General introduction

Chinese RoHS 2 regulation the “Measures for Administration of the Hazardous Substance Restricted Usage of Electric and Electronic Products” is developed from the so-called Chinese RoHS 1 “Administrative Measures on the Control of Pollution from Electronic Information Products”. It promulgated on January 06, 2016. The Administrative Measure includes four chapters and twenty-three articles.

• Chapter 1: General Rules (Articles 1 – 8)
• Chapter 2: Hazardous Substance Restricted Usage of Electric and Electronic Products (Articles 9 – 18)
• Chapter 3: Penalty Provisions (Articles 19 – 20)
• Chapter 4: Supplementary Provisions (Articles 21 – 23)

The following three standards, in conjunction with the Administrative Measure.

1. GB/T 26572-2011, “Requirements of Concentration Limits for Certain Hazardous Substances in Electrical and Electronic Products”
2. GB/T 26125-2011,  “Electrical and Electronic Products - Determination of Six Regulated Substances (Lead, Mercury, Cadmium, Hexavalent Chromium, Polybrominated Biphenyls, Polybrominated Diphenyl Ethers)”
3. SJ/T 11364-2014, “Marking for the Restriction of Use of Hazardous Substances in Electrical and Electronic Products”
4. SJ/Z 11388-2009, ”General guidelines of environment-friendly use period of electronic information products”

The major changes include:

• Scope: from electronic information products to electrical and electronic products, including relevant materials and components
• Catalogue: from Key Management Catalogue to Compliance Management Catalogue
• Conformity assessment scheme: from state-promoted voluntary certification to a new scheme still under development, which could possibly be a combination of self-declaration of conformity by enterprises, state-promoted voluntary certification, and compulsory certification. Companies might be able to choose between different approaches. Ex-post regulatory measures could vary with the scheme chosen. 

Scope

The Administrative Measure is to control and reduce environmental pollution and other public hazards during the process of manufacturing, selling, and importing electronic information products within the territory of the People’s Republic of China (Hong Kong, Macau and Taiwan excluded).  Exports are exempt from this measure.

Electric and electronic products refers to the equipment and auxiliary products relying on electric current or electromagnetic field or those targeted at generating, transmitting and measuring electric current or electromagnetic field with the rated operational voltage of 1500V at most for direct current and 1000V at most for alternating current. The equipment therein involved in electrical energy generation, transmission and allocation shall be excluded.

Products exempted from the Administrative Measures include:

1. Equipment used for the production, transmission and distribution of electricity, including systems and equipment used for power supply and distribution in power plants, transmission and distribution substations, and buildings;
2. Electrical and electronic equipment for military purposes;
3. Electrical and electronic equipment designed for special or extreme circumstances;
4. Electrical and electronic equipment to be exported;
5. Electrical and electronic products that are imported, or that enter the Chinese territory for servicing, on a temporary and not-for-sale basis;
6. Prototypes used for R&D and testing purposes;
7. Not-for-sale samples and products displayed at exhibitions.

Major product categories regulated by the Administrative Measures include:

1. Telecommunications equipment
2. Radio and television broadcasting equipment
3. Computer and other office equipment
4. Household appliances and electronics
5. Electronic instruments
6. Industrial electrical and electronic equipment
7. Power tools
8. Electro-medical equipment and devices
9. Lighting products
10. Electronic cultural & educational, art, sport and entertainment products

Remark: Please note that this list is not exhaustive and can only serve as a reference. 

Compliance Requirements

The “Administrative Measure” adopts a “two-step approach” method for Hazardous Substance Restricted Usage of Electric and Electronic Products. The first step is self-declaration.  Starting July 1st, 2016, a manufacturer affixes an environmental-friendly logo to the product and indicates environment-friendly information (the names and contents of toxic and hazardous substances, environment-friendly use period, recyclability, and the names of packaging materials, etc.) in the product instruction manuals. There are no requirements for the “substitution” or “limitation” of toxic and hazardous substances or elements during the first step.

The second step is a “Compliance Management Catalogue” will be developed to suggest a list of products whose use of hazardous substances shall meet the limitation requirements. The Catalogue will also allow transition periods, which may vary from products to products. But, for now the “Compliance Management Catalogue” is still in developing and hasn’t promulgated. Catalogue-listed products will face the same restrictions on substances as outlined by the EU RoHS Directive.  They must meet the limit requirements set forth in GB/T 26572-2011.  Additionally, The implementation date of the second step has not been determined at the time of this writing.

Summary

China RoHS 2.0“Measures for Administration of the Hazardous Substance Restricted Usage of Electric and Electronic Products” takes effect July 1st, 2016. All electric and electronic products must indicate environment- as stated under the Marking Requirements.  This is the first step of the two-step approach.

Once the “Compliance Management Catalogue” has been promulgated and an implementation date has been set, all electric and electronic products listed in the Catalogue must meet the requirement of limit, before entering the Chinese market.  At that time, Conformity assessment scheme also will be done by compulsory certification.

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