SAFEGUARDS | Electrical & Electronics NO. 045/18
On March 15, 2018, China’s Ministry of Industry and Information Technology (MIIT) released “The Standard Achieving Management Catalogue for the Restriction of Hazardous Substances in Electrical Appliances and Electronic Products (The First Batch)”  and “Exemption List for the Restriction of Hazardous Substances of the Standard Achieving Management Catalogue”  which shall enter into force one year after the publication date of March 12, 2018.
The Standard Achieving Management Catalogue (First Batch) includes the following 12 types of products with their scope, definition and the explanations on the scope of applications:
Electric water heaters
Handheld phones for mobile communication
Any content of lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, and polybrominated diphenyl ethers in the products listed above shall comply with the requirements of “Rules on the Restriction of Hazardous Substances in Electrical Appliances and Electronic Products” and related standards. The products are described in the scope of the conformity assessment scheme of hazardous substances in electrical appliances and electronic products. A product component is covered in the catalogue, when its usage is not clear and it is sold separately in the market. However, if a product covered by the catalogue is used as a component of another product (out of the scope of the catalogue), the catalogue will be not applicable to the product component. It is the finished product which will define the applicability of the catalogue.
As for situations under which RoHS compliance is technically or economically not feasible, the exemption list )which includes 39 exempt applications for the restriction of hazardous substances) is also established for the above products. These exemptions include all the exemptions of Annex III of EU RoHS 2, 39(a) in amending directive (EU) 2017/1975 and also those expired by March, 2018. It is different from EU RoHS 2 in that the exemption list of China RoHS 2 is grouped based on the six hazardous substances, and most of them do not have expiration dates. It is worth noting that the exemption list will be only applicable to the products in the catalogue during the conformity assessment.
At the present time, all regulated electrical and electronic products shall meet the requirement of step one of China RoHS 2, i.e. to provide a proper label to assist consumers and recycling factories to identify 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 Product). Many imported goods were inspected based on the labeling compliance of China RoHS 2 in 2017. Table 1 summarizes the market surveillance information:
Table 1. Summary of market surveillance in 2017.
|Product||Exporting country||Failed Reason||Measure|
|4 batches ultrasonic therapeutic apparatus||Republic of Korea||Without China RoHS 2 label & declaration table||Unknown|
|54 web cameras||Japan||Without China RoHS 2 label & declaration table||Returned cargo|
|Network controller||United states||Without China RoHS 2 label & declaration table||Impound|
|A batch of electric and electronic products||Malaysia, Japan||Without China RoHS 2 label||Rectification|
|45000 Li-ion batteries||Japan||Without China RoHS 2 label & declaration table||Rectification|
|536 fireplaces||Unknown||Without China RoHS 2 label & declaration table||Rectification|
|2 massage bathtubs||Japan||Without China RoHS 2 label & declaration table||Destruction|
Even products which are not covered in the new catalogue, shall comply with the labeling requirements summarized below.
Green symbol with an "e" in it: The product does not contain restricted substances and is a green, environmental-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 the EPUP. Manufacturers and importers shall also provide the declaration table of the hazardous substances present in the product according to the standard SJ/T 11364-2014
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