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What
is China RoHS Phase 1?
Decree No.39:
Electronic Information Products
Classification Notes
SJ/T11363-2006: Concentration Limits
SJ/T11364-2006: Marking
GB 18455-2001: Packaging
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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). |
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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. |
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Phase 2
applies only to products listed in the Catalog for Priority
Pollution Control. These products may not contain RoHS substances and must
pass China's compulsory product certification
(CCC). Phase 2 has not taken effect because the catalog has not been
published. |
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Electronic Information Products (EIP)
are products that use "electronic information technology" (a term
that is not defined), such as:
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Electronic radar
products (except military radar) |
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Electronic communications products
(transmission, receiver, switching) |
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Broadcast and
television equipment (transmission, receiver, production) |
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Computer products
(large-frame, network, PC, media) |
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Home electronic products (TV,
video & stereo equipment) |
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Electronic measuring
instruments |
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Specialized electronic products
(industry manufacturing equipment) |
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Electronic applications (medical equipment,
games, microwave oven) |
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Electronic components and parts |
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Electronic materials |
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Further elaboration
on the concept of EIP is available from: |
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Classification Notes, a
thirty-five page list of categories of EIP (issued by the MII
on March 16, 2006) |
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Questions and
answers (FAQs),
published at
www.rohs.gov.cn |
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Consistent with
China's catalog management model (which
works by listing the things that are regulated), FAQ #27 states that
only those things clearly listed in the Notes need comply. |
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The
scope of China RoHS electronic
information products (EIP) is generally broader than
EU RoHS
electrical and electronic equipment (EEE), with some exceptions: |
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In general, EU RoHS
is targeted at consumer products, not
commercial or industrial equipment. It does not apply to equipment rated over 1000 volts AC
or 1500 volts DC. It specifically excludes large-scale stationary
industrial tools, medical devices and monitoring &
control instruments. |
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China RoHS has
no such exclusions. It includes medical
equipment, measuring instruments, radar, communications transmission
and switch equipment, and manufacturing equipment for electronic
products. |
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China RoHS includes
batteries and packaging materials for
electronic products, whereas the EU has separate battery and
packaging directives. |
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Both China and EU
RoHS include digital memory products (CD, DVD & tapes) and printer
consumables (toner, ink and ribbons) |
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However, China's
exclusive focus on electronic products related to information
technology is less expansive that Europe's focus on
electrical and electronic products. As
a result, EU RoHS includes the following products that are excluded
from China RoHS: |
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"White"
household appliances, such as
refrigerators, washing machines & air conditioners (China covers
only "black" household appliances) |
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Small household
appliances, such as vacuums, sewing machines and coffee makers |
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Automatic
dispensers (vending machines) |
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China RoHS applies
only 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) |
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The
six "toxic or harmful substances"
regulated by China RoHS are the same
substances in EU RoHS -- lead, mercury,
cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and
polybrominated diphenyl ethers (PBDE) -- with one difference: |
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China exempts DecaBDE from restrictions
(the EU doesn't) |
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China also reserves the right
to add other substances to the list as scientific evidence becomes
available (as does the EU) |
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China's
concentration
limits (sometimes translated "limited requirements")
are the same as the EU -- 0.1% for lead, mercury,
cadmium, hexavalent chromium, PBB and PBDE and
0.01% for cadmium
-- but they are applied a little differently: |
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Category EIP-A
refers to each homogeneous material. The concentration limits apply. |
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Category EIP-B
refers to metallic coatings. Lead, mercury, cadmium and hexavalent chromium cannot be
added intentionally. |
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Category EIP-C
refers to small components (4mm3 or
less) that cannot be further disassembled under existing
conditions. Concentration limits are calculated for the whole. |
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Phase 1 of China RoHS is a labeling
requirement that applies to all EIP. Hazardous
substances are permitted so long as they are properly indicated for recycling. |
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Only the
final product (intended for sale) is
labeled. |
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Electronic components and materials sold
business-to-business or to OEMs do not need to be labeled, but
disclosure of hazardous materials is required. Identical components
sold directly to consumers must be labeled. |
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All EIP must be
marked with the
pollution control logo
(minimum size 5mm x 5mm). If product
size or function doesn't allow logo to be molded/painted/ pasted/printed on the product,
it may be placed in product instructions. |
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Logo
1 (the green arrow)
is used for products without toxic or hazardous substances (do not
exceed concentration limits) |
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Logo 2
(the orange arrow) is used for products that contain toxic or
harmful substances. The number inside the arrows varies to indicate
the product's environmental protection use period
(EPUP) |
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The
EPUP (sometimes
translated "environmental-friendly use period") is the period during
which toxic/hazardous substances in the EIP
will not leak or mutate to cause severe environmental
pollution, bodily injury or property damage. |
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EPUP is calculated
under normal operating conditions (extreme environmental
conditions do not need to be not considered) |
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EPUP is not the same as the
"safe use period" which evaluates such safety factors as
electrical/electronic performance and electromagnetic safety |
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The manufacturer
determines EPUP for its own products and should follow the guidance
from its industry trade association (if available) |
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A separate EPUP may
be calculated for regular replacement parts (such as batteries) or consumables
(such as ink and toner) |
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No Chinese standard for calculating the EPUP
has been published |
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The
date of manufacture is the EPUP start
date and must be marked on the product. It should include the
week/month and year of manufacture (and may be incorporated into the
product serial number or barcode) |
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When
Logo 2 is used,
Table 1 must be provided in the product
instructions: |
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There are separate
rows for each EIP component part |
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There are separate columns for each RoHS
toxic/hazardous substance |
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In each square, X indicates the presence and O
indicates the absence of the specified substance in the specified component |
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Table must be
printed in Chinese characters at least 1.8mm tall |
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China RoHS marks the Chinese government's embrace of
using national and international
standards
for environmental regulation. China has stated its intent to align
its regulations with international standards and to influence the
development of those standards going forth. China is a member of the
International Electrotechnical Committee (IEC)
and a participant of its Committee on Environmental Standardization
(TC111). |
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The Standardization Administration of the People's Republic of China
(SAC)
www.sac.gov.cn was organized in
2004. Chinese companies (often subsidiaries of global manufacturers)
participate in drafting the standards and commenting on them.
Published standards relevant to China RoHS are: |
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SJ/T11363-2006 on limit requirements (concentration limits) |
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SJ/T11364-2006 on marking (labeling requirements) |
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SJ/T11365-2006 on test methods |
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GB 18455-2001 on packaging material recycling logos |
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RoHS was based
on the
Law on the
Promotion of Clean Production, which took effect on January 1, 2003. |
This summary is
intended to give you an easy-to-understand overview 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.
Should
you need assistance in meeting the requirements of China RoHS, we stand ready
to help you. Just
email
us or give us a call at 972-679-8996 for a timely and personalized response.
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Technical Consulting
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