ask the experts: china rohs faqs

[email protected] | www.assentcompliance.com | TEL: 1 866 964 6931 1

Ask the Experts:China RoHS FAQs


Today’s Presenter

James CalderAssent ComplianceDirector, Compliance Programs


Assent Product Suites

Ethical Sourcing

Materials Management

Supplier Information Management

Inspections & Audit Tools

Configurable Surveys & Declarable

Substance Lists


The Assent Advantage


Agenda

Summary of China RoHS 1

Summary of China RoHS 2

Description of FAQ

Discussion on specific ‘Hot Topics’

1234


China RoHS 1

Management Methods on the Pollution Control Caused by Electronic Information Products

Passed February 28, 2006 and entered into effect March 1, 2007.

Known as “China RoHS” due to the substances captured aligning with the EU RoHS Directive, despite never restricting the use of any substances.

Scope Defined list of products listed in the “Electronic Information

Products (EIP)” list. Excluded many products captured in EU RoHS while including components and other products NOT captured under EU RoHS.


China RoHS 1 Requirements

Requirements: Disclosure of the six substances (Pb, Hg, Cd, Cr6+, PBDE and

PBBE) and their location within the product Captured in a “Table of Toxic and Hazardous Substances”

translated into simplified Chinese Environmentally Friendly Use Period (EFUP) label

Under the product quality law if there is technically an expiry date, then a date of manufacture is required

Packaging Recycling Mark

Requirements supported by standards for marking labeling, maximum concentration values and environmentally friendly use period

A ‘Catalogue’ was supposed to list products which require RoHS certification but it never had any official release.


China RoHS 2

Management Methods for the Restriction of the Use of Hazardous Substances in Electrical and Electronic ProductsPromulgated January 26, 2016Enters into effect July 1, 2016

Scope changed to “electrical and electronic products.”

“Devices and accessory products with rated working electrical voltages of no more than 1,500 volts direct current and 1,000 volts alternating current which function by means of current or electromagnetic fields, and generate, transmit and measure such currents and electromagnetic fields.”

But excludes power generation, transmission and distribution equipment.


Do We Finally Get the “R” In China RoHS?

Compliance Management Catalogue

The catalogue of electrical and electronic products that have met the requirements for restricted use of hazardous substances

The catalogue contains: The electrical and electronic product categories The uses of restricted hazardous substance classes The restricted use times The exemption requirements Other content

No longer compulsory certification but now a “Conformity Assessment System.”

EN 50581

ChineseStandar

d?


Do We Finally Get the ‘R’ In China RoHS?

Hazardous Substances:Lead and its compounds

Mercury and its compounds

Cadmium and its compounds

Hexavalent chromium compounds

Polybrominated biphenyls (PBB)

Polybrominated diphenyl ethers (PBDE)

Other harmful substances as regulated by the State

1234567


Table of Toxic & Hazardous Substances

Captured in SJ/T 11364—2014 (formerly SJ/T 11364-2014)


Environmentally Friendly Use Period (EFUP)

Also captured in SJ/T 11364—2014 (formerly SJ/T 11364-2014)

No change to the application of the EFUP, but increase in scope of products to require an EFUP

Number is based on the date of manufacture

Packaging Recycling Mark no longer mandatory


Reviewing the FAQ

This presentation will not cover every FAQ

The intention to review the most contentious and/or expedient issues

The interpretation is from a translation

The original text can be the only official source for interpretation


a”“

FAQ Topic of Concern 1: When?

When do products need to comply with the provisions of China RoHS 2?

Product Production Date Q5 and Q6 is the date at which products must meet the requirements. Implementation date is July 1, 2016.

The production date refers to the date that all processes of products are completed on the production line, products are inspected and packed as marketable finished products. The requirements for imported products and domestic products are similar, the time for implementation for both is subject to product production date and has nothing to do with inbound customs time or time-to-market.

This is now an inventory management activity.

[email protected] | www.assentcompliance.com | TEL: 1 866 964 6931 15a”

“Topic of Concern 2: Does It Apply to All

Electronic Products Similar to EU ROHS?Scope Decision Tree

Definition:

Devices and accessory products with rated working electrical voltages of no more than 1,500 volts direct current and 1,000 volts alternating current which function by means of current or electromagnetic fields, and generate, transmit and measure such currents and electromagnetic fields.


Topic of Concern 2: Does It Apply to All Electronic Products Similar to EU ROHS?

List of indicative and non-exhaustive product categories: Communication equipmentRadio and television equipmentComputer and other office equipmentHousehold appliances and electronic equipmentElectronic instrumentsIndustrial electrical and electronic equipmentElectric toolsMedical electronic equipment and instrumentsLighting productsElectronic education, industrial art, sports and entertainment products

12345678910


Topic of Concern 3: Which Products Are Excluded?

Equipment related to electric energy production, transmission and distribution, such as systems and devices used for power station, power distribution station and building power supply and distributionElectrical and electronic equipment used for military purposesElectrical and electronic equipment used in special or extreme environmentElectrical and electronic equipment used for export

Note: Electrical and electronic equipment used for export shall comply with provisions related to restricted use of hazardous substances in the country/region of ultimate destination.

Electrical and electronic equipment which are temporarily imported or imported for repair, but not for salePrototypes used for scientific research / research and development and testingSamples and exhibits used for exhibition and display, but not for sale.

1234

65

7


Topic of Concern 4: What About Transportation Products & Batteries?

Electric transport equipment and tools do not belong to electrical and electronic products, so they do not belong to the application scope of Measures for the Administration.

Except batteries and accumulators dedicated to products excluded clearly by Measures for the Administration in this document, all other batteries and accumulators belong to the application scope of Measures for the Administration .


Topic of Concern 5: What About Components & Unfinished Products?

Except wires and cables for power transmission and distribution involved in Item 1 of Q11, all other wires and cables of electrical and electronic equipment within application scope of Measures for the Administration shall meet the requirements of Measures for the Administration. For wires and cables sold in market without specific end use, they shall also meet the requirements of Measures for the Administration.

This implies that parts without a specific end use (i.e. components) are in scope unless exclusive for out of scope products.


Topic of Concern 6: What About Products Only Imported for Production & Export?

Broadly defined, processing and assembling with imported materials refers to the behavior of processing or assembling with imported raw materials or parts into finished products or complete machines, and then to export. The exported products and imported raw materials and parts used for export are not bound by Measures for the Administration.

Processing products with imported materials refer to the behavior of processing or assembling with imported raw materials or parts into finished products or complete machines and then sell them. If the products are used to export, they will not be bound by Measures for the Administration. If the products are sold in China’s domestic market, they shall meet the requirements of Measures for the Administration.

The exported products shall comply with provisions related to restricted use of hazardous substances in the country/region of ultimate destination.


Topic of Concern 7: What About Replacement Products?

The complete machine products with guarantee for replacement are considered as new products with the same product properties as the original products and put into market. They belong to the application scope of Measures for the Administration.

Does this mean that products manufactured before the date of compliance, but being used for replacement, must be compliant? Yes


Topic of Concern 8: What Kind of Documentation Can I Use to Demonstrate Compliance

The upstream supplier is required to provide relevant self-declaration information and supporting technical documents

Based on the existing real and effective product inspection report from any party, or test by itself, or entrust a third party to test the hazardous substances

Effective third-party product certificate. The interested parties shall be responsible for authenticity and effectiveness of declaration information

12

3


Topic of Concern 9: If I Use the Table From the Old Standard, Do I Have to Remove It & Use the New

One?

Under normal conditions, if the “hazardous substances name and content table” left by enterprises does not meet the standard requirements, it cannot be used continuously after the implementation of SJ/T 11364-2014. If this table is a part of product specification or printed on the product package, the specification / package can be used continuously. However, for reason of saving, enterprises can use the form of insert as the corrigendum of original table.


Topic of Concern 10: What About Products That Are Not EEE but Sold With EEE?

When accessories that do not belong to electrical and electronic equipment are sold with complete machines, they shall be identified according to SJ/T 11364-2014 if they are absolutely necessary for meeting the product structure requirements or function demands, such as the extension table of electric sewing machine and the lens hood of a camera, and the condition of hazardous substance content of these accessories shall also be noted in the “hazardous substances name and content table.” Otherwise, identification cannot be conducted.


Topic of Concern 11: How Detailed Do I Have to Be for Parts Listing In the Table?

The types of electrical and electronic products are various and the classification of product parts cannot be listed one by one. Enterprises can decide the specific classification mode of parts on their own, but each part of a product shall be included and the statement of hazardous substances is suggested to be made in the unit of single part or similar part, so as to fully reflect the condition of hazardous substance contents in products.

Parts without hazardous substances do not have to be listed in the hazardous substance content table in Table 1 of 6.2.2 of SJ/T 11364-2014.


Topic of Concern 12: How Are Products Added to the Catalogue?

The Ministry of Industry and Information Technology will cooperate with relevant ministries and commissions to issue the Catalogue for the Standard Compliance Administration batch by batch in the principle of openness and transparency according to the industry development situation.


Topic of Concern 13: What About Exemptions?

For products incorporated in Catalogue for the Standard Compliance Administration, the relevant application exception (exemption) of hazardous substances will be clarified and released along with Catalogue for the Standard Compliance Administration.

The transition period for execution of Catalogue for the Standard Compliance Administration will be set and this will be defined when the Catalogue for the Standard Compliance Administration is released.


Topic of Concern 14: How Long Is the Transition Period After a Product Is Added to the Catalogue?

The transition period for execution of Catalogue for the Standard Compliance Administration will be set and this will be defined when the Catalogue for the Standard Compliance Administration is released.


Topic of Concern 15: If I Get Bad Data from a Supplier, Am I Still Liable or Can the Liabilty Be Assigned to the Supplier?

If the final products are checked to be not compliant with requirements of Measures for the Administration, the responsibility will be taken by the producer of final products, although problems are caused by the upstream supplier of parts or elements. The responsibility of upstream suppliers shall be retroacted by the producer of final products on its own.


Summary


[Webinar] Cheat Sheet: Conflict Minerals Compliance & Supply Chain Transparency ConferenceWednesday, July 5th | 1PM

Upcoming Educational SummitsOctober 20, 2016 | ChicagoNovember 17, 2016 | BostonFebruary 8, 2017 | San Jose

Joint Materials Management Conference with Tetra TechDecember 1, 2016

Upcoming Events: Webinars & Conferences

More details to come at:www.assentcompliance.com/events

http://www.assentcompliance.com/events

http://www.assentcompliance.com/events


Any Questions?

Thank You