RoHS Compliance

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China RoHS

The Chinese Ministry of Industry and Information Technology (MIIT) published China RoHS 2 (called the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products on Jan 21, 2016, with it coming into effect on July 1, 2016. China RoHS 2 restricts the same six substances as EU RoHS 2.

The original China RoHS only impacted electronic information products (EIP); with China RoHS 2, electrical and electronic products (EEE) are impacted, similar to EU RoHS. This applies to equipment with working voltages less than or equal to 1000VAC and 1500VDC.

On June 29, 2017, the MIIT published a (Chinese language) draft catalog of products in 12 product categories subject to compliance, as listed below. Products and parts that contain restricted substances exceeding limits can still be sold in China but need to be marked as such. Unlike EU RoHS, there currently are no exemptions.

China RoHS 2 Product Categories

Communication equipment, fixed or mobile
Professional broadcast and TV equipment
Computer and office equipment
Household appliances
Electronic instruments for monitoring and control applications
Industrial electrical and electronic equipment, including monitoring and control equipment
Power tools
Medical electronics and devices
Lighting products, including electric light sources (lamps) and luminaires
Sports and entertainment products

Unlike EU RoHS, products for large commercial applications (Large Scale Industrial Tools (LSIT) and Large Scale Fixed Installations (LSFI)) are NOT exempted.

Unlike EU RoHS, which imposes substance concentrations for a product or component, China RoHS 2 restricts substance concentrations for to each homogenous material in the product. These concentration limits are published in the GB/T 26572-2011 (Requirements for concentration limits for certain restricted substances in electronic and electrical products).

China RoHS 2 also stipulates that an Environmental Protection Use Period be listed for each product that contains restricted substances above the prescribed limit during which products "will not leak or mutate suddenly under normal operating conditions and will not result in serious environmental pollution or cause serious bodily injury to the user or damage to their assets during the normal use by the user". This Use Period starts on the date of manufacture.

China RoHS 2 Marking:

The symbol on the left is affixed to products that pass RoHS 2 compliance for all materials, while the symbol on the right is affixed to products containing substances above RoHS limits, and displaying the Environment Use Period (in this example 10 years).

Along with the non-compliance mark, a Hazardous Substance table must also be supplied with the product that lists each part that is out of compliance:

Compliance enforcement protocols and penalties for non-compliance may be included might become part of the China Compulsory Certificate system, with testing by a 3rd-party lab required.