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 [email protected]