China RoHS

1
China RoHS

• Webinar
• International Trade Administration
• U.S. Department of Commerce
• January 11, 2007
• Jon Boyens
• Standards Coordinator
• for Manufacturing Industries
• International Trade Administration
• U.S. Department of Commerce

2
Disclaimer

• The information provided is intended to be of
  assistance to U.S. exporters. While we make every
  effort to ensure its accuracy, neither the United
  States government nor any of its employees make
  any representation as to the accuracy or
  completeness of information. Readers are advised
  to independently verify any information prior to
  reliance thereon. The information provided does
  not constitute legal advice.

3
Overview of Presentation

• Background
• Hazardous Substances
• Unique Provisions of China RoHS
• Product Scope
• Labeling/Documentation
• Priority Products Catalog
• Web Sites for More Information

4
Whats in a name? That which we call a RoHS
By any other name..might just be a RoHS
tooor not.Administrative Measures on the
Control of Pollution Caused by Electronic
Information ProductsManagement Methods for
the Control of Pollution by Electronic
Information Products
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HOWEVER, Not EU ROHS, Japan RoHS, Korea RoHS, or
any other RoHS

• Referring to this regulation as China RoHS has
  lead to the common assumption that Chinas
  requirements (and other RoHSes) mirror those in
  the EU RoHS Directive.

6
Background to the ever Mutating RoHS

• Grew out of EU RoHS
• But Chinas Administrative Measures on the
  Control of Pollution Caused by Electronic
  Information Products has unique provisions not
  found in the EUS RoHS
• Precautionary Principle and keeping up with the
  Joneses

7
Background to the ever Mutating RoHS (continued)

• Innovation/Competitiveness link
• Framework Regulations
• No international regulatory harmonization

8
What Are the Restricted Hazardous Substances
(RoHS 6)?

• Lead
• Mercury
• Hexavalent Chromium
• Cadmium
• Polybrominated Flame Retardants PBB and PBDE
• Others?

9
China RoHS vs. EU RoHS

• China
• All Products in Scope Subject to Mandatory
  Labeling (exceptions to follow p. 15)
• Products in Priority Products Catalog Subject to
  Restrictions (Bans) of the Use of Hazardous
  Substances

• EU
• All Products in Scope Subject to Restrictions
  (Bans) of the Use of Hazardous Substances Except
• Exempted Uses of Hazardous substances

10
Unique Features of China RoHS

• Different Product Scope
• Enforcement Dates Depend on Product/Provision
• Unique Labeling Provisions
• Priority Products Catalog
• Mandatory Inspection and Testing for Priority
  Catalog Products

11
China Standards and Guideline for Compliance

• Labeling - SJ/T 113642006 Marking for Control of
  Pollution Caused by Electronic Information
  Products
• GB 18455-2001 Packaging Recycling Mark
• Maximum Concentration Value - SJ/T 11363-2006
  Requirements for Concentration Limits for Certain
  Hazardous Substances in Electronic Information
  Products
• Test Methods - SJ/T 113652006 Testing Methods
  for Hazardous Substances in Electronic
  Information Products
• General Rule of Environment Friendly Use Period
  of Electronic Information Products (Guidance
  document in draft and expected to be released
  prior to the March 2007 deadline.)
• Lead-free Solders Chemical Compositions and
  Forms (5 different standards)

12
Chinas Two Step Approach

• All Products in Scope Subject to Mandatory
  Labeling (In Effect March 1, 2007!!!)
• Products in Priority Products Catalog
• Substance Restrictions, Mandatory Testing and
  Certification

13
Product Coverage China vs. EU

• China
• Radar Equipment
• Communications Equipment
• Navigational Equipment
• Broadcasting Equipment
• Medical Equipment
• Audio and Video Equipment
• Computers and Peripherals
• Measuring and Test Instrument
• Manufacturing and Assembly Equipment for
  Electronics
• Electronic Components
• Associated parts, subassemblies, and materials
• Outside of EU RoHS

• EU
• Large and Small Household Appliances
• White goods outside of China RoHS
• Telecommunications Equipment
• IT Equipment
• Lighting Equipment
• Electrical and Electronic Tools
• Automatic Dispensers

14
Examples of Non-EU RoHS Products in China RoHS
Scope

• Airborne and other Radar
• Satellite Ground Station Equipment
• Television Recording and Broadcasting Equipment
• Oscilloscopes, Electrical Test Instruments
• Cardiac Telemetry System, Blood Measuring
  Apparatus (Medical)
• Semiconductor Manufacturing Equipment

• Electronic Assembly Equipment
• Semiconductors (ICs) and other Electronic
  Components
• Washing Machine Motor
• Optical Fiber, Cable
• Semiconductor Materials
• Ink Cartridge, Printer Head

15
China RoHS Labeling Requirements

• In Effect March 1, 2007
• All Products in Scope (MANUFACTURED March 1, 2007
  or after) are subject to labeling requirements
• Except for products or parts
• 1. Imported into China for re-export or
  manufacturing of products to be exported and
• 2. Parts or components imported into China for
  manufacturing for sale in China
• (In this case, the parts supplier needs to
  supply the Chinese manufacturer with the
  information needed for them to label and disclose
  the information on the final product)

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China RoHS Labeling Requirements

• Environment-Friendly Use Period
• Content Level/Location of Hazardous Substances
• Recycle-ability of Product
• Packaging Material (Wrapping)

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China RoHS Labeling Recycle-ability of Product

• Producers to use recycle-able materials in
  products as much as possible
• Products are to be marked to indicate they are to
  be recycled (not put in with regular trash)

18
China RoHS Labeling Product Markings

• Symbol 1
• No restricted substances contained or above limit

• Symbol 2
• Use if EIP contains restricted substance above
  limit requirements
• EUP Year put in center

19
China RoHS Labeling Environment-Friendly Use
Period

• The time limit in years within which
  hazardous/toxic substances or elements in the
  EIP, under conditions of normal use, do not leak
  to pollute the environment or harm human beings
  and properties.
• Determined by the manufacturer, but advice from
  industry associations is suggested.
• Manufacturers have to weigh the costs and
  benefits of having longer and shorter
  environment-friendly use periods.
• If longer, then more responsibility if shorter,
  then it may lose out to competitors

20
China RoHS Labeling Environment-Friendly Use
Period

• The product with EFUP less than 5 years should
  use 1 year, 2 years, 3 years, 4 years and 5 years
  as EFUP
• The product with EFUP greater than 5 years should
  use 5 years, 10 years, 15 years and 20 years as
  EFUP, and so on. When the number of EFUP for an
  EIP is not multiple of 5, should use the closest
  multiple number as EFUP.

21
China RoHS Labeling Date of Manufacturing

• Products must be marked with the date of
  manufacturing. (According to Q22 in the
  Standards QA).
• Used to determine the start date of the
  Environment-friendly Use Period.
• Should be in the form of (month/day/year)

22
China RoHS Labeling Hazardous Substances MCVs

• Two steps
• Classify materials (unit) in EIP
• EIP-A Each homogeneous material
• EIP-B Metal coating of each parts
• EIP-C Small parts/materials (less than 4.0
  mm³)
• Apply maximum concentration limits
• EIP-A Same MCV as EU RoHS
• EIP-B Restricted substances shall not be
  intentionally added
• EIP-C Same as EU RoHS
• China uses the same Maximum Concentration Values
  (MCVs) as the EU to measure concentration values,
  except for metal plating
• Cadmium 0.01 by weight
• Lead, Mercury, Hexavalent Chromium, PBB, PBDE
  0.1 by weight

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China RoHS Labeling Hazardous Substance
Disclosure Table

• Must be in Chinese
• List EIP in column
• Insert X (exceeds) or O (less than or none) in
  table to identify if
• hazardous substance in EIP exceeds restricted
  limits
• Include statement identifying meaning of X and
  O under table

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China RoHS Labeling Packaging (Wrapping)

• GB 18455-2001 Packaging regulations
• Marking size 20 x 20, 40 x 40, 60 x 60, or 80 x
  80 mm
• Marks should be bright green or if green will not
  show, contrasting color may be used.
• Mark in place visible to consumer

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China RoHS Labeling Packaging Marks
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China RoHS Labeling Packaging Material Codes (1
of 2)
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China RoHS Labeling Packaging Material Codes (2
of 2)
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China RoHS Priority Products Catalog
Restriction of Hazardous Substances

• No release date, but expected in the 3rd quarter
  of 2007 (Allen Overy LLp)
• Catalog products are a subset of labeling scope
• Catalog products subject to hazardous substance
  restrictions

29
China RoHS Priority Products Catalog Timing

• Each restriction has its own timeline
• The Catalog is reviewed annually
• Unknown which products will be included in the
  Catalog

30
China RoHS Priority Products Catalog Inspection
and Testing

• Products in the Catalog are subject to compulsory
  certification and testing
• Imports of products in the Catalog are subject to
  authentication and inspection upon arrival at
  Chinese ports
• CCC Mark process (according to 3rd QA and
  discussions)

31
China RoHS Priority Products Catalog Inspection
and Testing (Concluded)

• Testing requirements, lab certification, and
  related information is not yet available

32
China RoHS Priority Products Catalog Other
Unknowns

• Procedure for putting products into the catalog?
• actual circumstances of industry development?
• lead time for compliance?
• industry input?
• How does a manufacturer confirm their products
  are in the catalog?
• Procedure for appeal or seeking a delay in the
  phase-in period for individual products?

33
China RoHS Penalties

• Manufacturers, importers, and retailers are all
  responsible for different parts of the
  regulations. This is spelled out in Chapter 3 of
  the regulations.
• However, neither the regulation nor any other
  rules or guidance have given detailed information
  on the level of penalties. Nonetheless,
  different parts of the Chinese government are
  responsible for enforcement, including MII,
  AQSIQ, SEPA, etc.

34
ASTM F40 on Declarable Substances in Materials

• ASTM F2577-06, Standard Guide for Assessment of
  Materials and Products for Declarable Substances
• Gives a general description of the process of
  assessing products and/or materials for
  compliance to declarable substance requirements
• Gives alternatives to testing for assessing
  product/materials compliance
• Helps eliminate superfluous testing/information
  gathering on materials and thus may reduce
  compliance costs
• Allows materials producers and experts to
  evaluate materials on a case-by-case basis based
  on scientific principles and logical deduction in
  order to limit the number of substances for which
  information is required
• Gives case studies to illustrate the
  products/materials assessment process
• http//www.astm.org/cgi-bin/SoftCart.exe/index.sht
  ml?Emystore

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Conclusions

• Chinarohs_at_mii.gov.cn (Single point of contact in
  MII for questions regarding China RoHSs.)
• Cross sector, multi market regulations
• Impacts the entire supply chain
• Billions of dollars in remanufacturing,
  compliance, and testing
• Expect more RoHS mutations.
• Australia, Brazil, Malaysia, Mexico, Singapore,
  Taiwan, and Thailand ??????
• Precautionary Principle.expect more
  environmental regulations of this sort!!!

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Thank You!

• Jon Boyens
• International Trade Administration
• U.S. Dept. of Commerce
• HCHB-2806
• Washington, DC 20230
• 202-482-0573
• Email Jon.Boyens_at_mail.doc.gov
• Please let me know if you would like to be on my
  RoHS email list.

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Web Sites for More Information on China RoHS

• Official (Chinese) links
• The Regulation (in Chinese) http//www.mii.gov.cn
  /art/2006/03/02/art_524_7343.html
• Detailed product scope list (in Chinese)
  http//www.mii.gov.cn/art/2006/03/16/art_1221_8441
  .html

38
China RoHS Web Sites (Cont.)

• Unofficial Translations and Further Information
• AeAs China RoHS Page http//www.aeanet.org/Gover
  nmentAffairs/gabl_ChinaRoHSpage0905.asp
• Design Chain Associates (DCA) China RoHS page
  http//www.chinarohs.com
• Grace LLC, includes QAs http//www.graspllc.com
  /news.php

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China RoHS Web Sites (Continued)

• Draft Marking, Maximum Concentration and Test
  Method Standards
• Draft Marking Standard (in Chinese)
  www.rohscn.com/document/2.pdf
• Draft MCV Standard (in Chinese)
  www.rohscn.com/document/1.pdf
• Draft Test Method (in Chinese)
  http//www.rohscn.com/document/rohs12.pdf