An update on the latest information available for China RoHS, as well as information and tips on surviving a product eco-compliance audit.
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Electronic Information Product (EIP) List issued (scope of EIP within purview of Art. 3(1) of the China RoHS regulation)
June 22, 2006Framework measures issued to establish testing and certification program aimed at establishing conformity with EU RoHS concentration limits for Chinese products exported to the EU.
November 6, 2006Labeling, Concentration Limit, and Test Method standards issued to facilitate implementation of key aspects of the China RoHS regulation.
December 2006 and February 2007Frequently Asked Questions (FAQ) Documents issued, then amended, to address questions related to the China RoHS regulation and associated implementing standards.
March 1, 2007China RoHS regulation effective date (representing implementation date for labeling and information disclosure aspects).
October 9, 2008China RoHS Catalogue Procedures document issued, laying out procedures and criteria for selection of EIP for inclusion in the Catalogue. EIP in the Catalogue subject to materials restriction and associated pre‐market certification Requirements.
October 9, 2009China RoHS draft Catalogue, first batch, issued for comment (deadline for public comment – Nov. 9, 2009).
November 9, 2009Public comment period ended. MIIT comment review period begins.
November 17, 2009China RoHS EPUP Guidelines and Lead‐free Standards (technical/voluntary measures) Promulgated.
January 2010Proposed Voluntary RoHS component certification program finalized (not yet launched/promulgated)
Small components or materials that cannot be furtherdisassembled under existing conditions in EIP. Generally partswhich are equal to or less than 4 mm3 in size.
EIP‐C
Metallic Coating of each part in EIPEIP‐B
Each homogeneous material composing EIPEIP‐A
DefinitionEIP Category
Shall not exceed 0.1% for Pb, Hg, Cr6, PBB, PBDE; 0.01% for Cd.
EIP‐C
Pb, Hg, Cd, Cr‐6 cannot be intentionally addedEIP‐B
Shall not exceed 0.1% for Pb, Hg, Cr6, PBB, PBDE; 0.01% for Cd.
Key agencies: (Ministry of Industry and Information Technology (“MIIT”) and the Certification and Accreditation Administration (“CNCA”, under Administration for Quality Supervision, Inspection and Quarantine)– Delays in finalizing the program continue as key agencies undertook
internal “consultations” relating to overall approach and details concerning China RoHS Catalogue and associated certification program.
– Certification program compulsory (per Article 19 of China RoHS regulation). Model for CNCA China RoHS certification are the existing China Compulsory Certification (“CCC” or “3C”) safety licensing certification programs, with “some modifications possible”.
– Current list of restricted substances (same as EU): Lead, Mercury, Cadmium, Hexavalent chromium, Polybrominated biphenyl (PBB), and Polybrominated diphenyl ether (PBDE),
– Testing methods: “Testing Methods for Regulated Substances in Electronic Information Products” must be used, also a Chinese government approved/certified Lab must be used for testing.
China RoHS ‐ Materials restriction and associated, compulsory pre‐market certification under “Phase II”
• Finalization of First Batch of China RoHS Catalogue– Necessity of adding in missing exemptions for the proposed product
categories, importance of using language/exemption listings that are consistent (in wording and numbering) with those used in the EU RoHS program, to minimize company compliance clarity and system changes. (example: repair parts.)
– China’s willingness to consider “positive” (i.e., listed) exemptions, as opposed to an earlier approach of indicating “if it is not specifically listed it is not covered” (i.e., “negative exemption” approach), represents months of industry exchanges with MIIT and MIIT technical advisors on these issues.
– MIIT’s reluctance to move toward a “positive” exemption approach also reflects the political difficulties associated with Chinese agencies taking up what may be perceived as “following another legal program” (in this case, the EU program). This reluctance may again manifest as industry attempts to make the exemptions consistent with the EU exemptions as they currently exist.
• WTO TBT Committee notification of draft Catalogue, first batch. Possible any day, as MIIT has met other authorities and reached agreement to notify WTO.
• Comment period, based on China past notifications, is typically 60 days from notification to the TBT Committee.
– So, for instance, if the Catalogue is notified on July 15, WTO members would have until mid September 2010 for comment.
– China typically finalizes notified laws very promptly after the WTO comment period ends.• If finalized (promulgated) by, end of September 2010, you would count 10
months until the effective date, if the timing indicated in the current draft Catalogue does not change (so, summer 2011).
• The “upgrading” of the China RoHS framework regulation to a State Council regulation (from an MIIT regulation) and possibly also the upgrading of the three key China RoHS standards (i.e., labeling, concentration limit, and testing) to national (GB) standards, presents a very significant future challenge for our industry.
• Current estimates are that this will not occur for 2‐3 years. This presents a possible 1‐2 year gap (or breather) between finalization of the substance restriction/certification “phase 2” of the China RoHS program and “opening up” the entire program (phases 1 and 2) to further changes, including possible massive scope changes.