China RoHS 2007-2012
In March 2007 the first phase of the China RoHS legislation known as the Administration of the Control of Pollution (caused) by Electronic Information Products (EIPs) was implemented.
This was known as the “Declaration” stage and included the labelling of over 1800 EIPs.
A green symbol indicated that no restricted substances where present above permitted levels. The six substances aligned with the EU RoHS Directive as did the maximum concentration values.
The second symbol, that was typically, although not obligatory, orange was specified as the hazardous substance symbol were the product contained a substance, or substances, that were above the permitted values. The orange symbol also had to include the Environmentally Friendly (safe use) Period, or EFUP, in years. This was the period of time that it was safe to use the equipment before hazardous substances could leak out into the environment. A mobile phone, for example, might be 10 years.
Where a toxic substance was present a disclosure table highlighting its location in the product was required in Chinese language.
Phase two of China RoHS was the Restriction stage. This is where a “Catalogue” of products would highlight substance restrictions on some, all or even more than the six restricted by EU RoHS. The Catalogue would define exemptions by product as well as where testing was required, via an authorised Chinese lab, and where China Compulsory Certification was required.
This Phase was due to be implemented at the end of 2007 but slipped to the middle of 2008 and, four years on, we are still waiting.
China RoHS applies to products imported into China for sale in China and products manufactured in China and sold in China, but exclude those imported into China for re-export or manufacturing of products for export.
A draft China RoHS Catalogue was published in October 2009 and issued for consultation. Around that time China RoHS was reviewed by the World Trade Organisation barrier to trade committee.
Later plans were published to form greater alignment with the scope of EU RoHS and move the emphasis from EIPs to Electrical and Electronic Products or EEPs.
So, we are still waiting and the word from China is “soon” so maybe sooner rather than later. In the meantime the Phase 1 labelling requirements still have to be adhered to.