China RoHS Overview

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• China RoHS Overview
• Gary Nevison

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RoHS in China

• Measures for the Administration of the Control of
  Pollution (caused) by Electronic Information
  Products (MII order number 39)China RoHS
• Deadline Products made from 1st March 2007
• Applies to products sold in China, but excludes
• Imported into China for re-export or
  manufacturing of products for export
• Imported into China as components used for
  manufacturing and future sale in China
• Precautionary Principle
• May cause harm to health and the environment in
  the future but no evidence today attributed to
  electrical equipment
• EU RoHS compliance does not necessarily mean
  China RoHS compliant
• China RoHS has some unique provisions not found
  in EU RoHS
• Product scope
• Priority products catalogue
• Enforcement dates by product
• Labelling
• Inspection and testing for catalogue products

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China RoHS 2 Stage Approach (Phase
1-Declaration)

• All Electronic Information Products (EIP)
• Over 1800 listed
• Put On The Market All products manufactured
  on, or after 1st March 2007
• 6 restricted substances are still permitted at
  this stage
• Must be labelled with Pollution (recycling)
  Control Symbols
• Symbol 1. No restricted substances symbol
• Symbol 2. Restricted substances symbol
• Environment Friendly Use Period
• Disclosure table highlighting toxic and
  hazardous substances
• Marking on packaging

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China RoHS 2 Stage Approach (Phase
2-Restriction)

• Products included in The Catalogue
• The Catalogue (reviewed annually) will define
• Substance restrictions where they apply (some, or
  all, of 6 EU substances)
• Will define further requirements (other
  restricted substances etc)
• Will define any exemptions
• Determine when each category has to comply
  allowing time to
• Testing via authorised Chinese lab (18 or more)
• Accreditation of China Compulsory Certificate
  (CCC)
• May specify limits to environmental use period
• If product is not specifically listed in
  catalogue
• No testing or certificate required
• No substance restrictions
• Not known which products will be included in The
  Catalogue

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Scope (1)

• 10 Categories - list published to indicate scope
• electronic radar products includes airborne and
  shipborne radar
• electronic communication products e.g.
  transmitters, navigation, telephones, base
  stations
• Broadcast television equipment industry products
  transmitters, camcorders, antennas
• computer products all types of computers,
  network equipment, printers, power supplies, CDs,
  toner cartridges, etc.
• household electronic products TV, DVD, video
  tapes, CDs, etc
• electronic measuring instrument products test
  equipment, meters, etc.

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Scope (2)

• electronic industry professional equipment
  products includes production equipment for
  EIPs, soldering tools, electric and air tools
• electronic component products passives, PCBs,
  sensors, connectors, switches, loudspeakers,
• 8a. electronic device industry vacuum tubes,
  diodes, semiconductors, ICs, electronic circuits,
  wire and cables, lamps and batteries
• Electronic application products household
  equipment (games, microwave ovens), medical
  devices
• Electronic professional use material products
  materials used in components, solder, laminates,
  etc.

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Substance use restriction

• All EIPs - marking requirements apply to
• Lead
• Cadmium
• Mercury
• Hexavalent chromium
• Polybrominated biphenyls (PBB)
• Polybrominated diphenyl ethers (PBDE) but not
  Deca-BDE
• Equipment listed in catalogue substance
  restrictions will include some or all of the
  above six, this will be specified - plus
• Other substances to be announced by State
• May vary by product

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Classification of materials

• Types prioritised EIP-AgtEIP-BgtEIP-C

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Marking / recycling requirements

• Pollution control symbols
• Symbol 1 use if none of the restricted
  substances are present / recyclability symbol
  Compulsory (no label is not an option)
• Symbol 2 - use if any restricted substance is
  present - Compulsory
• Must also provide table of hazardous materials
  - self-declaration

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Pollution control symbols

• Must be on product if regular 5000mm2 space
  available.
• If insufficient space, or irregular shape, or the
  function prevents this then print in user manual
• Clear, visible, hard to fade or remove
• In a prominent location
• Colour
• Symbol 1 green preferred, symbol 2 orange
  preferred
• But any prominent (bright) colour if not green /
  orange
• Marking may be moulded on to the EIP (same
  colour)
• Number of Environmental Friendly Use Period
  years in symbol 2

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Environmentally Friendly Use Period

• Period of time that it is safe to use the
  equipment before hazardous substances could leach
  out into the environment
• Must be determined by manufacturers
• Print date of manufacture on product or
  packaging. This is start date
• Every year up to 10 years, then multiple of 5
• Draft standards published Some examples of
  measurement
• Known through experience (practice method)
• Known through accelerated tests (experimental
  method)
• Normal life in the field repair (technical life
  method)
• Base on EFUP of similar products standards will
  provide examples
• Mobile phone 20 years, Notebook PC 10 years
  etc (from 3rd draft)
• Several substances present shortest EFUP will
  prevail
• Mark consumables that are EIPs separately
  (batteries etc)

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Table listing restricted substances - example

• Must be X (yes) or O (no) in table (no
  exemptions)
• Informs recycler which substances, and where
• Must be in paper form with product, ideally
  located in instruction manual (optionally also on
  web)
• Table in Chinese, explain meaning of X and O
• Part means PCBs, sub assemblies etc level of
  detail not yet defined
• Self declaration - no obligation to analyse

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Table listing restricted substances- required
format
Part names here in Chinese
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Packaging labels

• Chinese standard defines packaging and recycling
  symbol
• Symbol and material codes published 2001
• Apply label to packaging unless insufficient
  space (then in instruction manual)
• Use codes for major materials (words or table)
• In Chinese (letters numbers)
• Applies to and must specify
• Plastics
• Paper
• Metals
• Composite materials (plastic / aluminium etc)
• Glass
• Wood

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Packaging labels

• Codes in Packaging Recycling Mark of standard
  are required
• For example, packaging is high density
  polyethylene (HDPE) and Paper Board (PB), the
  label would have the following codes
• The symbols in the standard may also be used, for
  example the recycling symbol for HDPE is

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Other Packaging Labels

• Reusable
• Recyclable
• Includes Recyclable Materials
• Green Dot
• Adopted by several countries in EU as
• part of packaging regulations

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Marking requirements - Summary

• Yes if
• Product is an EIP sold to the user
• Symbol 1 if no substance restrictions
• Symbol 2 if contains restricted substances
• Need EFUP
• Need substance disclosure table
• Packaging information
• Product is not an EIP but contains EIP components
• Awaiting clarification from MII on 60 rule not
  required yet, mark only EIPs
• No if
• Product is sold to OEM who uses it as a component
  within their products
• OEM still requires details on 6 restricted
  substances
• Spare parts (unless sold individually to
  user-usually for repair)

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Who is responsible?

• Everyone in the supply chain has responsibilities
• This may include (not all on 1st March but via
  future standards)
• Manufacturers
• Designers
• Importers
• Distributors
• Retailers
• Penalties could include (not yet defined)
• Fines
• Withdrawal of operating licenses
• Closure of production or distribution facilities
• Criminal sanctions in serious cases
• Imposed by issuing authorities in line with their
  scope of authority
• MII, AQSIQ, SAIC, GAC etc

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Conclusions

• China RoHS will apply from 1st March 2007 and
  covers a wide variety of products
• Initially it requires marking of products (EIPs)
  only
• Symbol 1 No restricted substances
• Symbol 2 Restricted substances
• EFUP
• Disclosure of substances
• Some specific products will be listed in the
  Catalogue
• Substance restrictions will apply (some, or all,
  of 6 EU substances)
• Other substances maybe defined
• Exemptions
• Testing required
• CCC required

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Thank You

• GARY NEVISON
• gnevison_at_farnellinone.com