China RoHS – New EFUP Guidance

Further draft Guidance on the Environment Friendly Use Period (EFUP) highlights a few changes. Previously the number of years within the orange logo, which indicates the product contains RoHS substances above the maximum permitted concentration values, ran in sequence 1,2,3,4,5 then in multiples of 5.

It is now defined as increments of a year up to 10 years, then multiples of 5, up to 95. You will remember that the EFUP is the period of time before any of the RoHS substances are likely to leak out, causing possible harm to health and the environment. Some guide examples in the latest draft standard have also been amended. A cellphone is now “safe” for 10 years as opposed to 5 years in the previous draft. Makes sense I guess, especially as these substances should not leak out in the first place. Please share any detail with this column if you have experience to the contrary. Other examples include laptop PC’s at 8 years, while a digital camera, LCD monitor and desktop PC are all specified as 10 years. There are still several possibilities for determining the EFUP.

Two methods currently popular with manufacturers are:

1. A figure from the annex, as above, if the product is either the same or similar to the examples listed, made in a similar way using comparable materials

2. Based on the “technical life”.

In reality, this is the longest time (not the average) that a product will take from the date of production until the date it is recycled. This will include time after production and before being put into service as well as time after refurbishment or repairs. No doubt further draft standards will be published on this subject over time just to keep manufacturers on their toes!!

No-one wants to quote an EFUP that is too optimistic and face the wrath of the authorities, likewise quote an EFUP that is shorter than your competitors and face losing market share! As always, please contact me with any points regarding China RoHS or legislation, in general, that impacts our industry. Directive Decoder.


One comment

  1. Hello,

    Can you please explain to me the wisdom of the Chinese in not allowing the slightest of exemptions for products? Like the addition of 4% Pb for machining purposes in brass or up to 0.4% Pb in steels, etc.

    Thank you very much!

    Kind regards,

    Dr. Mike Reeder

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