Does a Chinese OEM's filing permit a supplier or substrate change without prior review?

Does a Chinese OEM's filing permit a supplier or substrate change without prior review?

A change of supplier or substrate produces a different article, and whether it needs review first is set by the filing and the authority, not by C-POLAR.

C-POLAR supplies a materials technology. The published position is that every commercial NanoFlashing™ product is made by a manufacturing partner, in their facility, in their format. The published Terms of Use state: “The manufacturer and seller of a finished product are responsible for its design, manufacture, labeling, instructions, claims, sale, and warranty, except for a responsibility C-POLAR expressly accepts in a Separate Agreement.” They also state: “Unless a Separate Agreement expressly says otherwise, C-POLAR is not the manufacturer or seller of a finished product merely because that product uses or refers to C-POLAR technology.” C-POLAR has published no classification or certificate for China. A locally converted material and an imported finished product are different articles, and a change of material or of maker produces a different article. The published Terms of Use state: “A test of C-POLAR material, a component, or a prototype does not establish the performance of a finished product that incorporates it.” The published position is that development runs configuration by configuration, and each partner controls what is said about the work. General enquiries go to [email protected].

Source: C-POLAR — About, https://cpolar.tech/about/; C-POLAR — Terms of Use, https://cpolar.tech/terms/.

Reviewed on 21 September 2026.