China RoHS 2: What You Need to Know About the Latest Compliance Requirements

In today's global marketplace, environmental regulations play a crucial role in ensuring the safety of products and protecting the environment. One such regulation is China RoHS, a set of standards aimed at controlling pollution caused by electronic information products (EIP) and electrical and electronic products (EEE). Understanding and complying with China RoHS is essential for manufacturers and suppliers operating in China and exporting products to the Chinese market. In this blog, we'll learn about China RoHS, covering its background, requirements, product categories, marking guidelines, and enforcement protocols.

China RoHS, officially known as the Administrative Measure on the Control of Pollution Caused by Electronic Information Products (ACPEIP), was implemented on March 1, 2007. It was introduced to address concerns regarding the presence of hazardous substances in electronic products and their impact on human health and the environment. Initially, China RoHS focused on electronic information products (EIPs) but was later expanded to include electrical and electronic products under China RoHS 2.

In 2016, the Chinese government made a major move to protect the environment and human health by introducing an update to their Restriction of Hazardous Substances (RoHS) regulations. Dubbed China RoHS 2, it came into effect on July 1st of 2016 and restricts substances such as lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBBs), and polybrominated diphenyl ethers (PBDEs). The original China RoHS only impacted EIPs, but this new update impacts all electrical and electronic products with working voltages less than or equal to 1000VAC and 1500VDC. The regulation also mandates product marking to indicate compliance status and provide information on the Environmental Friendly Use Period (EFUP), specifying the time before substances may cause harm.

The Chinese Ministry of Industry and Information Technology (MIIT) published a catalog of 12 types of EEPs that must comply with China RoHS 2 substance restrictions which are:

• Refrigerators
• Air conditioners
• Washing machines
• Electric water heaters
• Printers
• Photocopiers
• Fax machines
• Televisions
• Monitors
• Microcomputers
• Mobile communication handsets
• Telephones

Note - Unlike EU RoHS, there currently are no exemptions.

Environmental Protection Use Period

China RoHS 2 also stipulates that an Environmental Protection Use Period be listed for each product that contains restricted substances above the prescribed limit. This period starts on the date of manufacture and ensures that the products "will not leak or mutate suddenly under normal operating conditions and will not result in serious environmental pollution or cause serious bodily injury to the user or damage to their assets during the normal use by the user".

It is a big change for electronic manufacturers as they now have to take additional steps to ensure their products are compliant with the new regulations. This includes conducting regular testing of their products to detect any presence of restricted substances, as well as taking steps to reduce or eliminate the use of these substances in their products.

Substance Concentration Limits and Marking Guidelines in China RoHS

China RoHS 2 imposes substance concentration limits for each homogeneous material in a product, rather than for the product or component as a whole. Manufacturers must ensure compliance with these limits and mark products accordingly using prescribed symbols and labels. Compliant products bear a specific symbol, while non-compliant products require a different symbol along with a Hazardous Substance table listing non-compliant parts.

Latest Developments in China RoHS: Amendment No. 1 to GB/T 26572-2011 - Four New Phthalates Added to the Restricted List

After a long lead-in, China RoHS is finally being extended to cover a total of 10 restricted hazardous substances, including the addition of four phthalates: bis(2-ethylhexyl) phthalate (DEHP) (0.1%), butyl benzyl phthalate (BBP) (0.1%), dibutyl phthalate (DBP) (0.1%), and diisobutyl phthalate (DIBP) (0.1%) to the list of restricted substances. This significant expansion is part of Amendment No. 1 to GB/T 26572-2011, published on 29 June 2024 through China National Standard Announcement No. 14.

Transition Period for Compliance

An 17-month transitional period will now run until 1 January 2026, allowing manufacturers sufficient time to prepare for the new obligations. This period is crucial for companies to adapt their processes, supply chains, and product designs to meet the updated requirements.

Updated Testing Methods: Determination Methods of Restricted Substances

It's important to note that alongside the amendment, China has also updated the testing standards used for determining the presence of restricted substances in electronic products. Since March 1, 2024, conformity assessments for China RoHS compliance rely on the GB/T 39560 series of standards. These standards offer a more harmonized approach to testing, aligning with the international IEC 62321 series used in the EU RoHS directive.

Stricter Oversight and Penalties

The amendment underscores the government’s commitment to rigorous oversight. Compliance will be monitored through the China Compulsory Certificate (CCC) system, potentially requiring third-party testing by accredited laboratories. Non-compliance with these updated regulations can result in severe penalties, including fines and product recalls, emphasizing the critical importance of adherence.

Conclusion

It is expected that these changes will have a significant impact on electronic manufacturers, they will have to adapt to the new requirements in order to avoid penalties and maintain access to the Chinese market. However, the benefit of these changes is to further reduce the use of harmful substances in electronic products that can have a negative impact on the environment and human health.