China RoHS 2: What’s the Impact?

“Management Methods for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products,” also known as China’s RoHS 2 regulation, was released on January 21, 2016 by China’s Ministry of Industry and Information Technology (MIIT).

Those involved in the manufacture of “in-scope” electrical and electronic products in China, import into China, and those sourcing from Chinese manufacturers should note the requirements of the new regulation.

Similar to EU RoHS, the regulation establishes a framework for content limits of the hazardous substances indicated. Cadmium, hexavalent chromium, lead, mercury, polybrominated biphenyls, and polyborminated diphenyl ethers must be within the content limits. The mechanism for content limits is a notable change and was not present in the previous China RoHS regulation.

Furthermore, China’s RoHS 2 regulation also stipulates requirements for labeling and the disclosure of information regarding product, part, component, and hazardous substance content. While there is already existing labeling and information disclosure requirements, the introduction of content limits will most likely result in a change to the current requirements.

There are further changes between RoHS 1 and RoHS 2. One major change is the expanded scope of electrical and electronic products. Per the regulation (Article 3(1))…

“Devices and accessory products with rated working electrical voltages of no more than 1500 volts direct current and 1000 volts alternating current which function by means of current or electromagnetic fields, and generate, transmit and measure such currents and electromagnetic fields.”

However, power generation, transmission, and distribution equipment are excluded.

Compulsory certification from RoHS 1 is now replaced by a conformity assessment system. Implementation of this system is ongoing and the requirements as yet are unclear. However, it is important to note that it is being developed among MIIT, the Certification and Accreditation Administration (CNCA), with input from other governmental agencies.

Also in RoHS 2, a “Compliance Management Catalogue” is being developed by MIIT. This will cover “in scope” products that may be deemed to require additional controls for a product’s end of life and hazardous substance content/use. The catalogue will be phased in over the course of the regulation.

RoHS 2 also establishes packaging requirements. The conformity to packaging material standards is now within the enforcement of China RoHS 2 and their agencies.

The China RoHS 2 Regulation has been developed over the course of ten years. This careful development results in a version of China RoHS that is more similar to EU RoHS than its preceding version. Replacement of the compulsory certification program suggests a regulatory atmosphere that will, at least tolerate – if not foster, development and innovation of products. MIIT will continue to update via FAQs and other documents.

For a full, translated version of the regulation, please see https://www.manufacturingindustryadvisor.com/wp-content/uploads/sites/11/2016/01/China-RoHS-2-Regulation-Final-Foley-Format-ENG-clean2.pdf

 

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