Are You In Scope?: China RoHS 2

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Are You In Scope?: China RoHS 2

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Madison AdamsAssent ComplianceCompliance Services

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Valerie KuntzAssent ComplianceSubject Matter Expert — Materials Management







Feature PresentationPRESENTER, TITLE & COMPANY Feature PresentationChina RoHS 2







Regulation: “Management Methods for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products”

New Regulation: SJ/T 11364-2014Old Regulation: SJ/T 11364-2006

Date Legislation Signed: January 6, 2016

Effective Date: July 1, 2016

China RoHS 2






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⬥ Cadmium(Cd) and its compounds: 0.01%⬥ Mercury and its compounds: 0.1%⬥ Lead(Pb) and its compounds: 0.1%⬥ Hexavalent chromium (Cr6+) and its compounds: 0.1%⬥ Polybrominated biphenyls (PBB): 0.1%⬥ Polybrominated diphenyl ethers (PBDE): 0.1%

Substances & Threshold







China RoHS 2 Included Products:Electrical and Electronic Products (EEP) = Equipment dependent on electric current or electromagnetic fields for operation and equipment for the generation, transfer and measurement of such currents and fields, with a working voltage rating not to exceed 1,000 volts alternating current or 1,500 volts direct current.

Products “placed on the market" are in scope.

⬥ Spare or accessory products sold separately without an intended end product are considered standalone and must meet the requirements of a full product

⬥ Full product replacement is considered to be a new product and have the compliance requirement of that date







China RoHS 2 Excluded Products:⬥ Equipment related to electric energy production, transmission and distribution,

such as systems and devices used for power station, power distribution station and building power supply and distribution

⬥ Electrical and electronic equipment used for military purposes⬥ Electrical and electronic equipment used in special or extreme environment⬥ Electrical and electronic equipment used for export

Note: Electrical and electronic equipment used for export shall comply with provisions related to restricted use of hazardous substances in the country/region of ultimate destination

⬥ Electrical and electronic equipment which are temporarily imported or imported for repair, but not for sale

⬥ Prototypes used for scientific research / research and development and testing⬥ Samples and exhibits used for exhibition and display, but not for sale







China RoHS 2

China RoHS Catalogue:◆ Currently only labels and tables are mandatory, substance

compliance is voluntary◆ Over the life of the regulation, China will be releasing

catalogues of products that will be required to meet the restriction requirements of the substances

◆ Catalogues will be released intermittently, not all at once

Exemptions:

◆ None at this time◆ Catalogues may include exemptions as deemed necessary

Exemptions







Showing Compliance

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⬥ Label on the product indicating compliance (e-logo) or non-compliance (EFUP)⬥ Manufacture Date on product⬥ Hazardous Substance Table with all parts contained within the product or

individual tables for each part⬥ Conformity assessment replacing in-country testing

Note: The China RoHS 2 regulation no longer requires packaging material label requirements unless it is required by GB/T 18455-2010 (packaging recycling marks), but it is recommended







Showing Compliance - Labeling

Condition Label

None of the six substances exist in the product above threshold

Product contains one or more of the six substances above threshold. Number indicates the minimum number of safe years.







Environmental Friendly Use Period (EFUP)

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⬥ EFUP: is the period of time before any of the RoHS substances are likely to leak out, causing possible harm to health and the environment

⬥ EFUP Date ◇ From date of manufacture of the product ◇ Irrespective of importation date

⬥ Multiple EFUP numbers ◇ If a product contains multiple components using multiple EFUP numbers:

■ Each component is allowed its own EFUP number ■ The product can also be governed by an EFUP number for the whole product

which must be the lowest EFUP number of the product ⬥ EFUP in Battery Compartment

◇ The EFUP number / nameplate of the product can go into the battery compartment if the battery is removable by the end user






https://en.wikipedia.org/wiki/RoHS

https://en.wikipedia.org/wiki/Natural_environment


Label Requirements - Size

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⬥ Minimum 5mm x 5mm, but can be larger⬥ Number of grids is 100×100

⬥ Use the font “Impact” for the number in the non-compliant logo⬥ The ratio of the font’s height to the inner and outer diameters of the

circle is 5:8:12⬥ Colors recommended for labels: Green (compliant) and Orange

(non-compliant), but other colors are allowed







Label Requirements - Product Label Placement

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⬥ Ideally on the front of the product or another recognizable location ⬥ The mark may be moulded, painted, printed or on a sticker⬥ Using electronic methods:◇ Must appear for two seconds if displayed upon boot up ◇ If displayed along with other info, duration and size of the logo must

be appropriate so the logo is distinguishable ◇ If viewed through the user interface:

■ The table must be able to be viewed as well ■ Instructions must be able to point the user to this information ■ Information must be read only ■ Manufacturer must retain the digital data for the product three

years after its lifespan







Label Requirements - Product Placement

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Label not required to be placed on the product under these conditions:⬥ A maximum surface area less than 5×103mm2 ⬥ An irregular shape, e.g. a thin and long cable with a very large surface area⬥ Incapable of being directly marked on the surface of the product due to the surface

material or functions⬥ If label not placed on the product, the methods for providing the info are:

◇ Manual◇ Website - steps must be provided in the manual to access the China RoHS info ◇ CD/DVD ◇ Packaging material







Hazardous Substance Table Requirements

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◆ Must be included with the shipment in the following ways: ◇ Separate sheet ◇ In the manual◇ Website referenced by manual◇ Digitally available on the product

◆ New standard SJ/T 11364-2014 must be referenced in table ◆ Old table is temporarily allowed as long as reference to new standard is

documented somewhere in the product documentation◆ Specifics on size and requirements

◇ The height of the Chinese characters and symbols used in the marking shall be clear and legible and not be smaller than 1.8mm

◇ Only required if there is a declarable substance. Not required for e-products ◇ Simple Chinese required







Hazardous Substance Table

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下面的有害物质信息披露表适用于 <制造商名称> <制造商零件名称/编号> 其中 <是/不> 中国符合RoHS表 The following hazardous substance disclosure table applies to <manufacturer name> <manufacturer part name/number> which <is/is not> China RoHS Compliant.

有害物质名称及含量 Table of hazardous substances name and concentration

部件名称Part Name

有毒有害物质Hazardous Substances

铅 Lead（Pb），

汞Mercury（Hg），

镉 Cadmium（CD），

六价铬 Hexavalent Chromium（六价铬），(Cr(VI))

多溴联苯 Polybrominated

biphenyls（PBB），

多溴二苯醚 Polybrominated diphenyl ethers

（PBDE）

安装衬底 Mounting Substrate X O O O O O

柜 Cabinet O O X O O X

的阴极射线管 Cathode-ray tube

X O O O O O

此表是根据的规定编制SJ / T 11364 This table is prepared in accordance with the provisions of SJ/T 11364.

○：表示说，包含在所有均质的有害物质对于这部分的材料是低于的限量要求GB / T 26572. O: Indicates that said hazardous substance contained in all of the homogeneous materials for this part is below the limit requirement of GB/T 26572.

X：表示说，包含在用于这部分均质材料中的至少一种有害物质高于GB / T 26572.的限量要求 X: Indicates that said hazardous substance contained in at least one of the homogeneous materials used for this part is above the limit requirement of GB/T 26572.

（企业可进一步产品标有“X”根据自己的实际情况提供在此框中技术说明。）(Enterprises may further provide in this box technical explanation for marking “X” based on their actual circumstances.)







Hazardous Substance Table - TranslatedThe following hazardous substance disclosure table applies to <manufacturer name> <manufacturer part name/number> which <is/is not> China RoHS Compliant.

Table of hazardous substances name and concentration

Part Name

Hazardous Substances

Lead(Pb)

Mercury(Hg)

Cadmium(Cd)

Hexavalent Chromium(Cr(VI))

Polybrominated biphenyls

(PBB)

Polybrominated diphenyl ethers

(PBDE)

Mounting Substrate X O O O O O

Cabinet O O X O O X

Cathode-ray tube X O O O O O

This table is prepared in accordance with the provisions of SJ/T 11364.O: Indicates that said hazardous substance contained in all of the homogeneous materials for this part is below the limit requirement of GB/T 26572.X: Indicates that said hazardous substance contained in at least one of the homogeneous materials used for this part is above the limit requirement of GB/T 26572.Enterprises may provide in this box a further technical explanation for marking “X” based on their actual circumstances.







Summary

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◆ New China RoHS 2 regulation includes standard six substances, but allows for additional substances in the future

◆ Scope includes EEP with some excluded product types◆ Went into effect July 1, 2016◆ Requires including specific labels indicating product compliance (e-logo) or

non-compliance (EFUP) on the product and tables indicating substance compliance for each part within the product documentation

◆ Substance restrictions will be introduced with product catalogues that will be released intermittently throughout the life of the legislation







Q&A Discussion

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