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Products are listed
in the Catalog for Priority Pollution Control (sometimes translated
Key Administrative Catalog or Key Management Directory) only when substitutions for RoHS substances are
"technically mature and economically viable": |
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The catalog will
evolve over time, expanding as the technology for RoHS substitutions
develops and becomes mature. |
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Products will be
added to the catalog after "extensive
consultations" with businesses, industry associations, experts and relevant
government departments. |
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Revisions to the
catalog will be considered annually. |
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The first catalog
has not been published, so Phase 2 is not yet in effect. |
|
The
catalog management method represents a
very different approach to restricting toxic and hazardous
substances than
EU RoHS:
|
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Under China RoHS,
restrictions apply only to EIP products listed in the catalog. If mature technology for a
product does not exist, it is not listed in the catalog (and no
exemption is needed). |
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Under EU RoHS,
restrictions apply to all products that meet the definition of EEE.
If mature technology for a product does not exist, an exemption is required. |
|
China RoHS restrictions on toxic/hazardous substances
apply to products listed in the catalog: |
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Six substances are
prohibited: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and
polybrominated diphenyl ethers (PBDE) -- the same as EU RoHS |
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Products may contain DecaBDE -- unlike
EU RoHS |
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Concentration of
lead, mercury, cadmium, hexavalent chromium, PBB and PBDE may not
exceed 0.1% in any homogeneous material -- the same as EU RoHS
|
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Concentration of
cadmium may not exceed 0.01% in any
homogeneous material -- the same as EU RoHS |
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Concentration
limits also apply to small components (4mm3 or
less) that cannot be disassembled further into homogeneous materials
-- no such provision in EU RoHS |
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Lead, mercury,
cadmium and hexavalent chromium cannot be intentionally added to metal coatings -- no such provision in
EU RoHS |
|
China's
compulsory product certification (CCC
or 3C) is also required for products listed in the catalog: |
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This is very
different from EU RoHS, which carries the presumption of compliance
based upon the manufacturer's self-declaration. |
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China has not yet
specified how CCC certification will work. Current reports indicate
that testing/certification by Chinese labs will be required.
|
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Previous FAQs had
indicated China would consider mutual recognition agreements with
foreign governments for their respective certification
organizations. |
|
Phase 2 applies
only to products "put on the market" in China: |
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It does not apply to
prototypes or research & development |
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It does not apply
to products assembled in China for export |
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It does not apply to
products put on the market in Hong Kong or Macau |
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"Put on market"
refers to the date the product was manufactured (not the date the
model was introduced) |
|
Phase 2 is based on
the
Law on the Promotion of Clean Production. |
