When is assurance voluntary or mandatory?
Article 25 of the Cryptography Law and Article 12 of the implementing regulation encourage voluntary commercial-cryptography . Voluntary assurance does not waive Article 11: the activity must still comply with applicable laws, administrative regulations, mandatory national standards, and the operator's publicly declared standards. Testing and certification bodies must hold the required qualifications and work within their approved scope under the applicable technical specifications and rules.
Mandatory assurance applies to a narrower group. A commercial-cryptography product involving national security, the national economy and people's livelihoods, or the public interest must be included in the catalogue of and pass qualified before sale or provision. Both conditions matter: a cryptographic product outside that catalogue, or a listed network product that is not commercial cryptography, does not enter this mandatory route on those facts alone. A commercial-cryptography service that uses critical network equipment and specialised cybersecurity products must pass service certification.
The current network-product catalogue, effective since 3 July 2023, includes routers, switches, rack servers, and PLC equipment that meet stated technical thresholds, plus categories such as firewalls, intrusion-detection systems, VPN products, public-key infrastructure, file-encryption products, and identity-authentication products. Match the exact product and threshold. Do not substitute the separate commercial-cryptography product certification catalogue, which supports the national voluntary certification system, for the mandatory network-product catalogue.
The official interpretation explains that bodies issuing proof-bearing data or results for product testing or application security assessments must obtain commercial-cryptography testing-body qualification.
Articles 25 and 26 distinguish voluntary testing and certification from mandatory assurance for specified products and services.
Articles 11-21 state the standards duty, distinguish testing from certification, set body qualifications and scope controls, and state the mandatory product and service routes.
The joint-authority catalogue supplies the current categories and technical thresholds used for the mandatory product-route match.
The official announcement identifies the separate commercial-cryptography product certification catalogue and certification rules; Regulation Article 17 places that catalogue within the unified voluntary certification system.