China RoHS

1
China RoHS

• Scope, Compliance and Factors for Success
• November 7, 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
• EU vs. China
• Unique Provisions of China RoHS
• Product Scope
• Labeling/Documentation
• Priority Products Catalog
• Web Sites for More Information

4
EUs ROHS Directive is NOT the same as China
RoHS, Japan RoHS, Korea RoHS, or any other
RoHScurrently no regulatory harmonization.

• Referring to these regulations as China RoHS,
  Japan RoHS, Korea RoHS, etc., has led to the
  common assumption that the requirements for these
  regulations mirror those in the EU RoHS
  Directive.
• Only similarity are the RoHS 6 substances and
  Maximum Concentration Values (MCVs)

5
What Are the Restricted Hazardous Substances
(RoHS 6)?

• By Weight of Homogeneous Material
• 0.1
• 0.1
• 0.01
• 0.1
• 0.1
• 0.1

• Restricted Substances
• Lead
• Mercury
• Cadmium
• Hexavalent Chromium
• Polybrominated biphenyl (PBB)
• Polybrominated diphenyl ether (PBDE)

6
EU Environmental Regulations Affecting the
Product Cycle of Electrical and Electronic
Products (not comprehensive)

• WEEE (Waste of Electrical and Electronic
  Equipment Directive)
• RoHS (Restriction of Hazardous Substances
  Directive)
• EuP (Eco-design of Energy Using Products
  Directive)

7
EUs Regulations and the Product Stewardship Cycle
8
The Ever Mutating RoHS Current Drivers for
China et al

• EU
• Economic costs of environmental damage
• Chinas State Environmental Protection
  Administration (SEPA) calculated that
  environmental damage cost China approximately 65
  billion in 2004, or roughly 3.05 percent of GDP
  over the last two years.
• Extended Producer Responsibility/Product
  Stewardship
• A trend shifting responsibility for the
  management of end-of-life consumer products from
  governments to manufacturers, importers, and
  retailers
• Dumping Countries fear that non-compliant
  products will be dumped in their market.
• May or may not be an issue once the supply chain
  runs out of non-compliant parts/components.
• Innovation/Competitiveness Forced innovation
  ensure that domestic industry remains
  competitive.

9
The Ever Mutating RoHS Overarching Issues (not
all)

• Framework regulations
• No international regulatory alignment
• Impacts SMEs disproportionately
• Difficulty amortizing the associated costs
• Affects different industries differently

10
China RoHS vs. EU RoHS

• China
• CONTROLS (labeling and marking SDOC) and then
  RESTRICTS (mandatory testing/certification)
• All Products in Scope Subject to Mandatory
  Labeling (exceptions to follow)
• Products in Priority Products Catalog Subject to
  Restrictions (Bans) of the Use of Hazardous
  Substances

• EU
• RESTRICTS and then allows EXEMPTIONS
• All Products in Scope Subject to Restrictions
  (Bans) of the Use of Hazardous Substances
• Except
• Exempted Uses of Hazardous substances and
  Excluded Categories

11
Unique Features of the Administrative Measure on
the Control of Pollution Caused by Electronic
Information Products or China RoHS

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

12
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
• Toys (outside of China RoHS)
• Automatic Dispensers

13
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

14
Chinas Two Step Approach

• All Products in Scope Subject to Mandatory
  Labeling (Effective March 1, 2007!!!)
• Content Level/Location of Hazardous Substances
• Environment Protection Use Period (EPUP)
• Recycle-ability of Product
• Packaging Material (Wrapping)
• Products in Priority Products Catalog
• Substance Restrictions, Mandatory Testing and
  Certification
• Positive list of products/substance restrictions.
• Has created uncertainty within industry.

15
China Standards and Guideline for Compliance

• Labeling - SJ/T 113642006 Marking for Control of
  Pollution Caused by Electronic Information
  Products
• Packaging Recycling Mark - GB 18455-2001
• 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.)
• Special Disassembly Requirements for Testing
  Hazardous Substances in Electrical and Electronic
  Products - GB/Z xxxx-200x (11/06 Draft)
• Lead-free Solders Chemical Compositions and
  Forms (5 different standards)

16
China RoHS Labeling Requirements

• In Effect March 1, 2007
• All Products in Scope (MANUFACTURED March 1, 2007
  or after) are subject to labeling requirements
• Excluded from the scope are products or parts
• Imported into China for re-export or
  manufacturing of products to be exported and
• Parts or components imported into China for
  manufacturing and 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)

17
China RoHS Labeling Product Markings

• Symbol 1
• No restricted substances contained or below limit

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

18
China RoHS Labeling Environmental Protection Use
Period

• The time limit in years during which the toxic
  or hazardous substances or elements in the EIP
  will not leak or mutate under conditions of
  normal operating conditions, so that the use of
  the EIP will not result in severe environmental
  pollution, any bodily injury or damage to any
  assets.
• Determined by the manufacturer, but advice from
  industry associations is suggested.
• Guidance document available
• 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

19
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 Protection Use Period.
• Should be in the form of (month/day/year),
  although we have heard that it is acceptable if
  the date is in the product code or somehow
  visible on the product.

20
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

21
China RoHS Priority Products Catalog
Restriction of Hazardous Substances

• Catalog products are a subset of labeling scope
• Catalog products subject to hazardous substance
  restrictions
• Each restriction has its own timeline
• The Catalog is reviewed annually
• Unknown which products will be included in the
  Catalog
• No release date, but expected in the 2nd half of
  2008

22
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 MIIs 3rd QA and
  G2G discussions)

23
MII Created Three Technical Centers

• Testing, training, standards development, energy
  efficiency, recycling and environmental research.
• 1) MII Electronic Information Products
  Pollution Control Technology Advancement Center
  under China Electronics Standardization
  Institute (CESI)
• 2) MII Electronic Information Products Pollution
  Control CEPREI Testing Center under China
  Electronic Product Reliability and Environmental
  Testing Research Institute (CEPREI)
• 3) MII Electronic Information Products Pollution
  Control CTTL Environmental Protection
  Advancement Center under China
  Telecommunication Technology Labs (CTTL).

24
Current and Future Regulations??? (Not
Comprehensive)

• RoHS-like
• Korea
• Japan
• Australia (Assessment Study)
• Argentina (Proposed)
• New Zealand (?)
• India (?)
• Taiwan (?)
• Thailand (?)
• Malaysia (?)

• NOT RoHS-like
• Brazil (Proposed)
• Possibly RoHS-like
• Columbia (Final)
• Costa Rica (Proposed)

25
China RoHS Web Sites

• 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
• Standards Available at
• http//www.mii.gov.cn/art/2006/11/14/art_1221_2686
  1.htmlhttp//www.sj.cesi.cn/stan-cd/fxdg/dgms.htm
  
• Official MII China RoHS email ChinaRoHS_at_mii.gov.c
  n

26
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 - the only thing about RoHS
  thats FREE!!.