China RoHS is currently running just under two years late. Requests for China RoHS certificates of compliance are not applicable, although European based companies that export to China have had to supply the relevant disclosure tables (and labels) for some time now.
Phase one of China RoHS was implemented on time in March 2007.
Here, over 1,800 Electronic Information Products, or EIP, had to be labelled based on whether or not they contained one of the six restricted substances (same as EU RoHS) at levels below the permitted homogeneous value (typically a green label) or above these values (orange label).
If it was a case of the latter then other information was required including an environmentally safe use period and a disclosure table highlighting toxic and hazardous substances and their location in the product, so as to aid safe recycling.
Phase two was to introduce the products that would be in scope, any exemptions, substance restrictions (option for even more than the EU six) compliance dates and testing and certification requirements.
It was due to enter into force at the end of 2007, then slipped to end 2008, then mid 2009 and now probably early next year.
So, regardless of slippage, if you export to China for sale in China you already have obligations.
Directive Decoder