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Administration on Control of Pollution by Electronic Information Products (China RoHS law) - Chinese
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Administration on Control of Pollution by Electronic Information Products (China RoHS law) – English translation from PRC Ministry of Commerce

China

 

“China RoHS” is the law “Administration on the Control of Pollution Caused by Electronic Information Products,” which came into force in China on March 1, 2007.  Although it has come to be known as China RoHS, the requirements are notably different and more extensive than those of the EU RoHS.

China RoHS has two main sets of requirements for electronic information (EIP) products:

  • Substance restrictions and associated pre-market testing and compliance certification
  • Mandatory marking and/or information disclosure required for all EIP placed on the market on or after March 1, 2007

Electronic Information Products (EIP) include:

 
  • Radio and television products
  • Specialized electronic products
  • Electronic materials and accessories
  • Electronic communication products
  • Electronic radar products
  • Electronic application products
  • Computer products
  • Electronic components and parts
  • Home electronic products
  • Electronic instrument measuring products

The MII Electronic Information Products Classification and Explanations (“Catalogue”) provides a list of over 1800 specific EIP products, components, and materials that must comply with substance restrictions and labeling, information disclosure, and testing requirements.

The Catalogue specifies:

  • Categories of hazardous substances restricted for use
  • Categories of products
  • Timeline by which the designated products must comply with the hazardous substance restrictions and associated pre-market testing and compliance certification

China RoHS restricts the same chemicals (with same maximum concentration value) as the EU RoHS:

  • Lead (0.1 %)
  • Mercury (0.1 %)
  • Cadmium (0.01 %)
  • Hexavalent chromium (0.1 %)
  • Polybrominated biphenyls (PBB) (0.1 %)
  • Polybrominated diphenyl ethers (PBDE) (0.1 %)

The chemical restrictions are set out in the standard “Requirements for Concentration Limits for Certain Hazardous Substances in Electronic Information Products,“ SJ/T 11363-2006.

The scope of covered items in China is different than for EU RoHS, and China RoHS in general does not have exemptions.  Rather, it limits applicability by creating an extensive and significant catalogue of covered products.

China Labeling, Information Disclosure, and Testing Requirements

Electronic information products (EIPs) listed in the Catalogue must be marked with logos in accordance with the standard SJ/T11364-2006 (“Marking for Control of Pollution Caused by Electronic Information Products”).

If an EIP does not contain more than the maximum concentration value (MCV) of any restricted substances, it must be marked with a green “e”. If an EIP contains a restricted substance above the MCV of any restricted substances, then it must be marked with the product’s “environment friendly use period” (EFUP).  

  • The EFUP is the period during which the toxic substance contained in the EIP will not, under normal conditions of use, leak or mutate and result in pollution, injury, or damage.
  • The EFUP is provided inside the figure in the logo and is indicated in years (e.g. 50 = 50 years EFUP).
  • A table listing the hazardous substances and specified information must be provided.

Components that are intended to be used directly by an end customer need to be labeled.  Component suppliers do not need to provide the marking but do need to supply all necessary information to the purchaser.

EIPs listed in the Catalogue require pre-market testing and certification by a Chinese certified test lab.

  • The testing methods to be used by laboratories are described in the standard SJ/T11365-2006  (“Testing Methods for Regulated Substances in Electronic Information Products”).
  • The China Compulsory Certification (CCC) mark is required for EIPs in the catalogue.  CCC requirements incorporate China RoHS compliance testing.  The CCC is Administered by the Chinese government agency, Certification and Accreditation Administration (CNCA).
  • The process for applying for a CCC mark requires testing at accredited laboratories in China. 
  • The Packaging requirements referenced within China RoHS refer to an existing compulsory national standard, Packaging Recycling Marks, standard #GB 18455 on packaging recycling marks.  Packaging materials are required to be marked with the appropriate recycling mark and name of the packaging material.

The materials available and information provided at the Avery Dennison ADvantage: Complete Compliance site are for informational purposes only and not for the purpose of providing legal advice.