SRRC + CMIIT: mainland China radio certification
Guide · SRRC / CMIIT
SRRC (State Radio Regulatory Commission), now operating under MIIT (Ministry of Industry and Information Technology), administers radio type approval in mainland China. The visible mark on an approved product is the CMIIT ID, an alphanumeric identifier carried on the label. SRRC covers only the radio portion: electrical safety and electromagnetic compatibility on the same product fall under a separate, parallel scheme, CCC (China Compulsory Certification, 3C), run by CQC. This framing confusion is the most frequent import-side error: for a typical Wi-Fi or cellular IoT product entering the Chinese market, both certifications are required and pursued in parallel, with distinct labs and distinct dossiers. This page describes the scope of SRRC, the CMIIT ID format, the Chinese frequency plans, the approval procedure, and the recurring pitfalls.
SRRC, CMIIT ID and CCC, distinct scopes
Section titled “SRRC, CMIIT ID and CCC, distinct scopes”Three acronyms circulate on datasheets for products targeting the Chinese market, often confused, and definitions are best laid out first.
SRRC (State Radio Regulatory Commission) is the Chinese radio regulator. It operated for many years as a distinct entity under the information industry ministry, and was later integrated into MIIT (Ministry of Industry and Information Technology) through successive central government reorganisations. SRRC remains the technical body responsible for radio type approval (型号核准) and continues to be referenced by that acronym in industrial and regulatory documentation.
The CMIIT ID (China MIIT IDentifier) is the alphanumeric identifier assigned at the end of the SRRC procedure. It is the part visible on the product. It takes the form "CMIIT ID: AAAADJXXXX" or a close variant, where the leading characters encode the year of issuance and the equipment category.
CCC (China Compulsory Certification, 3C mark) is a separate conformity mark covering electrical safety and EMC. It is administered by CQC (China Quality Certification Centre) and carries its own logo (3C). The same IoT product (for instance a mains-powered Wi-Fi gateway) needs SRRC for its radio portion and CCC for its mains supply and EMC. See the dedicated guide CCC / 3C, China product safety and EMC for the detailed mechanism.
Scope table, SRRC vs CCC
Section titled “Scope table, SRRC vs CCC”| Criterion | SRRC (CMIIT ID) | CCC (3C mark) |
|---|---|---|
| Authority | MIIT / SRRC | CQC under SAMR |
| Technical scope | Radio only (transceiver, bands, power, spectral occupancy) | Electrical safety, EMC outside radio, certain product-class requirements |
| Reference text | PRC Radio Regulations, MIIT notifications | CCC regulation, GB standards (Chinese national standards) |
| Identifier | Alphanumeric CMIIT ID | CCC number + 3C logo |
| Lab | Chinese SRRC-accredited lab | Chinese CCC-accredited lab (often a different one) |
| Product marking | "CMIIT ID: ..." in Simplified Chinese | 3C logo + number |
| Local representative | Mandatory, registered with MIIT | Mandatory, CCC agent |
| Independence | Independent of CCC | Independent of SRRC |
A radio product can be placed on the market without CCC if it falls outside the 3C scope (for instance a battery-powered radio module not on the 3C list). Conversely, a mains-powered product without any radio function can be placed on the market without SRRC but requires CCC. Practical rule of thumb: for any consumer IoT product combining a radio and a mains supply, plan for both schemes in parallel.
Regulatory basis
Section titled “Regulatory basis”The framing instrument of the Chinese radio regime is the Radio Regulations of the People's Republic of China, promulgated in its modern form in the early 2010s and amended regularly. It sets the general principles: state monopoly on frequency allocation, mandatory type approval for any radio equipment manufactured, imported, sold or used on the territory, and a sanctions regime.
Below this framing instrument, several levels of instruments provide the technical substance:
- State Council decrees, which articulate the sectoral regimes (amateur, professional, civilian),
- MIIT notifications (Notice or Notification), which constitute the operational layer most consulted by manufacturers: frequency plans, power limits per band, technical requirements per equipment category,
- Chinese national standards (GB, Guo Biao), published by SAC (Standardization Administration of China) and used as a test reference alongside the MIIT notifications.
The most structuring notification for industry is MIIT Notice 423, which frames civilian radio frequency planning. It sets out the sub-bands open to short-range devices (SRD) and longer-range equipment, the power limits, and the indoor/outdoor usage rules. Additional notifications detail the 5 GHz Wi-Fi plan, the sub-GHz LPWA bands, and the cellular allocations to the three national operators.
SRRC equipment categories
Section titled “SRRC equipment categories”SRRC essentially distinguishes two logics:
Type Approval, 型号核准
Section titled “Type Approval, 型号核准”Type approval (型号核准) is the standard procedure, mandatory for nearly all radio equipment manufactured, imported or sold in mainland China. It applies to Wi-Fi, Bluetooth and BLE modules, 4G and 5G cellular modules, LPWA equipment (LoRaWAN on Chinese sub-bands, NB-IoT), RFID modules, professional equipment (PMR, industrial telemetry).
The manufacturer, through its local representative, files a complete dossier with SRRC, accompanied by the test reports of a Chinese accredited lab. SRRC examines the dossier, may request additional tests, and issues the CMIIT ID that must be carried on the product.
Restricted Radio Equipment
Section titled “Restricted Radio Equipment”Some equipment categories are subject to specific restrictions published by MIIT notification: open sub-bands narrower than the ITU Region 3 defaults, stricter power limits, indoor-only enforcement, or bounded transmission duty cycles. These restrictions concern in particular ultra-wideband (UWB) equipment, certain surveillance applications, and historically the upper 5 GHz band.
For these categories, the SRRC dossier must include a demonstration of compliance with the specific restrictions. The band declaration and the power declaration must reflect the limits of the applicable notification exactly: a firmware capable of going beyond the Chinese limits, even where those functions are not marketed in China, may cause approval to be denied until firmware-based region locking is demonstrated.
CMIIT ID format and marking
Section titled “CMIIT ID format and marking”CMIIT ID composition
Section titled “CMIIT ID composition”The CMIIT ID is an alphanumeric identifier typically composed of a four-digit prefix for the year of issuance, followed by several characters encoding the equipment category and an SRRC-assigned serial number. The form presented on the product is conventionally:
CMIIT ID: 2024DJXXXXXX
where the letter encodes the category (for instance DJ for domestic Wi-Fi equipment, other letters for cellular modules and so on, per the SRRC grid in force).
Marking requirements
Section titled “Marking requirements”The product label must carry:
- the full CMIIT ID, readable without magnification under normal use,
- the mandatory regulatory text in Simplified Chinese (中国大陆): model name, manufacturer, importer, usage restrictions where applicable,
- for products subject to CCC, the 3C logo and the associated CCC number, separate from the CMIIT ID.
The CMIIT ID must be permanently affixed. For products too small to carry the full marking, a derogation allows part of the information to be reported on the packaging and in the documentation, provided the CMIIT ID appears on at least one of the two physical supports. English-only labelling is a recurring ground for rejection in market surveillance on consumer products.
Listing in the MIIT public database
Section titled “Listing in the MIIT public database”Once issued, the CMIIT ID is listed in the public lookup database maintained by MIIT (srrcccc.miit.gov.cn). This listing is verifiable by customs, distributors and market-surveillance authorities. Absence of a listing, or a listed CMIIT ID that does not match the product actually imported, is treated as a non-approval: possible seizure, customs hold, administrative sanctions against the reseller.
Chinese frequency plans
Section titled “Chinese frequency plans”Chinese frequency plans, published by MIIT notification, have their own specifics. The table below summarises the main differences with the EU (ETSI) and US (FCC) plans.
| Band | EU (ETSI / CEPT) | US (FCC) | Mainland China (MIIT) |
|---|---|---|---|
| 2.4 GHz ISM | EN 300 328, up to 100 mW EIRP | Part 15.247, up to 1 W conducted | Aligned, limits close to ETSI, dedicated MIIT notification |
| 5 GHz Wi-Fi (U-NII-1) | 5150-5350 MHz, indoor on lower band | U-NII-1 open | 5150-5350 MHz, indoor-only on the lower band, more restrictive plan |
| 5 GHz Wi-Fi (U-NII-2) | 5470-5725 MHz under DFS | U-NII-2 under DFS | Historical restrictions, partial opening per notifications |
| 5 GHz Wi-Fi (U-NII-3) | 5725-5875 MHz | 5725-5850 MHz | 5725-5850 MHz typically open |
| Sub-GHz LPWA | 868 MHz (EN 300 220) | 902-928 MHz (Part 15.247) | 868 MHz NOT available, alternatives 470-510 MHz, 779-787 MHz, 920-925 MHz (limited) |
| 5G n78 (3.5 GHz) | 3GPP harmonised band | Close to CBRS | Widely deployed, assigned to the national operators |
| 5G n79 (4.9 GHz) | Limited use | Limited use | Distinct deployment, Chinese-specific plan |
| 5G mmWave (n257, n258, n260, n261) | 26 and 28 GHz bands | 24, 28, 37, 39 GHz bands | Different deployment, mmWave lower priority than sub-6 GHz |
The most differentiating point for a European product is the 868 MHz band, which is not available in mainland China. LPWA applications designed for 868 MHz (LoRaWAN EU868, Sigfox RC1, Z-Wave Europe) need to be redesigned for the Chinese market on the 470-510 MHz, 779-787 MHz or 920-925 MHz sub-bands, depending on permitted power and duty-cycle rules. A product that merely switches a firmware region without electrical validation will not pass SRRC: the RF chain (filter, antenna, power stage) has to be adapted to the Chinese band actually used.
For 5 GHz Wi-Fi, the open subset of channels is more restrictive than the EU and US plans, particularly on the intermediate bands. A Wi-Fi 6 firmware (802.11ax) must be configurable to respect the Chinese plan, failing which the band declaration to SRRC will be incomplete and the dossier rejected.
For cellular bands, the Chinese allocations to the three national operators (China Mobile, China Telecom, China Unicom) are specific and do not match the European or North American allocations. A global cellular module (for instance a multi-band 4G Cat M1 module) needs an operator variant or a firmware compatible with the bands actually used on the target network.
Accredited labs and recognition of foreign reports
Section titled “Accredited labs and recognition of foreign reports”SRRC relies on a network of accredited labs established on Chinese territory. SRRC filings are always supported by a test report from a Chinese accredited lab, even in cases where witness testing or manufacturer reports are reused.
Recognition of foreign test reports remains limited and conditional:
- for some radio categories, bilateral arrangements or technical protocols allow a foreign report to feed into the dossier as a supporting document, but not to replace the Chinese report,
- for the critical tests (spectral occupancy, power, harmonics on the Chinese bands), a fresh test cycle runs in China,
- for the EMC portion under CCC, the Chinese lab runs its own tests against the applicable GB standards.
In practice, a European manufacturer plans for an SRRC test cycle distinct from the CE / FCC cycle, with lead times that depend on the workload of the Chinese accredited labs. The CE and FCC report remains useful internally to frame the Chinese tests and identify likely deltas, but it does not substitute for the SRRC report at filing. See also certification timeline for cross-cutting orders of magnitude.
Chinese local representative
Section titled “Chinese local representative”A foreign manufacturer cannot file an SRRC dossier directly. The filing and document retention must go through a local representative resident in mainland China, registered with MIIT, with several duties:
- act as the official point of contact for SRRC and MIIT, receive correspondence and respond within deadlines,
- retain the technical file and test reports for the prescribed period,
- declare any hardware or firmware modification that could invalidate the CMIIT ID,
- ensure traceability in case of incident, recall or market-surveillance request.
The representative can be:
- the Chinese distributor of record for the product, when one exists and accepts the role,
- a local subsidiary of the manufacturer, legally established in mainland China,
- a third-party agent specialised in approvals and registered with MIIT, paid specifically for the function (common model for manufacturers without a Chinese commercial footprint).
Absence of a designated representative is grounds for immediate rejection of the dossier. The choice of representative is not neutral: its responsiveness drives the examination lead time, and its legal solidity drives its ability to carry the obligation throughout the product's commercial lifecycle.
Step-by-step procedure to CMIIT ID
Section titled “Step-by-step procedure to CMIIT ID”Without committing to a precise schedule, the typical sequence for a foreign manufacturer approaching SRRC for the first time is as follows.
- Freeze the product specification (hardware, firmware, antenna, accessories) and identify the applicable schemes: SRRC for the radio portion, CCC for the mains supply and EMC, cellular operator qualification where applicable.
- Designate a local representative resident in mainland China and registered with MIIT, by written contract. No filing is possible without one.
- Identify the applicable MIIT notifications for the bands used: 2.4 GHz plan, 5 GHz plan, sub-GHz LPWA plan, cellular plans. Verify that the product stays within the open Chinese sub-bands and power limits.
- Adapt the firmware to the Chinese frequency plan: region lock, masking of unauthorised channels, indoor-only configuration where mandated, removal of forbidden bands (typically 868 MHz LPWA).
- Select a Chinese accredited lab for the radio tests. Agree a test protocol consistent with the applicable MIIT notifications.
- Prepare samples in the serial-production configuration, with firmware frozen to the Chinese region and complete accessories, and ship them to China (temporary customs formalities handled by the representative or the lab).
- Conduct the SRRC tests: spectral occupancy, conducted and radiated power, harmonics, intermodulation, on the Chinese bands and per the limits of the applicable notifications.
- Compile the technical file in Simplified Chinese or bilingual (schematics, BOM, antenna plan, band declaration, user manual with regulatory text in Chinese).
- File the SRRC dossier through the local representative. Respond to any MIIT requests for additional information.
- Receive the CMIIT ID, integrate it into the product marking, validate the final label in Simplified Chinese, verify the listing in the srrcccc.miit.gov.cn public database.
- In parallel, pursue the CCC procedure for electrical safety and EMC through CQC: accredited CCC lab, GB tests, filing through a CCC agent, issuance of the CCC number and 3C logo. See CCC / 3C, China product safety and EMC.
- Pursue cellular operator qualifications where applicable: China Mobile, China Telecom, China Unicom each impose an additional network validation, with their own labs and their own lead times.
- Maintain the certification: change management on hardware and firmware (any RF chain change may invalidate the CMIIT ID), document retention by the representative, update if a new MIIT notification changes the applicable plan.
Chinese cellular operator qualifications
Section titled “Chinese cellular operator qualifications”SRRC is a necessary but not sufficient condition for deploying a cellular product on Chinese networks. Each national operator imposes its own network qualification:
- China Mobile (CMCC), the largest mobile operator worldwide, runs a dedicated programme for validating cellular modules on its bands and its core network,
- China Telecom (CT) maintains its own approved-module list, with distinct technical requirements,
- China Unicom (CU) operates a similar programme of its own.
These operator qualifications typically cover the bands used, the access protocols (notably IMS for VoLTE), 5G NSA and SA profiles, and certain specific behaviours (handover, emergency handling). They sit on top of SRRC without replacing it. For the equivalent mechanism on the North American side, see PTCRB, where AT&T, Verizon and T-Mobile operator certifications typically apply on top.
SRRC, CE and FCC, what does not transfer
Section titled “SRRC, CE and FCC, what does not transfer”The comparison often useful for product teams encountering SRRC after having managed CE and FCC.
| Criterion | CE (RED) | FCC (Part 15) | SRRC / CMIIT |
|---|---|---|---|
| Scope of the mark | RED for radio | Part 15 for unlicensed radio | SRRC for radio only, CCC in parallel for safety and EMC |
| Transferability of a foreign test report | Reusable across EU accredited labs | Reusable across recognised FCC labs | Near zero, tests redone in a Chinese lab |
| Lab required | EU accredited lab (or MRA) | FCC-recognised lab (TCB for Part 15) | Chinese SRRC-accredited lab |
| Label language | Member-state language | English | Simplified Chinese for consumer products |
| Local representative | EU authorised representative if non-EU manufacturer | FCC agent | Resident representative in mainland China, registered with MIIT |
| Product identifier | Notified-body number where applicable | FCC ID | CMIIT ID |
| Self-declaration possible | Module A and certain combined modules | DoC for some equipment | No, MIIT examination is systematic for radio |
The table sums up the classic mistake: a product fully certified to CE and FCC should be treated, for mainland China, as not certified. See also CE vs FCC for the EU vs US comparison, which share more mechanisms.
Common pitfalls
Section titled “Common pitfalls”| Pitfall | Consequence |
|---|---|
| Assuming a Hong Kong, Taiwan or Macau approval covers mainland China | Customs seizure, non-conformity finding, full SRRC filing to be redone |
| Designating the local representative late in the project | Filing blocked, industrialisation delayed, weak tariff negotiation |
| Keeping an 868 MHz LPWA firmware for the Chinese market | SRRC rejection, band not available, RF chain redesign needed |
| Declaring 5 GHz Wi-Fi channels copied from ETSI or FCC plans | Band plan inconsistent with the MIIT notifications, dossier rejected |
| English-only labelling on a consumer product | Rejection in market surveillance, commercial withdrawal |
| Conflating SRRC and CCC, filing only one of them | Product not placeable on the market, either the radio portion or the mains portion uncovered |
| Modifying the RF chain after certification without refiling | CMIIT ID invalidated, exposure to recall and MIIT sanctions |
| Neglecting the public listing on srrcccc.miit.gov.cn | Legitimate doubt from customs and distributors, logistics holds |
| Treating SRRC as sufficient for a cellular module | Module approved but not usable on operator networks without further qualification |
| Underestimating cellular deltas (n78 deployed, n79 distinct, mmWave specific) | Multi-band module unfit for the Chinese plan, operator qualification impossible |
Further reading
Section titled “Further reading”- CCC / 3C, China product safety and EMC: the scheme parallel to SRRC, required for nearly all mains-powered IoT products
- RED, CE radio marking: the EU equivalent on the radio side
- FCC: the US scheme, structurally the closest to SRRC on the product-identifier logic
- CE marking: for the reading of the CE mark and its articulation with RED
- PTCRB: North American cellular qualification, the conceptual analogue of the China Mobile, China Telecom and China Unicom programmes
- Certification timeline: cross-cutting orders of magnitude for the phases
- Parallel EU and US certification: the logic of mutualising the test cycles
- Glossary: definitions of SRRC, MIIT, CMIIT ID, CCC, CQC, GB
Sources & references
- MIIT, Ministry of Industry and Information Technology (official portal) , MIIT www.miit.gov.cn/index.html
- SRRC certificate search (CMIIT ID lookup) , SRRC / MIIT srrcccc.miit.gov.cn/
- MIIT Notice 423, civilian radio frequency planning , MIIT www.miit.gov.cn/zwgk/zcwj/wjfb/index.html
- CQC, China Quality Certification Centre (CCC / 3C authority) , CQC www.cqc.com.cn/www/english/
- ITU, Radio Regulations (Region 3, international context) , ITU www.itu.int/pub/R-REG-RR