You can choose two types of services for your China RoHS testing, declaration, and label logo symbol:
China RoHS vs EU RoHS: If you already have sufficient Europe RoHS technical documentation, Enviropass can reuse and adapt the information to China RoHS conformity for a fraction of the price.
With Classic China RoHS, you allow Expertise Enviropass to take over your products’ documentary assessments.
Enviropass will also prepare a table in Simplified Chinese for each substance to be examined, along with the recommendation of the applicable EFUP marking.
Deluxe China RoHS service shows you how to fish! Indeed, Deluxe China RoHS includes:
Complying with the Europe RoHS directive requirements is generally helpful. Indeed, both RoHS regulations share the same thresholds and same controlled substances barring phthalates, at the homogeneous material level:
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 |
However, it is not sufficient to claim conformity to the China RoHS regulation, i.e. Ministry of Industry and Information Technology MIIT Order #32 – Management Methods for the Restriction of the Use of hazardous Substances in Electrical and Electronic Products.
Except for household equipment regulated under China RoHS 2019 (please find details at the end of this article), the objective under RoHS is mainly to communicate the hazardous substances above a certain threshold, not to limit their concentrations.
Furthermore, contrary to Europe RoHS, your device placed in China must come with a specific label and a RoHS table in Chinese, identifying the restricted hazardous substances exceeding the general thresholds.
As a result, if there is no RoHS table or if your product does not bear the Environmental Friendly Use Period (EFUP) label, then it is very easy for Chinese authorities to know it is not compliant and therefore to retain it at the border.
If none of the above-mentioned threshold limits is contained in the homogeneous materials of a device, then the green ‘e’ EFUP symbol must be marked on the product. However, the green color is optional.
If any of the above-mentioned threshold limits are exceeded in the homogeneous materials level of a device then:
Since November 1st, 2019, the following product categories must meet the RoHS requirements of ‘The Implementation Arrangements for the Conformity Assessment System for the Restriction of Hazardous Substances in Electrical Appliances and Electronic Products’:
Similar to the EU RoHS, restrictions of lead, mercury, cadmium, hexavalent chromium, PBBs, and PBDEs apply to these product categories.
To show compliance, producers must either choose:
Depending on the adopted certification approach, compliant products must be marked with one of the following logos:
We know that China is the biggest manufacturer of Electronics in many areas. We also know that pollution, and particularly emissions of Volatile Organic Compounds (VOCs) into the atmosphere, contaminates the air. And the Electronics industry emits large quantities of VOC.
In order to fight the air pollution in China, the State Council of the People’s Republic of China has published a ‘three-year action plan to win the battle for a blue sky’. As a result, 4 mandatory standards targeting VOCs were published in 2020:
These standards are NOT part of China RoHS. However, they impose limitations not only on VOCs, but also on heavy metals, halogenated hydrocarbons, formaldehyde, Polycyclic aromatic hydrocarbons (PAH), and other chemicals used in the production of electronics.
Contact Enviropass for any questions on applicable Chinese regulations!
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