Progress on China RoHS2 – Draft Compliance Management Catalog & Exemption List Published
SAFEGUARDS | Electrical & Electronics NO. 133/17
China’s MIIT has published a draft “Compliance Management Catalog for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products (1st batch)” and a draft “Exemption list” for China RoHS2.
Following extensive review, a draft “Compliance Management Catalog for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products (1st batch)”  and a draft “Exemption list”  under China RoHS2 were published for public consultation by China’s Ministry of Industry and Information Technology (MIIT) on June 29, 2017. The consultation period closed on July 28, 2017.
The draft Compliance Management Catalog includes 12 product types:
- Air conditioners
- Washing machines
- Electric water heaters
- Fax machines
- Mobile communication handsets
According to China RoHS2, there are two steps to restrict the use of six hazardous substances . In the second step, it is mandatory that products listed in the Compliance Management Catalog shall comply with the restriction limits of the six substances according to related standards. The compliance of products listed in the Compliance Management Catalog will be reviewed according to the conformity assessment scheme, which is still under discussion.
Considering the current state of technology, a draft of exemption list applicable to the products listed in the Compliance Management Catalog was also published for public consultation. There are 39 exemptions in the draft list, including all the exemptions in EU RoHS2 Annex III, and also the EU RoHS2 exemptions expired in May, 2017. China RoHS2 differs from EU RoHS2 in that the exemption list is grouped base on the classification of six hazardous substances, and most of them do not have expiration dates. It is worth noting that the exemptions list will be only applicable to the products in the Compliance Management Catalog during the conformity assessment, but not to other products’ compliance assessment in step one of China RoHS2.
At the present stage, all regulated electrical and electronic products shall meet the requirement of step one of China RoHS2, i.e. to provide a proper label to assist consumers and recycling factories to indentify information about restricted substances in the products according to SJ/T 11364-2014 Marking for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products. The Jiangsu Inspection and Quarantine Bureau recently issued imported goods quality inspection information in the first half of 2017 . Lots of ports, such as Wuxi, Taicang, Zhenjiang and Suzhou industrial park, found a number of production batches of imported electrical and electronic products which contain China RoHS2 restricted substances, but without a proper label and declaration table, violating the China RoHS2 regulation and requiring rectification. The table below summarizes the market surveillance information:
|Product||Exporting country||Failed Reason|
|4 batches ultrasonic therapeutic apparatus (value US$ 329,000)||Republic of Korea||Without China RoHS2 label & declaration table|
|54 web cameras||Japan||Without China RoHS2 label & declaration table|
|Network controller||United states||Without China RoHS2 label & declaration table|
For products not listed in the Compliance Management Catalog, after the Catalog comes into effect, they shall also comply with the labeling requirements summarized below:
- Green symbol with "e" in it: The product does not contain restricted substances and is a green, environmentally friendly product which can be recycled
- Orange symbol with a number in it: The product contains certain hazardous substances and can be used safely during its environmental protection use period (EPUP) (as indicated by the number in the center) and should enter into the recycling system after EPUP. Manufacturers and importers shall also provide a declaration table for the hazardous substances present in the product according to standard SJ/T 11364-2014
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