China RoHS

“Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products”, the so-called “China-RoHS”, has been in force since 01 July 2016.

This has been expanded from electronic information products (EIP) to electric and electronic equipment (EEE-products). The definition of the products is identical with that familiar from the European RoHS directive. But the Chinese law lacks the exempted applications of EU RoHS Article 2 – Scope such as, for example:

The regulated substances are the four heavy metals: lead, mercury, cadmium and hexavalent chromium, as well as two groups of flame retardants (polybrominated biphenyls and polybrominated diphenyl ethers) with the same limits as the European RoHS. There will be no list of exceptions in the style of the EU RoHS.

EEE-products that exceed the defined limits and are included in the “Catalogue of electrical and electronic products subject to compliance management” yet to be created can no longer be sold in the People’s Republic of China in future. If exemptions will be provided, they will be included in the catalogue and not in document attachments as with the EU RoHS. The working group has made the following initial suggestions (inter alia) for this catalogue:

EEE-products that are not included in this catalogue can still be sold in the People’s Republic of China, but need to be labelled accordingly. The products must be labelled before import. In addition to this, they need to be accompanied by a so-called DoC (Declaration of Conformity) that tabulates the components which exceed the regulation’s limits. If no limit has been exceeded, the DoC may be eschewed and the green label used. Products that exceed a limit need to use the orange identification labels. The DoC information and labels are only applicable to the finished EEE-product, but not to the individual materials, articles, etc. this product consists of.