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CHINA ROHS COMPLIANCE

Conformity with China RoHS is mandatory to anyone introducing electrical or electronic equipment into China.

The Enviropass Approach for China RoHS Testing

You can choose two types of services for your China RoHS testing, declaration, and label logo symbol:

  • Classic China RoHS
  • Deluxe China RoHS

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.

Classic China RoHS

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

Deluxe China RoHS service shows you how to fish! Indeed, Deluxe China RoHS includes:

  • Verifying products according to China RoHS requirements, preparing the China RoHS table in Chinese and determining the applicable marking;
  • Products assessment training that will allow you to analyze yourself your new products and to update your compliance statements as required (i.e. when design change, etc.).

Aren't China and Europe RoHS the Same?

Complying with the Europe RoHS directive requirements is generally helpful. Indeed, both RoHS regulations share the same thresholds and same controlled substances, at the homogeneous material level:

SubstancesThreshold 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 (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 RoHS China – 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 China 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 China 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.

Examples of EFUP marking symbols
Examples of EFUP marking symbols

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.

e logo EFUP China RoHS

If any of the above-mentioned threshold limits are exceeded in the homogeneous materials level of a device then:

  • an orange EFUP symbol must be marked on the product.  The orange color is optional.  The figure (5, 10, 15, 20, 25, etc.) of this symbol represents the number of years during which no hazardous substances would leak or mutate under normal conditions of use.  The standard SJ/Z 11388-2009 – General Guideline of Environmental-friendly Use Period of Electronic Information Products – gives guidance on how to estimate this EFUP year period.
10 years EFUP logo China RoHS
  • the product must bear a manufacturing year, indicated the beginning of the EFUP year period.
  • a table, similar to the above-mentioned one must appear in the product documentation. The X must be written in the table whenever a restricted substance exceeds a threshold in a sub-assembly, otherwise, an O must be written.

China RoHS 2019

Since November 1st, 2019, the following product categories must meet the China RoHS requirements of ‘The Implementation Arrangements for the Conformity Assessment System for the Restriction of Hazardous Substances in Electrical Appliances and Electronic Products’:

  • Air conditioners
  • Copiers
  • Electric water heaters
  • Fax machines
  • Handheld phones for mobile communication
  • Micro-computers
  • Monitors
  • Printers
  • Refrigerators
  • Telephone sets
  • TVs
  • Washing machines

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:

  • The voluntary certification with a third-party certification body. Then, certified products are published on the ‘Public Service Platform for the Restriction of Hazardous Substances in Electrical Appliances and Electronic Product’
  • Self-declaration, with the submission of technical documentation and declaration of conformity on the Public Service Platform

Depending on the adopted certification approach, compliant products must be marked with one of the following logos:

China RoHS compliance logos of Declarations of Conformity

VOC Emissions from Electronic Manufacturers

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:

  • GB 30981-2020 – Limit of harmful substances of industrial protective coatings
  • GB 33372-2020 – Limit of volatile organic compounds content in adhesive
China Manufacturer Electronic air pollution
  • GB 38507-2020 – Limits of volatile organic compounds (VOCs) in printing ink
  • GB 38508-2020 – Limits for volatile organic compounds content in cleaning agents

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!