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The Chinese government has created regulations to address environmental pollution resulting from the disposal of electronic products, promote resource utilization, encourage environmentally-friendly consumption, and safeguard public health, What is the current status of the implementation of China RoHS2?

• March 1, 2007 : On, the Measures for the Control of Pollution from Electronic Information Products came into effect after being promulgated on February 28, 2006.
• July 16, 2010 : The regulations for controlling pollution from electrical and electronic products were made available for public comment.
• July 2016 : Decree No. 39 was issued to restrict the use of hazardous substances in electronic products
• March 2018 : The Catalogue of the Restricted Use of Hazardous Substances in EEE Products and the Exemption List were prepared
• May 16, 2019 : the government agencies established the Conformity Assessment System for Hazardous Substances in Electrical and Electronic Products
• November 1, 2019 : Products listed in the Catalogue the Restricted Use of the Hazardous Substances Contained in EEE Products that are entering the market or imported must comply with the Implementation Arrangement.

"Electrical and electronic products" are devices and accessories that operate using electric current or electromagnetic fields with a rated working voltage of up to 1500V DC and 1000V AC, or those that produce, transmit, or measure such currents or fields. This definition does not include power generation, transmission, and distribution equipment.

China RoHS includes batteries while EU RoHS does not.

China RoHS2 has a two-step process for limiting the use of six hazardous substances.

The categories of electrical and electronic equipment exempted from the restrictions on the use of hazardous substances under China RoHS2:

• Equipment for electricity production, transmission, and distribution
• Military electrical and electronic equipment
• Equipment designed for special or extreme circumstances
• Electrical and electronic equipment intended for export
• Temporary imported or serviced electrical and electronic products
• Prototypes used for research and development purposes
• Samples and products displayed at exhibitions, not intended for sale.

It is not a requirement for something to be compliant in ChinaRoHS to be compliant in Eu RoHS, and this is a misconception.

China RoHS 1st Step:

There are no requirements for substitution or limitation of toxic substances in electrical and electronic products under China RoHS2. Manufacturers must label hazardous substances in their products since July 1st, 2016.

Currently, all regulated products must comply with step one of China RoHS2, which involves providing proper labeling to assist consumers and recycling factories in identifying information about restricted substances.

Environmental-Friendly Use Period (EFUP)

• EFUP refers to the time period, expressed in years, where toxic and hazardous substances or elements contained in an EIP remain stable under normal operating conditions without causing pollution or damage to human life or the environment.
• Manufacturers are responsible for choosing an Environment-Friendly Use Period (EFUP) number to comply with "China RoHS." This number is typically based on factors such as the expected lifespan and reparability of the product, as well as the potential for chemical release from the product.
• The EFUP is calculated by adding the expected service life, the time between production and putting into service, and the likely extended service life if repairs or refurbishments are possible.
• The start date of the Environment-Friendly Use Period can be indicated by the "Date of Manufacture" marked on the product.
• EFUPs less than or equal to 10 years should be a whole number between 1 and 10. EFUPs greater than 10 years should be a multiple of 5. If the EFUP is not a multiple of 5, it should be rounded down to the nearest multiple of 5. For instance, an EFUP of 18 years should be rounded down to 15 years.

China RoHS Table

Manufacturers and importers must determine and mark the environmental protection use period (measured in years) for a product that exceeds concentration limits of certain hazardous substances. The date of manufacture must also be indicated. They are also required to provide the names and contents of the hazardous substances in the product instructions and mark them on the parts using the specified table. However, the hazardous substance information does not need to be marked on the product itself.

China RoHS 2nd Step:

• Products listed in the Compliance Management Catalog must comply with substance restriction limits based on relevant standards, and their compliance will be assessed using the conformity assessment scheme.
• From November 1, 2019, manufacturers must obtain voluntary certification and make a Declaration of Conformity for their products to comply with China RoHS2.

The Compliance Management Catalog comprises 12 different types of products.

1. Refrigerators
2. Air conditioners
3. Washing machines
4. Electric water heaters
5. Printers
6. Copiers
7. Fax machines
8. Televisions
9. Monitors
10. Microcomputers
11. Mobile communication handsets
12. Telephones

China RoHS 3rd Step:

To demonstrate compliance with the pollutant limit requirements for E&E products, suppliers have two options:

1. provide a test report from a qualified laboratory
2. create a conformity report based on pollutant determinations for all components, parts, and raw materials. The supplier is responsible for ensuring the accuracy, completeness, and consistency of the self-declaration and associated technical documents

The platform user or applicant must be registered in China, and companies based in the EU are not eligible to apply for self-declaration.

Self-Declaration

This pertains to a type of conformity assessment where the supplier (which could be the manufacturer, authorized representative, etc.) independently employs a suitable method to conduct the assessment of conformity and submits information that verifies that the electrical and electronic products being supplied meet the relevant standards and technical requirements for limiting the use of harmful substances.

State-Promoted Voluntary Certification

This refers to a certification process that businesses can choose to undertake voluntarily, which involves third-party certification bodies verifying that electrical and electronic products meet the appropriate standards and technical requirements for limiting the use of harmful substances. This process is overseen and regulated by the State in a uniform manner.

The placement of the logo is required on the product and can also be added to the packaging. Adding the label to the packaging can make it easier for customs to confirm compliance.

• If the size of the product is larger than 5mm by 5mm, the logo must be placed on the product.
• For products that are too small with dimensions less than 5mm x 5mm, the logo can only be placed on the packaging. However, in both cases, whether the logo is on the product or the packaging, it is required to include the marking information in the product manual.

China RoHS Testing Standards

Ahmed Sakr

Product Compliance Consultant 

ComplyMarket UG (haftungsbeschraenkt)