What is 'China RoHS' Phase 2?

Decree No.39: Electronic Information Products
SJ/T11363-2006: Concentration Limits

China RoHS refers to Joint Ministerial Decree No. 39: Management Measures for Controlling Pollution by Electronic Information Products, which was issued February 28, 2006. Our unofficial English translation is provided by the American Electronics Association (AeA).
	Phase 1 is a labeling requirement only. All electronic information products (EIP) must be marked with the appropriate pollution control logo and indicate the environmental protection use period. Phase 1 took effect on March 1, 2007.
	Phase 2 applies to products that are listed in the Catalog for Priority Pollution Control. RoHS substances are prohibited, and enforcement is by China's compulsory product certification (CCC).

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":
	The catalog will evolve over time, expanding as the technology for RoHS substitutions develops and becomes mature.
	Products will be added to the catalog after "extensive consultations" with businesses, industry associations, experts and relevant government departments.
	Revisions to the catalog will be considered annually.
	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:
	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).
	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:
	Six substances are prohibited: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE) -- the same as EU RoHS
	Products may contain DecaBDE -- unlike EU RoHS
	Concentration of lead, mercury, cadmium, hexavalent chromium, PBB and PBDE may not exceed 0.1% in any homogeneous material -- the same as EU RoHS
	Concentration of cadmium may not exceed 0.01% in any homogeneous material -- the same as EU RoHS
	Concentration limits also apply to small components (4mm3 or less) that cannot be disassembled further into homogeneous materials -- no such provision in EU RoHS
	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:
	This is very different from EU RoHS, which carries the presumption of compliance based upon the manufacturer's self-declaration.
	China has not yet specified how CCC certification will work. Current reports indicate that testing/certification by Chinese labs will be required.
	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:
	It does not apply to prototypes or research & development
	It does not apply to products assembled in China for export
	It does not apply to products put on the market in Hong Kong or Macau
	"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.

This summary of the China RoHS Phase 2 is designed to provide you with an accurate, easy-to-understand overview of the topic and does not constitute legal advice. The actual standard in the original language should be reviewed and used for all business, legal, and product compliance purposes.

RSJ excels at helping you collect and report the data about what is in your products. Once you have the underlying data about your products in place, it can be analyzed against any standard or regulation worldwide. We are here to help you!
 

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