China RoHS Standards Ready - Marking Required Only On Products Exceeding Concentration Limits

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Two standards - on 'Concentration Limits' and 'Marking' - stipulated by China's RoHS type regulation are ready for Ministerial approval. The two standard per se do not require extra work from companies whose products already comply with the EU's RoHS Directive. But a yet to be published Catalogue will subject certain products to mandatory certification.

The implementation of China’s equivalent to the RoHS Directive, which was adopted on February 28 and will enter into force on 1 March 2007, requires several standards and further regulatory measures, e.g. a standard on ‘Concentration Limits’ of hazardous substances; a standard on ‘Marking’ to indicate the presence of hazardous substances, as well as a safe-to-use period and the packaging material; a standard on ‘Testing Procedures’ and - most importantly - a Catalogue of products which are subject to substance restrictions and mandatory certification.

Since 1 May the standards on 'Concentration Limits' and 'Marking' have been ready for Ministerial approval. The drafts are unlikely to be changed in substance.

The maximum concentration values defined in the standard on ‘Concentration Limits’ will only apply to EEE listed in the yet-to-be defined Catalogue. All other products may exceed the limits. The substances and concentration limits are identical to those of the EU’s RoHS Directive. However, going beyond the EU Directive, the Chinese standard applies the limits to components which it divides into 3 groups: parts of homogenous materials to which the concentration limits apply; small items that are hard to disassemble and are treated like homogenous materials; and finally metal plate parts, in which the RoHS substances may occur if they have not been added intentionally.

The standard on ‘Marking’ will apply to all EEE within the scope of ‘China RoHS’. Like its Japanese equivalent, the Chinese standard requires only those products to be marked that exceed the concentration limits defined in the standard above. If a product exceeds the hazardous substances limits, it must be marked with a round symbol specified in the draft. A number in the centre of the mark must designate the period in years during which the product is safe-to-use for the user and the environment. In addition, the presence of hazardous substances in each component must be declared in a table in the manual. Only products in the yet-to-be- defined ‘Catalogue’ are subject to mandatory testing. For all others, the labelling is based on self-declaration.

Ministry of Information Industry (MII) clarified the scope of ‘China RoHS’ in March. The standard on ‘Testing Procedure’ is expected shortly. To establish the Catalogue of products that are subject to mandatory certification, MII is currently developing selection procedures and criteria that include industry consultations, expert assessment etc.

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Raphael Veit
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