The Chinese government has established regulations to address environmental pollution caused by the disposal of electronic products, promote resource use, encourage environmentally friendly consumption, and protect public health. What is the implementation status of RoHS2 in China?
- March 1, 2007: Measures to prevent pollution from electronic information products and other products were published and implemented on February 28, 2006.
- July 16, 2010: Regulations to control pollution from electrical and electronic products have been published in the Public Comments.
- July 2016: Cabinet Order No. 39 has been issued restricting the use of hazardous substances in electronic products.
- March 2018: A catalogue and exclusion list for use of hazardous substances in EEE products has been created
- May 16, 2019: Government agencies have established a system for assessing the conformance of hazardous substances for electrical and electronic products
- November 1, 2019: Products listed in the Restriction Catalog of Hazardous Substances in EEE Products that are brought to the market or imported must comply with the Implementation Agreement.
"Electrical and Electronic Products" refers to devices and accessories that operate using currents or electromagnetic fields with a operating voltage rated up to 1500V DC and 1000V AC, or equipment and accessories that generate, transmit or measure such currents or fields. This definition does not include power generation, power transmission, or power distribution facilities.
China's RoHS includes batteries, but EU's RoHS does not.
China's RoHS2 has a two-stage process to limit the use of six hazardous substances.
Categories of electrical and electronic equipment exempt from restrictions on use of hazardous substances under China's RoHS2:
- Equipment for electricity production, transmission and distribution
- Military Electrical and Electronic Equipment
- Equipment designed for special or extreme situations
- Electrical and electronic equipment for export
- Temporarily imported or repaired electrical and electronic products
- Prototypes used for research and development purposes
- These are samples and products displayed at the exhibition and are not intended for sale.
Those that are compliant with China's RoHS do not need to comply with EU's RoHS. This is a misunderstanding.
China RoHS No.1 Steps:
China's RoHS2 does not have any requirements for the replacement or limitation of hazardous substances in electrical and electronic products. From July 1, 2016, manufacturers must label their products with hazardous substances.
Currently, all regulated products must comply with step 1 of China RoHS2. This includes providing appropriate labels to allow consumers and recycling plants to identify information about restricted substances.
Environmentally friendly duration of use (EFUP)
- EFUP refers to the period in which toxic and harmful substances or elements contained in EIP are maintained stable under normal operating conditions without causing pollution or damage to human life or the environment.
- The manufacturer is responsible for choosing an environmentally friendly period of use (EFUP) number to comply with "China RoHS". This number is usually based on factors such as the expected lifespan of the product, repairability, and the likelihood that chemicals will be released from the product.
- EFUP is calculated by adding the expected life expectancy, the time from manufacture to start of use, and the life expectancy that could be extended if repairs or renovations are possible.
- The start date of the environmentally friendly usage period can be determined by the "Date of Manufacturing" listed on the product.
- EFUPs of 10 years or less must be an integer between 1 and 10. EFUPs over 10 years must be multiples of 5. If EFUP is not a multiple of 5, it must be truncated to the nearest multiple. 5. For example, the 18-year EFUP should be truncated to 15-year.
China RoHS Table
Manufacturers and importers must determine and mark the period of environmental protection use (measured in years) for products that exceed the concentration limits of certain hazardous substances. The date of manufacture must also be displayed. It is also mandatory to include the name and content of the hazardous substance in the product manual and mark the parts using the specified table. However, there is no need to display information about hazardous substances on the product itself.
China RoHS 2nd edition Steps:
- Products listed in the Compliance Management Catalog must comply with substance limit restrictions based on relevant standards, and their conformance will be assessed using a conformance assessment scheme.
- From November 1, 2019, manufacturers must obtain voluntary certification and declare conformance in order for their products to be compliant with China's RoHS2.
The Compliance Management Catalog consists of 12 different products.
- refrigerator
- Air conditioner
- washing machine
- Electric water heater
- printer
- Copy machine
- fax
- tv set
- monitor
- Microcom
- Mobile communication terminal
- phone
China RoHS 3rd Edition Steps:
Suppliers have two options to demonstrate compliance with contaminant limiting requirements for E&E products.
- Provide test reports from qualified labs
- Compliance reports are created based on the determination of contaminants in all components, components and raw materials. Suppliers are responsible for ensuring the accuracy, completeness and consistency of their self-declaration and related technical documents.
Platform users or applicants must be registered in China, and EU-based companies are not eligible to apply for self-report.
Self-declaration
This involves a type of conformance assessment in which a supplier (manufacturer, authorized agents, etc.) uses a unique and appropriate method to conduct a conformance assessment and submits information to verify that the electrical and electronic products supplied meet the standards. Related standards and technical requirements to limit the use of hazardous substances.
Voluntary certification promoted by the state
This refers to a certification process that companies can choose to do voluntarily. This includes third-party certification bodies that verify that electrical and electronic products meet appropriate standards and technical requirements to limit the use of hazardous substances. This process is supervised and regulated in a state-uniform manner.
Logo placement is essential for the product and can also be added to the packaging. Adding labels to a package makes it easier for customs to check compatibility.
- If the product size exceeds 5mm x 5mm, you must place the logo on the product.
- For products that are too small, less than 5mm x 5mm in size, the logo can only be placed in the package. However, whether the logo is on the product or on the packaging, the product manual must include marking information.
China's RoHS Examination Standards
Ahmed Sakr
Product Compliance Consultant
ComplyMarket UG (Haftungsbeschraenkt)
