New China RoHS Regulation
Overview and explanation
Presented by:
Bruce Calder
VP of Consulting Services
Overview - Agenda
•
•
New China RoHS Law
•
Overview
•
Structure
•
Products for export
China RoHS Standards
•
New standard
•
Hierarchy
•
Scope
•
Labels & Tables
•
•
Placement
•
Structure
•
Options
•
Examples
Summary
Webinar is 50 minutes with 10
minutes of Q&A
(hopefully)
Claigan Overview
• Principal Services
-
Consulting
Laboratory testing
Data gathering
• Experience
-
Wide range of professional, medical, industrial,
and consumer companies
RoHS, REACH SVHC, REACH Registration, Conflict Minerals,
Batteries, Packaging, Persistent Organic Pollutants, Proposition
65, California Transparency in Supply Chains, UK Modern
Slavery, and more….
Claigan - Update Services
• Monthly or Quarterly
Updates
- Custom webinar
- On the changes in
requirements
- Impacts to your specific
products
- Monthly or Quarterly
- Interactive
Monthly (or Quarterly) Updates
• Webinar for just your company
• and interactive
• Based on changes in restricted materials compliance
requirements
-
Legislative
Enforcement
• Optional
-
Recording of web meeting
New China RoHS Law Published
• On January 6, the New China RoHS law was published
-
“Electrical and electronic products Restriction of Hazardous
Substances Management Measures”
Goes into effect 1 July 2016
-
• Highlights
-
New definition of EEE (same as EU RoHS)
-
-
EU RoHS scope of products
Table and labelling
-
To the new China RoHS standard (SJ/T 11364-2014)
-
Not restrictions (yet)
-
Conformity assessment replacing in country testing
General Comment on China RoHS
• We are going to discuss a Chinese law
-
Based on an English translation of a Chinese attempt to
better align with a translation of EU RoHS, and
In which the practical details are included in industry
standards, and
Is intended to have a government FAQ later this year.
• So
-
Don’t jump to any final conclusions regarding the text
China RoHS
China RoHS Law
(Electrical and electronic products
Restriction of Hazardous Substances
Management Measures)
Mandatory
labelling of content
and recyclability
Packaging marking
if mandatory
standard exists
Restriction of
substances if
catalog exists
Standard only
‘recommended’
SJ/T 11364-2014
Product Labelling Standard
(Marking for the restriction of hazardous
substances in electrical and electronic
products)
GB/T 18455-2010
Package recycling marking
No catalogs at this time
Restriction Catalogs
Products and Exemptions
China RoHS - Scope
•
Electronic and Electrical Products (EEP)
- Devices and accessory products with rated working electrical
voltages that do not exceed 1500V direct current and do not
exceed 1000V alternating current and function by means of
current or electromagnetic fields and generate, transmit and
measure such currents and electromagnetic fields.
• Very similar to EU RoHS
• Components likely no longer directly in scope
•
We will see in the FAQ
Products for Exports from China
• Common industry panic
-
Exclusion for products for export removed
-
and
• Scope wording
-
Article 2 - These Methods are applicable to the
production, sale, and import of electrical and electronic
products within the territory of China.
Scope
• Do you remember the confusion around
-
(b) "producer" means any person who -
(i) manufactures and sells electrical and electronic equipment under his own brand;
-
(ii) resells under his own brand equipment produced by other suppliers, a reseller
not being regarded as the "producer" if the brand of the producer appears on the
equipment, as provided for in subpoint (i); or
-
(iii) imports or exports electrical and electronic equipment on a professional basis
into a Member State.
• It looks like we are looking at an English translation of a
Chinese government attempt to paraphrase the confusing
definition of a producer from the original EU RoHS into
Chinese law
-
PS - China is not about to risk their electronics exports industry
-
More details expected in the eventual government FAQ
Producer Definition - Re-visiting
• New China Regulation
-
Article 2 - These Methods are applicable to the production,
sale, and import of electrical and electronic products within
the territory of China.
• Old RoHS Directive
-
(b) "producer" means any person who -
(i) manufactures and sells electrical and electronic equipment under his
own brand;
-
(ii) resells under his own brand equipment produced by other suppliers,
a reseller not being regarded as the "producer" if the brand of the
producer appears on the equipment, as provided for in subpoint (i); or
-
(iii) imports or exports electrical and electronic equipment on a
professional basis into a Member State.
New China RoHS Standard
• In late 2014, China RoHS standard was updated
SJ/T 11364-2014
-
from SJ/T 11364-2006
• Standard into force
-
1 January 2015
-
But held in abeyance until new law was published in 2016
• Major changes
-
Scope change
-
Removal of mandatory recycling marking
-
Further specifics on table and label
Notes on Chinese Standards
• GB
-
“Guobiao" standards
-
National standards
• SJ
-
Professional standard for electronics
- Ansi
• /T
-
tuījiàn, "recommended"
China RoHS - Substance Thresholds
• Substance threshold are identical to the EU RoHS
Directive 2011/65/EU
-
Only difference is there are no exemptions
-
Not a restriction
-
Declaration only
• Restricted substance thresholds (GB/T 26572)
-
Pb 1000 ppm
-
Hg 1000 ppm
-
Cd 100 ppm
-
CrVI+ 1000 ppm
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PBB 1000 ppm
-
PBDE 1000 ppm
New China RoHS Standard - Logos
•
How do you communicate if your product has a restricted
substance above the threshold?
•
All EEP that are sold in China shall be marked with China RoHS
logos
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The ‘E’ inside the circular chasing arrow indicates a product does not contain any
restricted substances above the threshold. This logo is usually green.
-
A logo with a number inside the circular chasing arrows indicates that there is a
restricted substance present above the prescribed threshold. This logo is usually
orange.
-
When these logos are used, the product is not intended for the regular waste
stream
China RoHS - Logos
• The number inside the logo is the Environmental Friendly Use Period (EFUP)
• EFUP (Environmental Friendly Use Period) is the expected safe use life span (in
years) of the product where the substance will not leak out and cause human or
environmental harm
• The EFUP may be displayed in years ranging from 1-5 and then from 5 to 50 in
five year increments
• The size of the logos must not be less than 5mm x 5mm
• The ratio of the font inside to the inner and outer circle is 5:8:12
• The product must also have
• Date of manufacture
Date of Manufacture
• The date of manufacture is the starting point for the EFUP period
• Format
• Year, or
• Year / month, or
• Year / month / day, or
• Year / week, or
• as part of a serial code that include date information
• Location
• Same location requirements as EFUP number
China RoHS - Logos
• Location of logo has been elaborated on
-
Ideally on the front of the product or another recognizable location
-
The mark may be moulded, painted, printed or on a sticker
-
Recommended colours of the logos are specified, but may appear how the
manufacturer wishes (Orange and Green)
• If the product is an odd shape
• Too small (less than 5mm x10mm2 )
• Unable to be marked due to surface or function
-
The markings may be placed in the:
•
Manual
•
Website
•
steps must be provided in the manual to access the China RoHS info
•
CD/DVD
•
Packaging material
• Additional new option for digital display is available for products with screens
China RoHS - Digital Display option
• Logo must appear for 2s if displayed upon boot up
• If displayed along with other info,
-
duration and size of the logo must be appropriate so the logo is
distinguishable
• May be viewed through the user interface
-
The table must be able to be viewed as well
-
Instructions must be able to point the user to this information
• This information must be read only
• Manufacturer must retain the digital data for the product
3 years after its life span.
China RoHS - Hazardous Substance Table
Tables
•
Must be included with the shipment either as a
•
-
Main attributes of hazardous substance table unchanged
-
New standard to be referenced in table
-
Some additional specifics on size and requirements
•
-
•
separate sheet, in the manual, website referenced by manual, or digitally
available on the product
The height of the Chinese characters and symbols used in the marking shall be
clear and legible and not be smaller than 1.8 mm
Only required if there is a declarable substance. Not required for ‘e’ products
Simple Chinese required
China RoHS - Hazardous Substance Table
“Part Names”
“Hazardous Substances”
Standards
Optional Explanation of ‘X’s
Table - Variations 2016 - Logitech
Table - Variations 2016 - TE
Table - Variations 2016 - MSI
Summary
• Scope
-
All products under scope of EU RoHS
-
Text is confusing, but looks to apply to all in scope products placed
on the market in China.
• Table
-
We need to update our table in test reports to the new standard
-
Some allowance for customization
• Table and EFUP
-
More options on placement
• Packaging and restrictions
-
Packaging marking recommended only
-
Material restrictions and exemptions in future catalogs
Claigan - Update Services
• Monthly or Quarterly
Updates
- Custom webinar
- On the changes in
requirements
- Impacts to your specific
products
- Monthly or Quarterly
- Interactive
Claigan Overview
• Principal Services
-
Consulting
Laboratory testing
Data gathering
• Experience
-
Q&A
Wide range of professional, medical, industrial,
and consumer companies
RoHS, REACH SVHC, REACH Registration, Conflict Minerals,
Batteries, Packaging, Persistent Organic Pollutants, Proposition
65, California Transparency in Supply Chains, UK Modern
Slavery, and more….
[email protected]
www.claigan.com