For some, it’s creeping in on cat’s paws. For others, it’s coming in as loud as a lion. Whether or not you saw it coming, the first phase of China RoHS concerning product “mark and disclosure” will arrive this Thursday. And the overwhelming question to the electronics supply chain is: Are you ready?

China RoHS, the common name for the Chinese law “Management Methods for Controlling Pollution by Electronic Information Products,” follows last year’s implementation of the European Union’s Restriction of Hazardous Substances (RoHS) directive. While the two are often compared – as both have tremendous impacts on the supply chain by regulating the amount of hazardous or toxic materials in electronics and both focus on the same six substances (lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyl and polybrominated diphenyl ether) – they vary greatly, most notably in terms of scope, exemptions and product markings.

Indeed, many product types not within the span of EU RoHS are within the scope of China RoHS; vice versa, certain product categories of EU RoHS are not within the range of China RoHS. Unlike the EU directive, which allows levels of the six defined hazardous substances in some product categories, including military and medical equipment, China’s Ministry of Information Industry (MII) has yet to define any exemptions for China RoHS. And marking a product as EU RoHS compliant will not meet the MII’s requirements for China RoHS product markings.

Specifically, China is requiring all products that meet its regulations for the six hazardous substances include a logo to signify that, an “e” enclosed by a green circle. If the product does not meet the regulations, China requires that a listing of the included hazardous substances be include in the product’s documentation and a different circle logo be included on the packaging that notes the Environmental Protection Use Period (EPUP), a time in years that the hazardous substances will not, under normal conditions, leak out or that the product will not cause severe environmental pollution, injury to health, or great damage to property. 

Further, packaging material, itself, must be disclosed on the outside packaging for this first phase of China RoHS, and the date of manufacture also must be marked on the product.

By: DocMemory
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