Update on China RoHS

This article has been provided by Farnell's Gary Nevison.

UK: Back in March 2007 phase one of the so called “China RoHS” Directive was implemented, on time.

This declaration period required labelling and information on up to 1800 Electronic Information Products. Pollution (recycling) symbols were required to indicate the level of toxic substances in a product.

Where below permitted levels a green symbol would typically be used and orange where restricted substances were present above the permitted levels broadly outlined within the EU RoHS Directive, that had entered into force in July 2006.

Other unique information would also be required including an environmentally friendly use period advising how many years a product could be safely used before hazardous substances were likely to leak into the environment, and a disclosure table outlining which toxic substances were present in a product and, to aid recycling, where the were located.

Phase two which, via a China RoHS “catalogue” would restrict actual products was to follow at the end of 2007. Little were we to know that it would take a further two years to publish the first draft catalogue as it slipped from the end of 2007 to mid and then the end of 2008, then on to mid 2009.

Finally, on 9 October, the first draft was published allowing for a one month consultation period. The restrictions will come into force ten months after the adoption of the legislation.

As anticipated the first draft only provided for a token number of products and these were principally telephones and printers. The list of products will be updated periodically.

The restricted substances are the same as EU RoHS, excluding deca-BDE, as are the maximum permitted concentration levels of homogeneous material, although China RoHS specifically refers to coatings and very small components.

Ten of the EU RoHS exemptions are permitted for “mobile handsets” and the same 10 for “telephones” under the proposals within the first draft of the China RoHS “Catalogue”.

Using the EU numbers they are: 5, 6 (split in to 3 covering steel, aluminium and copper alloy) 7a, 7c, 13, 14, 15 and 23.

The same 10 are permitted for computer printers with the addition of numbers 3 and 20.

Testing may prove a bottleneck as all equipment exported to China for sale in China will require analysis and the China Compulsory Certificate (CCC) and the testing can only be carried out, in China, via authorised Chinese labs. This begs the question will 10 months allow sufficient time?

The approved Chinese labs, and the standards they will use, are yet to be announced.

There will be insufficient time to modify product designs to comply so clearly it has been assumed that telephones and printers made by Chinese manufacturers will already meet these substance restriction obligations as the directive also covers products manufactured, and sold in, China.