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China RoHS came into force in March 2007 and the variety of information available for those trying to decide exactly what it means is dizzying. Here Richard Kenshole, Component Engineering Manager for Lambda UK highlights the most important points about the legislation and offers his opinions on how it will affect industry.

China RoHS, or to give the legislation its full title ‘Measures for the Administration of the Pollution Control of Electronic Information Products, Ministry of Information Industry (MII) Order No 39’, came into force on 1st March 2007 and applies to products sold in China (not products exported from China). The legislation can be split into two distinct stages: Stage one where all Electronic Information Products (EIP) must be marked with certain information and the packaging must also be labelled; Stage two which is concerned with a yet-to-be-drafted catalogue and the restrictions that inclusion in this will entail.

Stage one – marking and labelling
As from March 1st 2007 all products to be sold in China, that appear on the EIP list and that were made after 1st March, have to conform to China RoHS labelling and marking requirements. These requirements include: a table with all parts that contain a restricted substance (similar to the Japanese labelling requirements); a symbol which includes an indication of the environmentally friendly period and a packaging mark on all packaging.

In terms of restricted substances China RoHS has the same ‘banned’ substances as Euro RoHS (Lead, Mercury, Cadmium, Chrome 6, PBB, PBDE), but there are some important differences. China RoHS does not have any exemptions on the EIP list, for example the ceramic in surface mount resistors, contains lead which in Euro RoHS would be exempt, but not in China RoHS. At this point the manufacturer would have to provide a table of information about the product, in Chinese language. This information again must only be provided if the customer in China is an end user, or if the product is for the Chinese domestic market.

If a product contains none of the restricted elements then it can display the Green China RoHS symbol. However, those products that do not conform must display the orange version of the symbol even if they are exempt in EU. As readers can see from the example this symbol has a number within it. This number is where the manufacturer has to estimate at which year the restricted substances contained within the product could begin to leach into the environment. This figure is either between 1 and 10 years (shown in single figures) or between 10 and 50 years (in which case the figure must be shown in multiples of five). The normal packaging mark size is to be 40 by 40mm but for especially large or small package component sizes the mark may be enlarged or reduced as appropriate.

Stage two - verification
The second stage of China RoHS is where the real differences from the Euro version become apparent. Between the end of 2007 and 2008 the Chinese MII is to publish a paper catalogue that will contain all the products that must conform to China RoHS. Again, the elements covered are the same as in Europe but there are most likely to be products in the Chinese catalogue that are not currently covered by Euro RoHS. Possible areas such as medical, military and aerospace could be included.

There are numerous additional requirements on products that feature in the catalogue. First amongst these is that the restricted elements contained within a certain product cannot exceed the maximum concentration limits and more importantly these declarations are to be verified by a Chinese-approved laboratory before the product is permitted to be sold. This verification process could create a bottleneck as there are currently only eight such laboratories in China and independent verification by a testing organisation is simply not accepted.

A factor which could ease the bottleneck is that every product listed in the catalogue has a date by which it must be certified. The allocation of these dates will be crucial, but as to what happens to those products at the back of the queue it is unclear. It is my feeling that large volume white goods will go into the catalogue and through the verification process first and I do not feel that embedded power supplies, i.e. built into end equipment, will be in the first edition. Once the products have passed through the verification process then they can be marked with the CCC (China Compulsory Certification) legend.

The scope of EIP and the 60% rule
Under China RoHS, the scope of what is classified as an EIP is much wider than under Euro RoHS and includes: certain production equipment; electrical and electronic components; spare parts, sub-assemblies and batteries. There are also possible implications for electrical products that are not EIPs but that contain EIPs.

According to the legislation, non-EIPs that contain EIPs are not included, however, there is a general rule of Chinese legislation – the 60% rule. This means that products that contain EIPs with a monetary value of more than 60% of the total value are regarded as EIPs. This is made more complex still because products that contain EIPs with a monetary value of less than 60% are not EIPs but may need to be marked with the information on the contained EIPs.

So the question that needs to be answered is ‘When is marking required?’. It is required when the product is an EIP sold to the end user and if the product is not an EIP but adheres to the 60% rule. Marking is not required when a product: is sold to an OEM who uses it as a component; is not sold in China; is a military product; is not ‘put onto the market’ i.e. demonstration samples for own use; is software. Enforcing this will be the Chinese customs agencies, who will look for labeled products as under China RoHS manufacturers must mark products, again a difference to Euro RoHS.

In terms of how the legislation affects Lambda it is not clear at this stage. Whereas I do not expect embedded power supplies to appear in the catalogue they are included on the EIP list and therefore they must have the table of ‘Toxic and Hazardous Material Names and Contents’. The purpose of this is to provide the recycler with information about where and which RoHS substances are present. It is an important point that this table is a self-declaration with no restrictions on the six substances and without the requirement to analyse, again markedly different from the catalogue.

I feel that, as was the case with its European counterpart, there is so much conjecture surrounding China RoHS that the fundamentals are often lost. The basic point is that when dealing with any supplier, manufacturers should enquire at an early stage about the steps the supplier has taken towards China RoHS compliance. They should, as Lambda can, be able to demonstrate that the right documentation is available and that the right procedures are in place.

About the author:
Richard Kenshole is Component Engineering Manager for Lambda UK and for the past 10 years has spent six months of every year in China.