Inclusion of China RoHS Phthalates

The Ministry of Industry and Information Technology of the People’s Republic of China (MIIT) has drafted an amendment to include new substances to China RoHS: four phthalates.

Importantly, to introduce electrical or electronic equipment into China, producers and importers must comply with this so-called China RoHS-2.

What is the China RoHS Amendment on Phthalates?

On March 14, 2022, the Electrical and Electronic Product Pollution Control Standardization Group of MIIT (The Chinese Ministry of Industry and Information Technology) and other agencies conducted a virtual meeting announcing intentions for revising the standards of China RoHS. Accordingly, this amendment reinforces the restriction of hazardous substances in electrical and electronic products under China RoHS regulation. Over 1,700 industry representatives attended this meeting.

What are the China RoHS Phthalates?

The main goal of this amendment is to add four phthalates and bring the total number of chemicals within the scope of China RoHS regulation to 10, in line with the EU RoHS legislation.

The four phthalates are:

Bis(2-ethylhexyl) phthalate (DEHP)
Butyl benzyl phthalate (BBP)
Dibutyl phthalate (DBP)
Diisobutyl phthalate (DIBP)

These are the same four phthalates that were added to EU RoHS in 2015 through Commission Delegated Directive 2015/863 amending Annex II to Directive 2011/65/EU of the European Parliament and of the Council as regards the list of restricted substances.

Furthermore, this amendment intends to set precise rules for hazardous substance labeling and test procedures. As a result, this new revision of China RoHS revises the SJ/T 11364-2014 standards-Marking requirements for restrictions on the use of hazardous substances in electronic and electrical products. To prove compliance with this new amendment, companies must label their products according to the presence of the chemicals and guarantee that concentrations do not exceed the threshold set by the regulation.

Why these China RoHS Phthalates?

According to a report by the China Electronics Standardization Institute, these phthalates have been added as part of MIIT’s mission to make production processes cleaner and to control the use of hazardous substances in electronic products. These substances cause harm to the environment and human health, and their regulation further implements China’s green industrial development program as part of their 14^th Five-Year Plan.

What is the Implementation Schedule of the China RoHS Amendment on Phthalates?

The following table demonstrates the timeline for this new amendment, according to the Fifth Electronics Research Institute of MIIT:

Deadline	Actions
April 2022	Conducting research on companies to investigate the feasibility of restricting the usage of the four phthalates
September 2022	Developing and revising regulatory standards based on the research
December 2022	Announcing related requirements on the revised GB/T 26572 “Requirements of concentration limits for certain restricted substances in electrical and electronic products” standards

What is RoHS?

RoHS stands for the Restriction of Hazardous Substances. It is a law that restricts the use of certain hazardous substances used in electrical and electronic equipment. These products are heavily regulated because they are harmful to the environment, wildlife, and human health. Their restriction makes electric and electronic waste less damaging and easier to recycle.

Different countries have different RoHS regulations. Any in-scope electrical or electronic equipment being introduced into a country must comply with that country’s RoHS regulations.

China RoHS: the Gist

China regulates ten hazardous substances and restricts their use in products above a certain threshold, as outlined in the table below:

China RoHS Restricted Chemicals	Threshold Limits
Lead and lead compounds (Pb)	0.1% (w/w), 1000 ppm
Mercury and mercury compounds (Hg)	0.1% (w/w), 1000 ppm
Cadmium and cadmium compounds (Cd)	0.01% (w/w), 100 ppm
Hexavalent chromium and compounds (Cr VI+)	0.1% (w/w), 1000 ppm
Polybrominated biphenyls (PBBs)	0.1% (w/w), 1000 ppm
Polybrominated diphenyl ethers (PBDEs)	0.1% (w/w), 1000 ppm
Butyl benzyl phthalate (BBP) – CAS # 85-68-7	0.1% (w/w), 1000 ppm
Di-n-butyl phthalate (DBP) – CAS # 84-74-2	0.1% (w/w), 1000 ppm
Bis(2-ethylhexyl) phthalate (DEHP) – CAS # 117-81-7	0.1% (w/w), 1000 ppm
Diisobutyl phthalate (DIBP) – CAS # 84-69-5	0.1% (w/w), 1000 ppm

In addition, any device introduced to China must come with:

a manufacturing year,
a RoHS table in Chinese identifying any restricted substances exceeding general thresholds, as well as
the Environmental Friendly Use Period (EFUP) label.

What are Phthalates?

Phthalates are a group of chemicals used in plastics, cosmetics, fabrics, electronics, and many other products. People may be exposed to the phthalates in the items they use. Most phthalates do not pose a significant threat to the environment or human health. However, certain phthalates, particularly the ones of China RoHS, are toxic.

Contact Enviropass for any questions about China RoHS-2 or product environmental regulations in other countries.