely certification required for US market entry.
– Cost escalation pressure: Companies must now seek alternative, non-prohibited certification bodies, potentially leading to increased testing fees and extended certification cycles.
– Market access uncertainty: Further Chinese laboratories may face inclusion on the prohibited list, undermining stable certification expectations.
Against this backdrop, PCBA manufacturers must reassess their certification strategies and establish resilient certification systems. Implementing dual or even multiple backup mechanisms will safeguard product certification processes against disruptions from any single institution. This situation also reflects the ongoing ‘de-risking’ restructuring of global supply chains, where technical standards and certification systems increasingly serve as tools in international competition. Manufacturers must therefore cultivate greater strategic flexibility and heightened risk awareness.
Core Framework for Dual Backup Certification Bodies Strategy
Within the PCBA manufacturing sector, establishing a dual backup certification bodies strategy is an essential measure to navigate the current complex international certification landscape. This strategy transcends mere ‘spare wheel’ selection, constituting a comprehensive certification risk management system requiring multi-dimensional construction and implementation.
Selection Criteria and Combination Strategy for Dual-Backup Certification Bodies
When selecting a dual-backup combination of certification bodies, PCBA manufacturers should establish a multi-dimensional evaluation system, avoiding simple random selection or price-driven decisions. The primary consideration is geopolitical risk diversification. An ideal dual-backup combination should span different political and economic alliances, such as selecting both domestic Chinese bodies and certification bodies from other regions like Europe or Southeast Asia. Recent findings indicate that while the United States has intensified scrutiny and restrictions on Chinese technical bodies, it maintains relatively higher acceptance of bodies from Europe and other regions. This policy divergence creates operational opportunities for certification backup arrangements.
Technical capability alignment constitutes another critical metric. Backup certification bodies must possess technical testing capabilities equal to or exceeding those of the primary body, particularly specialised qualifications within specific product categories. For instance, concerning PCBA products related to vehicle connectivity, backup bodies should hold ISO 17025 accreditation for dedicated vehicle connectivity testing, encompassing electromagnetic compatibility (EMC), radio frequency (RF), and specific security standard testing conditions. It is noteworthy that certification requirements vary across different markets. Backup bodies should ideally cover the requirements of target markets simultaneously, such as FCC certification in the United States, CE certification in the European Union, and CCC certification in China, achieving the efficiency goal of ‘one test, multiple countries’.
Service reliability and emergency response capability constitute the third major selection criterion. Enterprises need to assess the service stability of backup certification bodies, including their track record, client evaluations, equipment sophistication, and personnel expertise. In emergencies, the ability of backup bodies to respond swiftly and shorten standard certification cycles is a key measure of their value.
Internationally renowned certification groups like TÜV, SGS, and BV maintain branches across multiple regions. Should policy restrictions affect one regional office, certification work can be promptly transferred to another branch. This ‘internal backup’ mechanism provides enterprises with additional safeguards.
Standardisation and Parallel Management of Certification Processes
Implementing a dual-backup certification strategy necessitates systematic optimisation of process management to ensure both certification pathways operate efficiently in parallel without mutual interference. The core lies in establishing a standardised certification documentation system, enabling a single set of technical documents to simultaneously meet the requirements of different certification bodies. This includes key files such as product specifications, circuit diagrams, bills of materials (BOM), and test outlines, which should adopt internationally recognised formats and terminology to avoid repetitive revisions caused by differences in expression.
The intelligent allocation of test samples constitutes another critical phase. Ideally, PCBA manufacturers should prepare sufficient test samples for submission to both primary and backup certification bodies for parallel testing. Where sample quantities are limited, a phased strategy may be adopted: the primary certification body completes the full suite of tests, followed by the backup body conducting verification testing on key items. For destructive testing items, a rational sample allocation plan must be devised to ensure both bodies obtain valid data. In accordance with backup strategy principles from search results, this ‘full backup + differential backup’ model guarantees comprehensiveness while enhancing efficiency.
Progress monitoring and risk alert systems are indispensable. Manufacturers should establish certification progress dashboards to track testing advancements and identified issues across both bodies in real time, incorporating early warning mechanisms. Should the primary body experience delays or restrictions, expedited procedures with the backup body can be immediately activated to minimise disruption. Practice demonstrates that enterprises with robust parallel certification management systems experience average product launch delays of merely 10-15 days when a single certification body fails. Conversely, organisations lacking backup strategies may face delays of several months or even indefinite postponements.
Table: Comparative Analysis of Dual-Backup Certification Body Combination Strategies
| Combination type | Geographical advantage | Technical Specifications | Cost implications | Risk diversification effect |
| Internationally renowned institutions | Balancing Eastern and Western demands | Must comply with multiple national standards | Relatively high | ★★★★ |
| International Organisation A+B Different Regions | Mitigate regional policy risks | Inter-agency technical equivalence is required. | Very tall | ★★★★★ |
| Specialist organisations + generalist organisations | Combining specialisation with comprehensiveness | Standard differences require coordination | Medium | ★★★ |
| Government background + commercial organisation | Adapt to the characteristics of different markets | A standardised testing methodology is required. | Medium | ★★★★ |
Risk Mitigation Mechanisms in PCBA Production
The dual-backup strategy for certification bodies represents merely the starting point for risk management. PCBA manufacturers must establish comprehensive risk mitigation mechanisms across broader dimensions. Only through a multi-layered defence system—encompassing supply chains, technical standards, policy monitoring, and emergency response—can enterprises maintain resilience amidst volatile international conditions.
Policy Risk Dynamic Monitoring and Early Warning System
Changes in international certification policies often follow discernible patterns. Establishing a systematic monitoring mechanism enables PCBA manufacturers to anticipate risks proactively and adjust certification strategies accordingly. Key monitoring areas should include: legislative developments in target markets, personnel changes within regulatory bodies, updates to industry white papers and technical standards, and certification cases involving peer enterprises. For instance, the US FCC voted to implement restrictions on Chinese laboratories in May 2025, with formal implementation occurring in September – this time lag provided a buffer period for prepared enterprises.
Diversifying information channels is paramount. Enterprises should combine multiple sources: government gazettes, industry association briefings, internal communications from certification bodies, and analyses from specialist legal counsel. Companies adopting the ‘self-inspection and self-certification’ model must particularly monitor policy documents like the Opinions on Deepening the Reform of the Management System for the Electronic and Electrical Appliance Industry for adjustments to certification requirements. Larger enterprises with the capacity may establish dedicated policy research roles or engage third-party consultancy services to establish a routine policy scanning mechanism.
Risk Assessment and Contingency Planning The ultimate purpose of monitoring. Enterprises must periodically (e.g., quarterly) evaluate collected policy information, categorise risks by potential impact and probability of occurrence, and formulate corresponding response plans. For high-risk, high-probability events (e.g., imminent de-accreditation of specific laboratories), backup certification procedures should be initiated in advance. For low-probability but high-impact events (e.g., nationwide certification suspension), business continuity plans (BCPs) must be prepared. Establishing such a tiered response mechanism ensures enterprises can deliver proportionate and cost-effective reactions to risks of varying severity.
Redundancy Design and Verification for Supply Chain Certification
Certification of PCBAs extends beyond the final assembly plant, relying on compliance throughout the supply chain. From PCB substrates and components to assembly processes, each stage may require corresponding certification documentation. Consequently, backup supply chain certification is equally vital—indeed, often more critical—as raw material certification issues frequently surface later in the process, causing more severe delays.
Dual backup certification for critical components is a fundamental requirement. For core components (such as chips, wireless modules, and power management units), PCBA manufacturers should require suppliers to provide at least two alternative certification pathways. For instance, a wireless module may hold both FCC and CE certifications, or equivalent test reports issued by different certification bodies. This approach is particularly pertinent for products recently subject to mandatory certification in the US, such as lithium-ion batteries and power adapters/chargers. Should certification for these high-risk components lapse, it would directly compromise the compliance of the entire end product.
Supplier certification audits require heightened rigour. Beyond routine quality inspections, enterprises should evaluate suppliers’ certification risk management capabilities, including: diversity of testing laboratories utilised, sensitivity to regulatory changes, and completeness of certification documentation. For high-value or long-lead-time critical materials, ‘pre-certification’ may be considered – whereby two certification bodies concurrently validate material compliance during the design phase to prevent production delays due to certification issues later.
Internal testing capability development provides the ultimate safeguard. PCBA manufacturers of a certain scale may consider investing in internal laboratories to obtain fundamental accreditation such as ISO 17025, thereby establishing a dual assurance system of ‘third-party certification plus self-inspection’. In line with the spirit of the ‘Opinions on Deepening the Reform of the Management System for the Electronic and Electrical Appliance Industry’, the state is promoting the ‘self-inspection and self-certification’ reform for market access of electronic and electrical products. This reduces the absolute reliance on third-party certification bodies for capable enterprises. Naturally, establishing a fully independent laboratory entails significant costs. Small and medium-sized enterprises may achieve comparable functionality through joint investment or utilisation of shared laboratories.
Multi-version Compatibility Design for Technical Standards
Technical standard conflicts frequently pose obstacles in international certification for PCBA products. Certification bodies across different regions may base assessments on varying versions of technical standards or interpret identical standards differently. Addressing these discrepancies during the product design phase can substantially mitigate subsequent certification risks.
A standards comparison matrix serves as an effective management tool. Enterprises may organise technical teams to conduct clause-by-clause comparisons of key certification standards in target markets (e.g., FCC Part 15 in the US, EU’s RED Directive, China’s SRRC certification), identifying discrepancies and compatibility points between standards. For instance, subtle yet critical differences may exist across standards concerning wireless transmission power, electromagnetic compatibility limits, or safety isolation requirements. Compiling these discrepancies into a comparative table and embedding it within product design specifications ensures inherent multi-standard compatibility in the final product.
The modular certification design philosophy further enhances flexibility. By dividing PCBA products into functionally independent modules (e.g., power supply, wireless, control), each module undergoes separate certification. Target markets then combine certified modules as required. This approach, inspired by public-key certification systems for financial IC cards, extends to broader electronics applications. Should a module’s certification falter, it can be swiftly replaced with an equivalent, pre-certified module without redesigning the entire product.
Certification-friendly design is equally crucial. Consideration for certification testing convenience during the product design phase—such as reserving sufficient test points, designing removable shielding covers, and employing programmable RF parameters—may incur minor additional costs. However, these measures substantially reduce certification testing time and complexity. The value of this design philosophy becomes particularly evident when rapid switching between certification bodies is required. Industry experience indicates that certification-friendly design can reduce the certification cycle by an average of 30%, with even greater advantages in urgent situations.
Secure Backup and Management System for Certification Data
Data integrity and security during the certification process are equally critical for the successful market launch of PCBA products.
Comprehensive lifecycle management of certification data—from private key management to test records, and from certificate backup to recovery verification—constitutes a vital component of the dual-backup strategy, yet remains an aspect frequently overlooked by many enterprises.
Backup and Secure Management of Electronic Certification Private Keys
In PBCA product scenarios involving digital certificates (e.g., connected vehicle devices, secure payment terminals), private key management constitutes the core of certification security. Per PBCA production certification standards, the private keys of electronic certification service providers and subscribers’ signing private keys should not be entrusted for custody in principle. However, under necessary circumstances, backups may be implemented under stringent conditions. Such backups are critical for ensuring business continuity but must be executed with guaranteed security.
Multi-person control mechanisms constitute a fundamental requirement for private key backups. The backed-up private key must be segmented into multiple parts, each held by a different responsible party, ensuring no single individual can access the complete key. Concurrently, backup media should be stored in high-security facilities, such as vaults equipped with biometric access control, and subject to 24-hour surveillance. For high-security commercial transaction environments, at least one backup must be stored off-site to guard against natural disasters or regional destruction. While primarily targeting electronic certification service providers, these measures also hold reference value for critical private key management by PCBA manufacturers.
A regular rotation system further mitigates risk. Even without indications of compromise, key pairs should be updated and re-authenticated according to scheduled cycles (e.g., annually). The generation and backup of new private keys must adhere to the same stringent procedures as the original keys, whilst old keys should be securely destroyed under supervision. During the transition period, both new and old keys may be used concurrently to ensure deployed devices remain unaffected. This ‘hot switch’ approach, drawing upon the practical experience of CA construction by financial IC card issuers, effectively balances security and continuity requirements.
Restoration testing is indispensable for verification. Backup private keys must not merely exist in theory; they should undergo regular practical restoration operation tests to ensure functionality when required. Testing must be conducted in an isolated environment, with detailed operational logs recorded and the entire process supervised by auditors. Testing frequency may be determined based on risk assessments, but should generally occur no less than annually. For particularly sensitive systems, quarterly or biannual testing may be considered.
Dual Backup Strategy for Certification Test Data
The substantial volume of test data generated during certification processes likewise requires a robust backup mechanism. This data encompasses test reports, raw records, sample information, and corresponding standards – constituting core supporting documentation for certification applications and vital evidence for subsequent regulatory audits.
Combining full backups with differential backups represents an efficient data backup methodology. Full backups should be performed weekly, capturing complete copies of all certification-related data. Differential backups, conducted daily, record only changes since the last full backup. This combination ensures data security while avoiding the resource consumption of full backups at every instance. In practice, automated scripts can be configured to initiate backups during off-peak business hours (e.g., after working hours), minimising disruption to daily operations.
Multi-media off-site storage enhances the resilience of backup data against risks. Backup data should be stored simultaneously on at least two distinct media types, such as disk arrays and tape, distributed across separate physical locations. Disk arrays offer rapid access suitability for daily operations, while tape provides long-term stability and cost-effectiveness for archival storage. Cloud storage may serve as a third option, offering cross-regional accessibility, but requires careful selection of service providers and detailed service agreements clarifying data sovereignty and security responsibilities.
Lifecycle management ensures the validity of backup data. Certification-related data is not permanently retained; appropriate retention periods should be determined based on its value and regulatory requirements. For instance, incoming material inspection records for PCBA typically require retention for no less than three years, while fundamental product certification data may necessitate longer storage. Data exceeding its retention period should be securely destroyed to free storage space and reduce management complexity. The destruction process must also be documented to demonstrate compliance with relevant regulations and internal policies.
Certificate and Certification Result Verification and Traceability System
Obtaining certification marks only the beginning; ongoing verification and traceability are equally vital. PCB assembly manufacturers must establish systematic mechanisms to ensure products maintain compliance with certification requirements and can swiftly address potential challenges or audits.
Product consistency management forms the foundation of sustained compliance. Post-certification, enterprises must strictly control changes to product design, materials, and processes. Any alteration potentially impacting certification compliance requires reassessment, retesting, or resubmission where necessary. Establishing a Change Control Board—comprising representatives from R&D, quality, certification, and other relevant departments—is an effective practice. This body evaluates change impacts and determines subsequent actions. Concurrently, production lines should maintain detailed configuration records for each batch, ensuring specific product compositions remain traceable when required.
Internal surveillance sampling prevents potential issues. Enterprises should conduct regular internal sampling of certified products based on risk assessment outcomes to verify ongoing compliance. Sampling frequency may reference national surveillance principles, namely ‘annual total control of sampling frequency for similar products from the same enterprise,’ to avoid excessive inspection. Sampling should focus on critical metrics, particularly parameters susceptible to supply chain fluctuations or process drift, such as wireless transmission power and safety isolation performance.
Simulation Drills Enhance Emergency Preparedness. Enterprises should regularly simulate scenarios involving loss of certification data or failure of the certification body, practising how to swiftly restore certification status using backup data and alternative certification bodies. Drill content should include: restoring critical data from backup media, establishing emergency communication channels with backup certification bodies, and accelerating recertification processes. Following each exercise, a detailed assessment report should be produced, identifying shortcomings and refining backup strategies. This ‘firewall drill’ approach significantly enhances an organisation’s crisis response capabilities in real-world scenarios.
Organisational Support and Implementation Pathway
The successful implementation of a dual-backup strategy for certification bodies relies on robust organisational support and a scientifically designed implementation pathway. Comprehensive backing and investment are required across all fronts – from team development and process optimisation to resource allocation and cultural development – to translate the strategy into tangible outcomes.
Cross-Functional Certification Risk Management Team Establishment
Certification risk management should not be confined solely to the remit of quality or certification departments; effective implementation necessitates cross-departmental collaboration. It is recommended that PBCA manufacturers establish dedicated certification risk management teams comprising members from key departments including R&D, quality, production, procurement, and legal affairs. This fosters multi-perspective risk identification and response capabilities.
Defining clear responsibilities forms the foundation for effective team operation. The R&D department is responsible for designing multi-version compatibility of technical standards, ensuring products inherently meet certification requirements across multiple regions. The procurement department develops backup suppliers for critical components to avoid single-source risks. The quality department manages backup and verification of certification data, guaranteeing information integrity and reliability. The legal department monitors policy changes, providing legal risk assessments and response recommendations. This specialised division of labour ensures dedicated personnel for each stage, eliminating management blind spots.
Regular joint meetings facilitate information sharing and rapid response. The certification risk management team should convene monthly meetings to share risk intelligence and mitigation experiences identified by each department, coordinating solutions to cross-departmental issues. In emergencies (such as the sudden withdrawal of accreditation from a certification body), the team can immediately transition to emergency response mode, communicating daily or even in real-time to ensure swift decision-making and execution. Meeting minutes and action items should be properly documented to serve as the basis for management reviews and continuous improvement.
Professional development elevates the team’s overall capability. Certification risk management encompasses broad expertise, including product technology, international standards, testing methodologies, and legal regulations. Enterprises should invest in ongoing education for team members, such as standard interpretation training, certification process optimisation workshops, and policy analysis seminars. Particularly for core personnel, systematic certification-specific training should be provided to cultivate genuine ‘certification specialists’ capable of anticipating issues rather than merely reacting post-event. Concurrently, establish a network of external specialists to swiftly access advisory support for highly specialised or complex issues.
Phased Implementation Pathway for Dual Certification Backup Strategy
Comprehensive implementation of a dual certification backup strategy cannot be achieved overnight. It requires phased advancement, with resource allocation and prioritisation tailored to the enterprise’s actual circumstances and risk tolerance.
Phase One: Risk Assessment and Planning (1-2 months)
– Identify all certification bodies and certification types currently relied upon by the enterprise
– Assess geopolitical risks and technical capabilities of each certification body
– Determine critical certification pathways, prioritising the establishment of dual backups for these certifications
– Develop an overall implementation plan and investment budget
– Secure senior management approval and resource commitment
Phase Two: Backup Certification Body Development and Validation (3-6 months)
– Screen and audit backup certification bodies based on Phase One assessment findings
– Establish cooperative relationships with backup bodies, negotiating special terms (e.g., emergency response mechanisms)
– Conduct parallel certification testing on small product batches to validate backup body reliability and result consistency
– Adjust product design or documentation to ensure compatibility with backup body requirements
– Establish a backup management system for certification data and certificates
Phase Three: Full Implementation and Process Optimisation (Ongoing)
– Formally implement dual backup operation for all critical certifications
– Monitor execution and effectiveness of dual backup strategy
– Periodically review backup agency suitability and adjust as necessary
– Continuously optimise internal processes to minimise additional costs from dual backup
– Extend successful practices to additional certification types and regions
Agile iteration is a key principle throughout implementation. Each phase should establish clear milestones and evaluation criteria, with subsequent plans adjusted based on actual outcomes. For instance, if a backup agency’s capabilities prove inadequate during Phase Two, alternative solutions should be promptly sought rather than mechanically adhering to the original schedule. Simultaneously, appropriate differentiation in implementation pace may be applied across product lines or market regions, prioritising certification security for high-risk, high-value products.
Resource Allocation and Benefit Balancing Mechanism
The dual backup certification strategy inevitably increases operational costs, including higher certification testing fees, more complex administrative overheads, and potential product design adjustment expenses. Enterprises must establish a scientific resource allocation mechanism to ensure limited resources are directed where most needed, achieving an optimal balance between risk control and economic efficiency.
Risk-tiered investment remains fundamental. Enterprises may categorise products into high, medium, and low risk levels based on factors such as product criticality, strategic market value, and consequences of certification failure. For high-risk products (e.g., core revenue-generating products, products entering strategic markets, or products where certification failure would cause significant losses), implement a comprehensive dual-backup strategy, or even consider multiple backups. For medium-risk products, partial backup or shared backup resources may be employed. For low-risk products, a single certification path may be temporarily maintained, subject to ongoing monitoring and adjustment. This differentiated approach can reduce backup costs by 30-50% while still mitigating the most severe risks.
Cost-sharing models facilitate rational decision-making. The benefits of certification backup are holistic (e.g., ensuring business continuity, maintaining market access), yet costs are often borne by specific departments (e.g., compatibility design work by R&D, parallel testing management by quality assurance). . Organisations may establish internal cost-sharing mechanisms, transferring portions of these costs to enterprise-level risk management expenditure through transfer pricing or dedicated budgets. This prevents departments from compromising backup strategy implementation due to cost pressures.
Long-term value assessment transcends short-term costs. When evaluating the return on investment for dual backup strategies, enterprises should focus on enduring value rather than immediate expenditure. This encompasses: avoiding market share losses due to certification failures, reducing costly expedited fees when urgently switching certification bodies, and mitigating potential fines or litigation costs arising from compliance risks. Some enterprises also consider strategic value, such as enhancing customer confidence in supply chain stability and elevating the organisation’s compliance reputation in international markets. While these intangible benefits prove difficult to quantify precisely, they frequently constitute pivotal factors in decision-making.