China: CNAS issues new rules for handling appeals, complaints and disputes, CNAS-R03:2026 — complaints only against already accredited bodies and ten grounds for not accepting them
On 28 September 2026 the China National Accreditation Service for Conformity Assessment (CNAS) published its letter of 22 September issuing CNAS-R03:2026, which replaces the 2019 edition and applies from the date of issue. The attached comparison of changes in 31 items shows a narrower scope of appeals and complaints and new rules against abuse of the right to complain.
- Letter No. 69 of the CNAS secretariat was addressed to certification bodies, laboratories, inspection bodies and validation and verification bodies; the document can be downloaded from the CNAS website under the general rules. An appeal can now be lodged against five kinds of decision: refusal to accept an application, change of the scope of accreditation, refusal to grant accreditation, suspension and withdrawal — refusal to continue an assessment, a request for corrective action and “any other action impeding the attainment of accreditation” were dropped from the 2019 list.
- An appeal is lodged within 10 working days of receiving the decision, with grounds set against the basis of the CNAS decision and with genuine evidence, under the company seal. It is handled within 60 working days of acceptance, with a possible extension of at most 6 months whose reasons are given to the appellant in writing; the appeals committee meets with at least 5 members, and if no quorum can be reached within 45 working days the case is handled in writing, where the ruling needs the support of more than 2/3 of those voting.
- Complaints are accepted only against CNAS and its staff (concerning accreditation activities and breaches of rules or procedures) and against the activities of already accredited bodies, within the accreditation requirements and scope; information on applicant bodies is taken into account during assessment, and complaints concerning customers of accredited bodies (e.g. organisations certified by them) were dropped from the scope. The complainant must give identification details and a specific request; the new clause 6.3.2 lists ten grounds for not accepting a complaint, including false information, a matter accepted or handled by a court, arbitration or administrative body, more than three years since the complainant knew or should have known of the infringement, and mass or collusive complaints against the same body within a short period.
- Also new are joint complaints (with two representatives), merging of complaints supplemented with new facts, encouragement of settlement, and a rule that persistent malicious reports are not accepted and their authors may face legal liability; a complaint against an accredited body may first be handled by that body at CNAS’s request, and the investigation normally takes up to 90 working days. The reference to ISO/IEC 17011 was replaced by the identical GB/T 27011; that standard defines a complaint (3.20) as dissatisfaction with the activities of the accreditation body or an accredited conformity assessment body, and an appeal (3.21) as a request for reconsideration of an adverse accreditation decision.
Source: CNAS — 关于修订发布CNAS-R03:2026《申诉、投诉和争议处理规则》的通知 (认可委（秘）〔2026〕69号, 22.09.2026; z zestawieniem zmian)