Understanding Taiwan RoHS Compliance: Guidance to Reduce the Use of Restricted Chemical Substances in Electrical and Electronic Equipment (EEE)

Taiwan RoHS, represented by the CNS 15663 standard, is a voluntary conformity standard established by the Taiwan Ministry of Economic Affairs Standards Inspection Bureau. Released on July 30, 2013, CNS 15663 provides guidance on reducing the presence of restricted chemical substances in electrical and electronic equipment (EEE) in Taiwan.

What is CNS 15663?

CNS 15663, titled "Guidance to Reduce the Use of Restricted Chemical Substances in Electrical and Electronic Equipment (EEE)" acts as a roadmap for companies seeking to comply with Taiwan RoHS and reduce the presence of restricted chemicals in their products. It outlines specific requirements and methodologies to identify, assess, and manage these hazardous substances throughout the manufacturing process. Bureau of Standards, Metrology, and Inspection (BSMI), under the Ministry of Economic Affairs, is responsible for implementing Taiwan RoHS. CNS 15663 standard promotes transparency, product safety, and environmental sustainability. By following the guidance provided by CNS 15663, businesses can ensure their products meet the regulatory standards and contribute to a safer and greener future.

What Substances are Restricted under Taiwan RoHS?

The following substances are restricted in electrical and electronic equipment under Taiwan RoHS:

1. Lead (Pb) - restricted to 0.1% weight percentage
2. Mercury (Hg) - restricted to 0.1% weight percentage
3. Cadmium (Cd) - restricted to 0.01% weight percentage
4. Hexavalent chromium (Cr+6) - restricted to 0.1% weight percentage
5. Polybrominated biphenyls (PBB) - restricted to 0.1% weight percentage
6. Polybrominated diphenyl ethers (PBDE) - restricted to 0.1% weight percentage

The Scope of Taiwan RoHS

Covered Products: The scope of Taiwan RoHS or CNS 15663 applies to electrical and electronic devices with a power supply voltage below 1000V AC or 1500V DC. These products encompass a wide range of consumer, industrial, and commercial equipment.

• Information Technology Equipment (e.g., computers, laptops, printers, monitors)
• Telecommunications Equipment (e.g., phones, mobile devices, routers)
• Consumer Electronics (e.g., TVs, cameras, audio/video equipment)
• Lighting Equipment (e.g., lamps, luminaires)
• Electrical & Electronic Tools (e.g., drills, saws, soldering equipment)
• Toys, Leisure, & Sports Equipment (e.g., electronic toys, gaming consoles)
• Medical Devices (e.g., monitoring equipment, diagnostic devices)
• Monitoring and Control Instruments (e.g., meters, gauges)
• Automatic Dispensers (e.g., vending machines, ATMs)
• Industrial Equipment (e.g., manufacturing machinery, laboratory equipment)
• Other equipment covered by CNS 3765, CNS 14408, and CNS 14336-1

Excluded Products: Certain products are excluded from Taiwan RoHS, such as

• EEEs not reliant on electricity as the primary power source
• EEEs not requiring electrical components for their primary function
• EEEs that are part of other products
• Batteries
• Large-scale stationary industrial tools
• Annex C of CNS 15663 provides additional details on exemptions.
• Annex D of CNS 15663 lists 37 conditions for exemption from concentration limits.

Taiwan RoHS Compliance Assessment Options

• Self-Declaration: One common option for assessing compliance with Taiwan RoHS is through self-declaration. Manufacturers and importers can conduct in-house testing or rely on test reports from their suppliers. They must gather the necessary data and documentation to demonstrate that their products meet the prohibited substance levels. This method requires a comprehensive understanding of the regulation and the ability to effectively assess and verify compliance.
• Third-Party Testing and Certification: Another option is third-party testing and certification. Manufacturers and importers can collaborate with independent testing facilities or certification bodies to conduct thorough product testing and evaluation. These third-party organizations possess the expertise and accreditation to perform the necessary tests and issue compliance certificates. Third-party testing and certification add credibility and assurance for customers and regulatory bodies.

The choice between self-declaration and third-party testing depends on various factors, including the complexity of the product, available resources, and the desired level of confidence in compliance. RoHS Compliance software can support in compliance assessment process by automating supplier engagement, compliance data management & validation process.

Understanding BSMI Approval

BSMI Approval refers to the certification or approval process conducted by the Bureau of Standards, Metrology, and Inspection (BSMI) in Taiwan. Certain categories of products require BSMI Approval before they can be legally sold or imported into Taiwan. The approval process involves assessing the product's compliance with relevant safety, quality, and technical standards established by the BSMI. When a product is compliant with RoHS, the "RoHS" logo symbol must be displayed alongside the commodity inspection mark, with an identification number starting with R (RPC), D (DoC), T (TABI), or Q & M ("Monitoring Inspection").

Below is the pattern of the commodity inspection marks:

• Each mark carries a unique 5-digit identification number, commencing with either "R," "T," "D," "Q," or "M." The identification number, together with the term "RoHS," should be positioned below or to the right of the graphic symbol.
• The presence of "RoHS" signifies that the product complies with the concentration limits for all six restricted substances.
• In the case of "RoHS(XX, XX)," it indicates that the product contains specific restricted substances that surpass the concentration limits. For instance, "RoHS (Cd, PBDE)" signifies that the product exceeds the concentration limits for Cd and PBDE.

BSMI Approval Procedures

There are three main BSMI Approval procedures, depending on the product category:

1. Registration of Product Certification (RPC): Manufacturers or importers register their products with the BSMI to demonstrate compliance with the RoHS requirements. This procedure involves submitting relevant documentation and information to obtain an official certification mark, enabling authorities to track and monitor compliant products in the market. RPC ensures transparency and facilitates regulatory compliance for products subject to Taiwan RoHS.
2. Batch-by-Batch Inspection: Batch-by-Batch Inspection is a method used in Taiwan RoHS to assess compliance with the regulation's requirements on hazardous substances. It involves inspecting each batch or lot of products to ensure they meet the restricted substance limits specified by Taiwan RoHS. This inspection process verifies that products in the market comply with the regulation on a batch-by-batch basis, ensuring continuous adherence to the restricted substance requirements and maintaining consumer safety.
3. Declaration of Conformity (DoC): The Declaration of Conformity (DoC) is a document issued by the manufacturer or importer of a product to declare its compliance with the requirements of Taiwan RoHS. The DoC states that the product meets the restricted substance limits outlined in the regulation and is in accordance with applicable standards and regulations. It serves as a formal declaration of the product's conformity and is often required to demonstrate compliance during audits or inspections by regulatory authorities.

Taiwan RoHS: Hazardous Substances Marking

In Taiwan RoHS, the Hazardous Substances Marking is a labeling requirement for products containing restricted substances above the specified threshold limits. The marking is used to inform consumers, regulatory authorities, and other stakeholders about the presence of hazardous substances in the product. Companies must clearly mark the hazardous substance content table on the body, packages, stickers, or instruction books of the affected EEE products. Additionally, those utilizing websites to announce "the presence conditions of the restricted substances" must clearly mark the website address on the body, packages, stickers, or instruction books.

Below table shows an example of how to mark the presence of hazardous substances in EEE products by components:

Why is Taiwan RoHS Important?

Taiwan RoHS plays a vital role in protecting human health and the environment by reducing hazardous substances in electronic devices. Compliance with this regulation is crucial for manufacturers and importers to ensure market access in Taiwan, meet regulatory requirements, and showcase a commitment to responsible manufacturing.

Conclusion: Taiwan RoHS, as defined by CNS 15663, is an essential regulation that aims to minimize the presence of hazardous substances in electrical and electronic equipment. Compliance with this regulation not only ensures market access in Taiwan but also demonstrates a commitment to sustainable and responsible manufacturing. By understanding the requirements, compliance methods, BSMI approval, and the significance of hazardous substances marking, manufacturers and importers can navigate Taiwan RoHS successfully, fostering a safer and more eco-friendly electronics industry.