As the China RoHS marking requirements enter force on 1 March 2007, ERA’s Dr Paul Goodman reviews Chinese Ministry guidance on implementation.

The Chinese Ministry of Information Industry has published guidance on interpretation of the legislation known as China RoHS. These FAQs were published originally in Chinese on 1 December 2006 but the American Electronics Association (AeA) has provided an interpretation of the 83 points addressed together with translation of certain pertinent sections from the FAQs. This review highlights new information or where the requirement appears to have changed from the previously understood position.

Sale of components: All EIPs (electronic information products) sold in China must be marked but if these are sold to OEMs then this is not required but the supplier must provide information on any hazardous substances present.

Label colours: “Green” and “orange” are recommended but this answer states that producers may use any colour as long as they are “striking” to the consumer.

Put onto the market date: Contrary to the original definition (date of sale), this is now regarded as the production date - the date when “the product comes off the production line”.

Packaging marks: The marks in Chinese standard GB18455-2001 take precedence over other marks that might be used in other countries. The marks should be applied to the outermost layer of packaging so that it is clearly visible. It is stated however that “we encourage that recycling packaging information be put on each package material”.

Spare parts: It appears that if spare parts are sold individually to users, they must be marked. If sold to an OEM, then they are treated in the same way as components.

Hazardous substance table: The default requirement is that the table must appear in product literature available to the end user and the FAQs point out that putting this information on the web, while a useful supplement, is no substitute because internet access in China is limited. It does however allow that, where EIPs such as electronic components and materials are distributed only to those who do have internet access, then this information can be provided on the web alone.

Enforcement: At present, it is unclear how the first stage marking requirements of China RoHS will be enforced but these answers indicate that Chinese customs (CIQs) and officials inside China will carry out spot-checks (market surveillance).

Catalogue: It is likely that a product will be included in the catalogue when it can be produced (in China) without the RoHS substances (unless there is no substitute). The process should be systematic and allow sufficient time for producers to comply. Industry is invited to participate and can submit information via chinarohs@mii.gov.cn.

Analysis of small parts (Q57): Very small parts are regarded as single homogeneous materials and a size limit EIP- C is for parts <4 mm3 whereas larger parts come under EIP-A and so all homogeneous materials within these need to be assessed.

Coatings – not intentionally added: The view is that if a RoHS substance is not intentionally added, it will not be present. The policy which the authorities intend to follow is that if a RoHS substance can be detected at above the MCV by analysis, then it will be regarded as being intentionally added.

Reference: American Electronics Association www.aeanet.org/GovernmentAffairs/gamm_ChinaRoHS_WorkshopFAQs.asp
This article is an excerpt from an article in ERA’s environmental newsletter RE 4view.

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