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Information about AFDEC China RoHS

Published on October 10, 2007

Author: Spencer


Slide1:  China RoHS Overview Gary Nevison RoHS in China :  RoHS in China Measures for the Administration of the Control of Pollution (caused) by Electronic Information Products (MII order number 39)…”China RoHS” Deadline: Products made from 1st March 2007 Applies to products sold in China, but excludes: Imported into China for re-export or manufacturing of products for export Imported into China as components used for manufacturing and future sale in China Precautionary Principle May cause harm to health and the environment in the future but no evidence today attributed to electrical equipment EU RoHS compliance does not necessarily mean China RoHS compliant China RoHS has some unique provisions not found in EU RoHS Product scope Priority products catalogue Enforcement dates by product Labelling Inspection and testing for catalogue products China RoHS – 2 Stage Approach (Phase 1-Declaration) :  China RoHS – 2 Stage Approach (Phase 1-Declaration) All “Electronic Information Products” (EIP) Over 1800 listed “Put On The Market”: All products manufactured on, or after 1st March 2007: 6 restricted substances are still permitted at this stage Must be labelled with “Pollution (recycling) Control Symbols” Symbol 1. No restricted substances symbol Symbol 2. Restricted substances symbol + Environment Friendly Use Period + Disclosure table highlighting toxic and hazardous substances Marking on packaging China RoHS – 2 Stage Approach (Phase 2-Restriction):  China RoHS – 2 Stage Approach (Phase 2-Restriction) Products included in “The Catalogue” The Catalogue (reviewed annually) will define: Substance restrictions where they apply (some, or all, of 6 EU substances) Will define further requirements (other restricted substances etc) Will define any exemptions Determine when each category has to comply allowing time to: Testing via authorised Chinese lab (18 or more) Accreditation of China Compulsory Certificate (CCC) May specify limits to environmental use period If product is not specifically listed in catalogue No testing or certificate required No substance restrictions Not known which products will be included in The Catalogue Scope (1) :  Scope (1) 10 Categories - list published to indicate scope: electronic radar products – includes airborne and shipborne radar electronic communication products – e.g. transmitters, navigation, telephones, base stations Broadcast television equipment industry products – transmitters, camcorders, antennas computer products – all types of computers, network equipment, printers, power supplies, CDs, toner cartridges, etc. household electronic products – TV, DVD, video tapes, CDs, etc electronic measuring instrument products – test equipment, meters, etc. Scope (2) :  Scope (2) electronic industry professional equipment products – includes production equipment for EIPs, soldering tools, electric and air tools electronic component products – passives, PCBs, sensors, connectors, switches, loudspeakers, 8a. electronic device industry – vacuum tubes, diodes, semiconductors, ICs, electronic circuits, wire and cables, lamps and batteries Electronic application products – household equipment (games, microwave ovens), medical devices Electronic professional use material products – materials used in components, solder, laminates, etc. Substance use restriction:  Substance use restriction All EIPs - marking requirements apply to: Lead Cadmium Mercury Hexavalent chromium Polybrominated biphenyls (PBB) Polybrominated diphenyl ethers (PBDE) but not Deca-BDE Equipment listed in catalogue – substance restrictions will include some or all of the above six, this will be specified - plus Other substances to be announced by State May vary by product Classification of materials:  Classification of materials Types prioritised: EIP-A>EIP-B>EIP-C Marking / recycling requirements:  Marking / recycling requirements Pollution control symbols Symbol 1 – use if none of the restricted substances are present / “recyclability symbol” – Compulsory (no label is not an option) Symbol 2 - use if any restricted substance is present - Compulsory Must also provide “table of hazardous materials” - self-declaration Pollution control symbols :  Pollution control symbols Must be on product if regular 5000mm2 space available. If insufficient space, or irregular shape, or the function prevents this then print in user manual Clear, visible, hard to fade or remove In a prominent location Colour Symbol 1 – green preferred, symbol 2 – orange preferred But any prominent (bright) colour if not green / orange Marking may be moulded on to the EIP (same colour) Number of “Environmental Friendly Use Period” years in symbol 2 Environmentally Friendly Use Period:  Environmentally Friendly Use Period Period of time that it is safe to use the equipment before hazardous substances could leach out into the environment Must be determined by manufacturers Print date of manufacture on product or packaging. This is start date Every year up to 10 years, then multiple of 5 Draft standards published: Some examples of measurement Known through experience (practice method) Known through accelerated tests (experimental method) Normal life in the field + repair (technical life method) Base on EFUP of similar products – standards will provide examples Mobile phone = 20 years, Notebook PC = 10 years etc (from 3rd draft) Several substances present – shortest EFUP will prevail Mark consumables that are EIPs separately (batteries etc) Table listing restricted substances - example :  Table listing restricted substances - example Must be X (yes) or O (no) in table (no exemptions) Informs recycler which substances, and where Must be in paper form with product, ideally located in instruction manual (optionally also on web) Table in Chinese, explain meaning of “X” and “O” “Part” means PCB’s, sub assemblies etc – level of detail not yet defined Self declaration - no obligation to analyse Table listing restricted substances - required format:  Table listing restricted substances - required format Part names here in Chinese Packaging labels:  Packaging labels Chinese standard defines packaging and recycling symbol Symbol and material codes published 2001 Apply label to packaging unless insufficient space (then in instruction manual) Use codes for “major materials” (words or table) In Chinese (letters & numbers) Applies to and must specify: Plastics Paper Metals Composite materials (plastic / aluminium etc) Glass Wood Packaging labels:  Packaging labels Codes in “Packaging Recycling Mark” of standard are required: For example, packaging is high density polyethylene (HDPE) and Paper Board (PB), the label would have the following codes: The symbols in the standard may also be used, for example the recycling symbol for HDPE is Other Packaging Labels:  Other Packaging Labels Reusable Recyclable Includes Recyclable Materials Green Dot Adopted by several countries in EU as part of packaging regulations Marking requirements - Summary:  Marking requirements - Summary Yes if Product is an EIP sold to the user Symbol 1 if no substance restrictions Symbol 2 if contains restricted substances Need EFUP Need substance disclosure table Packaging information Product is not an EIP but contains EIP components Awaiting clarification from MII on 60% rule – not required yet, mark only EIPs No if Product is sold to OEM who uses it as a component within their products OEM still requires details on 6 restricted substances Spare parts (unless sold individually to user-usually for repair) Who is responsible?:  Who is responsible? Everyone in the supply chain has responsibilities This may include (not all on 1st March but via future standards) Manufacturers Designers Importers Distributors Retailers Penalties could include (not yet defined) Fines Withdrawal of operating licenses Closure of production or distribution facilities Criminal sanctions in serious cases Imposed by issuing authorities in line with their scope of authority MII, AQSIQ, SAIC, GAC etc Conclusions:  Conclusions “China RoHS” will apply from 1st March 2007 and covers a wide variety of products Initially it requires marking of products (EIPs) only Symbol 1: No restricted substances Symbol 2: Restricted substances + EFUP + Disclosure of substances Some specific products will be listed in the “Catalogue” Substance restrictions will apply (some, or all, of 6 EU substances) Other substances maybe defined Exemptions Testing required CCC required Thank You :  Thank You GARY NEVISON

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 | 03/02/15

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