Draft Version of New China RoHS Published

Original Article by CIRS

7 June 2012, The Chinese Ministry of Industry and Information Technology (MIIT) has published draft Measures for Administration of the Pollution Control of Electronic and Electrical Products (known as new China RoHS) for public consultations. The deadline for comment is 10 July 2012. The old measures issued in 2006 will be revoked once the new measures enter into force.

New China RoHS also restricts the use of certain hazardous substances such as lead, mercury, cadmium, and hexavalent chromium and flame retardants such as polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE) in electrical and electronic equipments and their packaging materials. However, there are a few changes(for example, change of product scope, new labeling requirement and flexible certification mechanism) in the new China RoHS that companies might need to know before placing electronic and electrical products on the Chinese market.

Change of Product Scope

Old China RoHS regulates electronic information products which are referred to as electronic radar products, electronic communication products, broadcast and television products, computer products, household electronic products, electronic measurement instrument products, security products for electron, electronic component products, electronic application products, electronic material products, and other relative products and their accessory parts.

Products affected by new China RoHS include electrical and electronic equipments which are designed for use with a voltage rating not exceeding 1000 Volt for alternating current and 1500 Volt for direct current(similar to EU RoHS) and its accessory parts.  Many home appliances (Washing machines, refrigerators) that fall out of the scope of old China RoHS will now be regulated by new China RoHS.

New Labeling Requirement

New China RoHS requires that manufacturers and importers of electrical and electronic products provide information about the impact of a product on environment and human health when the product is misused or disposed of in addition to the name and concentration of hazardous substances, the name of parts that contain hazardous substances, and whether a part or product can be recycled.

Flexible Certification Mechanism

Under the old China RoHS, products listed in the Key Administrative Catalog for the Pollution Control of Electronic Information Products (“Catalog”) will need to be tested by one of the approved labs in China and obtain CCC accreditation (China Compulsory Certification).

Under the new China RoHS, the Catalog will be renamed as Target Administrative Catalog for the Pollution Control of Electrical and Electronic Products. Various government bodies will set a timeline to prohibit the use of certain hazardous chemicals for the products listed in the Catalog. In the future, various certification mechanisms might be available. It is possible for companies to issue a self-declaration or ask independent third party to carry out the certification.

CIRS's Comments

The measures do not give detailed requirements on the concentration limit of certain hazardous substances and marking. More detailed requirements can be found in the following standards.

- Standards on the Requirements of Concentration Limits for Certain Restricted Substances in Electrical and Electronic Products

- Standards on Electrical and Electronic Products - Measurement of Six Regulated Substances (Lead, Mercury, Cadmium, Hexavalent Chromium, Polybrominated biphenyls, Polybrominated diphenyl ethers)

- Marking for Control of Pollution caused by Electrical and Electronic Equipment

- Guidance on Risk Assessment for Substances of Certain Hazardous Substances contained in Electrical and Electronic Equipment

- General Rules on the Screening of Restricted Substances in Electrical and Electronic Equipment - X-ray Fluorescence Spectrometry

- Application Requirement of Soldering Process for Lead Free Component

The China National Certification and Accreditation Administration will also soon publish

- Implementation Rule on Certification on Pollution Prevention and Control of Electrical and Electronic Products



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