How to comply with
China RoHS2
3 March 2016, 2-3pm GMT (London)
© Copyright 2015 CW Research Ltd
Today’s webinar aims
•
To highlight China RoHS1, China RoHS2 & EU RoHS2;
•
Explain how companies can re-use EU RoHS2
materials declarations to manage compliance with
China RoHS2 labelling and disclosure requirements;
•
To discuss the upcoming compliance management
catalogue which will apply substance restrictions and
conformity assessment requirements to specific
products.
© Copyright 2015 CW Research Ltd
Speakers
v Aidan Turnbull, Director, BOMcheck.net
v Chair: Sarah Thompson, Chemical Watch
© Copyright 2015 CW Research Ltd
Questions
Please submit questions during the webinar
using your chat box.
Any unanswered questions can be raised in
the AsiaHub LinkedIn group following the
webinar:
www.chemicalwatch.com/asia-hub
© Copyright 2015 CW Research Ltd
How to comply with China RoHS2:
Comparison of China RoHS1, China RoHS2 and
EU RoHS2 requirements
Dr Aidan Turnbull
Director, BOMcheck.net
Email: [email protected]
Agenda
1. Scope and timelines
2. Labelling requirements
3. Substance restrictions and conformity assessment
4. Packaging
BOMcheck: Industry-lead shared web
database for the electrotechnical industry
Launched in May 2008 by Siemens,
Philips and GE Healthcare
ü Industry Steering Group directs the
development of new functions and
features on BOMcheck
ü Industry Substance List Working Group
identifies and evaluates substance
regulations
Owned and operated by thinkstep
compliance limited
ü Co-Chair of US Standard IPC 1752A
for Materials Declarations
ü European Regional Coordinator for
International Standard IEC 62474 for
Materials Declarations.
ü Helped write EN 50581 Standard for
RoHS2 Technical Documentation
2 million parts and 5,700 users including...
UK Govt guidelines and RoHS policy
exchange with Chinese Govt
Hosting UK Govt RoHS policy exchange with Chinese Govt
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•
•
•
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Freimut Schroeder, VP EHS Siemens Healthcare
Steve Andrews, UK RoHS Regulatory Authority
Aidan Turnbull, BOMcheck
Richard Frewin, UK Director of RoHS Enforcement
Gao Dongsheng, China RoHS2, MIIT Deputy Director
Lisson Zhang, Senior Manager Philips
5
Agenda
1. Scope and timelines
2. Labelling and substance disclosure requirements
3. Substance restrictions and conformity assessment
4. Packaging
China RoHS2 timelines
§ China RoHS2 published 21 Jan 2016 takes effect 1 July 2016
– “Administrative Measures for the Restriction of the Use of
Hazardous Substances in Electrical and Electronic Products”
§ All products in scope must comply with labelling and substance
disclosure requirements from 1 July 2016
– Same labelling and disclosure requirements as China RoHS1 but
now applied to a much larger scope of products
§ Substance restriction and conformity assessment requirements
will apply to specific products listed in a not-yet-published
“Compliance Management Catalogue”
– Similar to China RoHS1 where a draft product catalogue was
prepared but never published
China RoHS2 documents not yet published
§ China RoHS2 FAQ expected later this year
– Will cover similar questions as addressed in China RoHS1
FAQ published 2007
§ Other important documents not yet published
– Compliance Management Catalogue
– Conformity Assessment System
§ Monitor AsiaHub and Chemical Watch for further information
Comparing the scope of China RoHS2, EU
RoHS2 and China RoHS1
§ China RoHS 2 Article 3: “electrical and electronic products”
“devices and accessory products with rated working electrical
voltages of < 1,500 V DC and < 1,000 V AC which function by
means of electric currents or electromagnetic fields”
– Power generation, transmission and distribution equipment excluded
§ EU RoHS2 Article 3: “electrical and electronic equipment”
“equipment with voltage rating < 1,500 V DC and < 1,000 V AC
which is dependent on electric currents or electromagnetic fields”
– Several products excluded under Article 2 (4)
§ China RoHS2 scope is much broader than China RoHS1 which
only covered “electrical information products” falling into 10
product categories
China RoHS1 “electrical information
products” defined as 10 product categories
1.
Electronic radar products – included airborne and ship borne radar
2.
Electronic communication products e.g. transmitters, navigation, telephones, base stations
3.
Broadcast television equipment industry products – transmitters, camcorders, antennas
4.
Computer products – included network equipment, printers, power supplies, CDs, toner
cartridges, etc
5.
Household electronic products – TV, DVD, video tapes, CDs, etc
6.
Electronic measuring instrument products – test equipment, meters
7.
Electronic industry professional equipment products – included production equipment for
EIPs, soldering tools, electric tools and air tools
8.
Electronic component products – passives, PCBs, sensors, connectors, switches,
loudspeakers
8.
a) Electronic device industry – vacuum tubes, diodes, semiconductors, ICs, wire and cable,
lamps and batteries
9.
Electronic application products – household equipment (games, microwave ovens), medical
devices
10.
Electronic professional use material products – materials used in components, solder,
laminates, etc
Products excluded from EU RoHS2 which
may be in scope of China RoHS2
§ Batteries (in scope of China RoHS1)
§ Military equipment (out of scope of China RoHS1)
§ Means of transport for persons or goods
(out of scope of China RoHS1)
§ Equipment designed to be sent into space
§ Large-scale industrial tools
§ Large-scale fixed installations
§ Non-road mobile machinery for professional use
§ Active implantable devices
§ PV panels for permanent installations
Note: Review Article 2 (4) for further details
Products not yet in scope of EU RoHS2
which may be in scope of China RoHS2
§ In Vitro Diagnostic Medical Devices (part of Category 8) come
into scope of EU RoH2: 22 July 2016
§ Active Implantable Medical Devices (part of Category 8) exempt
from EU RoHS2
§ Industrial Monitoring & Control Instruments (part of Category 9)
come into scope of EU RoHS: 22 July 2017
§ Category 11 “All EEE not covered by any other category” come
into scope of EU RoHS: 22 July 2019
How does China RoHS2 apply to products
manufactured for export?
§ China RoHS1: Article 2: “These methods shall not apply to the
production of products destined for export”
§ China RoHS2: Article 2: “These methods are applicable to the
production, sale, and import of EEP within the territory of China”
§ China RoHS2: MIIT Explanation Document: “[China RoHS1] encouraged
some enterprises to adopt two standards for production – restriction of
hazardous substances for products destined for export and no
appropriate measures for products subject to domestic sales”
Made in China
Made in China
China RoHS2 appears to distinguish between
disclosure and restriction requirements
§ China RoHS2: Article 10: “Producers of electrical and electronic
products, in producing or manufacturing electrical and electronic
products, shall … restrict or phase out the use of hazardous
substances”
§ China RoHS2: Article 13: “Producers and importers shall ...
indicate via labelling the hazardous substances contained in
electrical and electronic products that they bring to market”
§ China RoHS2: Article 14: “Producers and importers of
electrical products must indicate in the labelling the
environmental protection use period of the products that they
produce or import”
FAQ will clarify how China RoHS2 applies
to products manufactured for export
§ Industry trade associations are in discussions with Chinese Government
– Does it make sense for a product manufactured in China for exclusive sale in
the US to be marked with environmental protection use period and to include
a table in Chinese in the instructions for use?
– Contact Tad Ferries, Partner at Foley & Lardner LLP, [email protected]
§ Most likely outcome at this stage is FAQ likely to clarify that
– Electrical and electronic products (EEPs) in scope which are sold in China
must comply with labelling and substance disclosure requirements from 1
July 2016
– EEPs which are manufactured exclusively for export may not need to comply
with labelling and substance disclosure requirements
– EEPs in scope which are listed in the yet-to-be published Compliance
Management Catalogue must comply with the China RoHS substance
restrictions. In addition to products sold in China, this may also apply to
products manufactured in China exclusively for export.
Agenda
1. Scope and timelines
2. Labelling and substance disclosure requirements
3. Substance restrictions and conformity assessment
4. Packaging
All EEPs in scope must be labelled with an
environmental protection symbol
§ Same labelling requirements as China RoHS1 but now applied to
a much wider scope of products in China RoHS2 from 1 July 2016
§ Label EEP with green environmentally friendly symbol if all
homogenous materials in all parts of the EEP contain
< 0.01% Cadmium/cadmium compounds
< 0.1% Lead/lead compounds
< 0.1% Hexavalent chromium compounds
< 0.1% Mercury/mercury compounds
< 0.1% Polybrominated biphenyls (PBB)
< 0.1% Polybrominated diphenyl ethers (PBDE)
Labeling if any part in EEP exceeds RoHS
limits in any homogenous material
§ Label product with orange symbol and Environmental Protection
Use Period if any homogenous material in any part of EEP
contains > 0.1% of RoHS substance (> 0.01% for cadmium)
§ EPUP is the period during which the RoHS substances “will not
leak or mutate” …. Usually calculated as
EPUP = {expected service life} + {time between production and putting into
service} + {likely extended service life if repairs/refurbishment possible}
§ In addition, must mark product with date of manufacture – this is
the start of the Environmental Protection Use Period (EPUP)
Substance disclosure if any part exceeds
RoHS limits in any homogenous material
§ Include table in Chinese product instructions to identify part
names which contain RoHS substances
– China RoHS2 table follows same format as China RoHS1 but has updated
references
Updated references
Labelling and substance disclosure do not
include EU RoHS2 exemptions
§ Annex III and IV of EU RoHS2 provide exemptions for materials
applications and types of components where substitution of
RoHS substances is technically or scientifically impractical
A product which
complies with EU
RoHS based on an
exemption must be
labelled with the
orange EPUP symbol
Note: this China RoHS1 table
contains old references
How to use EU RoHS compliance efforts to
comply with China RoHS2 labelling
§ Suppliers should provide material declarations which comply with
EU RoHS conformity assessment standard EN 50581
– Provide the compliance status for each individual RoHS substance and
identify any exemptions that have been applied.
– Example is industry standard IPC 1752A for materials declarations
§ Check EU RoHS materials declarations
§ If all parts in the product comply with EU RoHS without any
exemptions
– Label product with the green environmentally friendly symbol
§ If some parts in the product claim EU RoHS exemptions, or are
non-compliant to EU RoHS
– Label product with orange symbol with Environmental Protection Use
Period and ensure product marked with date of manufacture
– Include substance disclosure table in product instructions
EU product labelling requirements
§ Products which comply with EU RoHS2 substance
restrictions must be marked with CE mark
§ Products which fall under categories 1 to 10 of the EU
WEEE Directive must be marked with the crossed out
wheelie bin
Agenda
1. Scope and timelines
2. Labelling and substance disclosure requirements
3. Substance restrictions and conformity assessment
4. Packaging
Compliance Management Catalogue has
not been published yet
§ Substance restriction and conformity assessment
requirements will apply to specific products listed in a notyet-published “Compliance Management Catalogue”
– In-scope products expected to added in batches in future years
§ China RoHS1 referenced the China Compulsory Certificate
– Would have required testing by authorized Chinese laboratory
§ China RoHS2 references a “conformity assessment
system” which will be drafted by MIIT
– MIIT Explanation Document noted that “full implementation of a
mandatory certification program would delay product introduction to
market and adversely affect product innovation”
– “Conformity Assessment System” is expected to be more flexible
Recommended approach to prepare for
China RoHS2 substance restrictions
§ Monitor AsiaHub and Chemical Watch
for further information
– China RoHS2 FAQ
– Compliance Management Catalogue
– Conformity Assessment System
§ Implement EU RoHS conformity
assessment standard EN 50581
– China RoHS2 more aligned with EU RoHS2
– It is likely that Conformity Assessment
System may be based on EN 50581
– Download guide to EN 50581 at
https://www.bomcheck.net/rohs
Agenda
1. Scope and timelines
2. Labelling and substance disclosure requirements
3. Substance restrictions and conformity assessment
4. Packaging
China RoHS2 no longer requires marking
of packaging
§ China RoHS1 required marking of packaging for EIPs with
material codes and graphics
Reusable
Recyclable
Includes
Recyclable
Materials
Codes for “major materials”
§ Marking of packaging is no longer mandatory under China
RoHS2. But Article 12 does require compliance with packaging
standards and use of materials that are “non-hazardous, easily
degradable, facilitate recycling and reuse”
China RoHS2 summary
§ China RoHS2 published 21 Jan 2016 takes effect 1 July 2016
– New scope is electrical and electronic products (EEPs) with rated
working electrical voltages of < 1,500 V DC and < 1,000 V AC
§ All products in scope must comply with labelling and substance
disclosure requirements from 1 July 2016
– Same labelling and disclosure requirements as China RoHS1 but
now applied to a much larger scope of products
§ Substance restriction and conformity assessment requirements
will apply to specific products listed in a not-yet-published
“Compliance Management Catalogue”
– Similar to China RoHS1 where a draft product catalogue was
prepared but never published
How to comply with China RoHS2: Comparison of China
RoHS1, China RoHS2 and EU RoHS2 requirements
Thanks for your attention .….
….. what questions would you like to discuss?
Dr Aidan Turnbull
Director, BOMcheck.net
Email: [email protected]
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