China RoHS – an overview

Hello there, and welcome to my new weekly rambling on all things legislation, and the impact on our industry. Recently, I have read through what seemed like endless documents on China RoHS. One tip though, while the internet is an obvious source of information, some of the older documents are now out of date, and certain details have changed, so beware. As the world gradually comes to terms with the RoHS (Restriction of use of Certain Hazardous Substances) Directive that came into force across European Member States in July 2006, we now have new legislation to consider. Stage one of the “Measures for Administration of the Pollution Control of Electronic Information Products” hereafter called “China RoHS!!” comes into effect on March 1st. While core elements of the European legislation, such as the maximum permitted levels of restricted substances, remain the same, China RoHS contains several unique features. Stage one, from March, is fundamentally about labelling products (from a comprehensive, but not exhaustive, list of Electronic Information Products or EIP’s) correctly based on whether or not they contain any restricted substances. Stage two is when it really “kicks off” as a catalogue will list products that do have substance restrictions, and these are not necessarily limited to the six substances that form the basis of EU RoHS. This catalogue, exact release date still unknown, will also include details of any exemptions as well as the implementation date by product. The scope of China RoHS is broader than the EU and includes product categories such as test equipment, medical, sub assemblies and electronic components that are not currently within the scope of EU RoHS. Other differences include variable implementation dates, madatory inspection and testing as well as clearly marking the actual packaging with the appropriate symbol and words. A disclosure table, in Chinese, indicating which substances are present, and where they can be located in a piece of equipment, is also a requirement. Finally, an EFUP, or Environment Friendly Use Period, must be included as part of the symbol denoting hazardous substances are present. This represents the period, in years, during which any of the substances present will not leak out and cause environmental pollution. Finally for now, if you build and ship products into China that feature in the catalogue, be ready to send a sample off for testing and analysis by one of the approved labs in China, as well as seeking CCC accreditation (China Compulsory Certification). The implementation date, in theory, will allow sufficient time to do this once the product appears in the catalogue. That’s enough on China RoHS for now but much more during coming weeks. I look forward to receiving your thoughts on RoHS, WEEE, EuP, REACH, ATEX, the Battery Directive or anything else “Green” especially if you are a Design Engineer who has had to make process changes to accommodate any of the new legislation. Directive Decoder

Leave a Reply

Your email address will not be published. Required fields are marked *