management methods for controlling pollution by electronic information products chris cleet, manager...

Management Methods for Controlling Pollution byElectronic Information Products

Chris Cleet, Manager of Environmental AffairsElectronic Industries Alliance (EIA)

ECA Fall Engineering SummitSeptember 26, 2006

China Rulemaking PrinciplesChina Rulemaking Principles

Guilty until proven innocent China laws generally speak of “precaution”

Laws generally require “proof of innocence” Pre-market testing

Certification

China Rulemaking PrinciplesChina Rulemaking Principles

Looking internationally for inspiration Looking to other countries for models

Use of “models” does not mean they are “copying” Tend to review models for inspiration

Fit to meet China’s needs

China Rulemaking PrinciplesChina Rulemaking Principles

Resource Conservation China increasingly concerned with resources

conservation Energy

Water

Materials

“Management Methods for Controlling Pollution by Electronic

Information Products”

RoHS PronunciationRoHS Pronunciation

"Ross"

"Row-Hass"

"Roce"

"Rowsse"

"Rose"

"Roz"

"R.O.H.S."

"Rosh"

China RoHSChina RoHS

≠

There is a misperception that because it’s often called “China-RoHS” that it is just like the European Union RoHS Directive

AgenciesAgencies

Lead agency:

Several other agencies are involved in developing the implementing measures for China RoHS State Environmental Protection Agency (SEPA)

Administration for Quality Supervision, Inspection and Quarantine (AQSIQ)

State Administration for Industry and Commerce (SAIC)

Important DatesImportant Dates

2006 2007

February 28, 2006

China RoHS promulgation. China RoHS released to the public a few days later

March 1, 2007

Effective date for labeling provisions and measures other than materials restrictions

September 2007 – March 2008

Projected, possible effective dates for first batch of catalogues/ materials restrictions

September 2006 – June 2007

Possible promulgation period for RoHS standards (will not be released all at once; labeling, MCV and testing standards likely released first)

ScopeScope

“Electronic Information Products” Defined in categories; there are many…partial list

is: Communications equipment, electronic components,

audio equipment, surveying equipment

MII issued an illustrative note listing products in these categories, on March 16, 2006

Covers finished products, parts and components and materials

China RoHSChina RoHS

Three key components:

Thou shalt not use…

Substance Restrictions Pre-market certification

Labeling

China RoHSChina RoHS

To ease understanding…think of China RoHS as two separate laws:

1) Labeling and information disclosure

2) Substance restrictions and pre-market certification

Labeling and Information DisclosureLabeling and Information Disclosure

Must comply if “you import or manufacture EIP”

Goal of labeling: Protect environment

Provide end-of-life information for users and recyclers

Labeling and Information DisclosureLabeling and Information Disclosure

Three key elements: Environmental protection period (articles 3,

11, 12)

Material content, toxic-substance content and recyclability marking (article 13)

Packaging material content marking (article 14)

Labeling and Information DisclosureLabeling and Information Disclosure

Materials content and environmental protection period accomplished through product labeling

Label 1 Label 2

Labeling and Information DisclosureLabeling and Information Disclosure

Label 1: Any EIP that does not contain toxic or

hazardous subtances

Must be on product or in product literature

Label 2: Any EIP that contains toxic or

hazardous substances

Must be marked on product (except where product literature marking is authorized, per the labeling standards)

Labeling and Information DisclosureLabeling and Information Disclosure

If EIP is subject to label 2, a table must be in the product literature:

Name of Part*

Pb Hg Cd Cr6+ PBB PBDE

resistor X O O O O O

*Definition of “part” is subject to MII interpretation

Substance RestrictionsSubstance Restrictions

Catalogue approach

No “exemptions” as per EU RoHS

If not in catalogue, not covered

MII is working on criteria for listing EIP in the catalogue

Substance RestrictionsSubstance Restrictions

Current substance restrictions (article 3) Lead Mercury Cadmium Hexavalent chromium PBBs PBDEs

Maximum concentration limit standards (MCVs) are being finalized and will be set forth in an implementing standard

Substance RestrictionsSubstance Restrictions

Pre-market testing and certification Apply only to those EIP listed in the

Catalogue

Will require testing by Chinese labs

AQSIQ certification based on lab results

Testing methods are being finalized

Dates for implementation to be included on catalogue

Q&AQ&A

Contact InformationContact Information

Chris CleetManager of Environmental AffairsElectronic Industries Alliance703-907-7573ccleet@eia.org