China RoHS is a compulsory requirement for electrical and electronic products, i.e. it is illegal to sell or import products into China market without complying with China RoHS. The primary challenge for manufacturers or importers is that the compliance with EU RoHS does not automatically lead to the conformance to China RoHS. For example, the requirement of labeling and information disclosure in phase I of China RoHS is significantly different from that of EU RoHS. As for phase II, the difference grows even bigger in terms of conformity assessment (see ‘FLOWCHART’ tab). Accordingly, the differences of China RoHS to EU RoHS could be one of the barriers for EE manufacturers who are interested in exporting products to China.

Certrip suggests any manufacturers or importers to take following actions immediately in order to meet China RoHS requirements.

1. Carefully study if your products are in the scope of China RoHS, especially for products which are not covered by EU RoHS. Although the expansion of product scope of both legislation leads to more overlapping, there still exist some non-overlapping areas. For example, batteries and other components or materials are DIRECTLY regulated by China RoHS, but not by EU RoHS.
2. For products falling into the scope of China RoHS, measures in phase I mainly concern meeting the standard of SJ/T 11364 by affixing China RoHS mark and providing associated ‘hazardous substances table’ (if necessary) required .
3. As far as phase II is concerned, efforts shall be taken to firstly identify whether products in concern fall under ‘The Standard Achieving Management Catalogue’.  If yes, ‘voluntary certification’ or ‘self-declaration’ shall be completed per ‘Implementation Arrangements’ to demonstrate the compliance with standard of GB/T 26572 (See ‘FLOWCHART’ tab). In this phase, foreign applicants may often find themselves stuck in a difficult situation. For example, Chinese version of ‘declaration of conformance’ and supporting technical documents shall be uploaded to ‘public service platform’ by ‘providers’. And ‘providers’ herein refer to producers (trademark holder) or ‘authorized representatives’ registered in China.

Certrip can be your reliable ‘authorized representative’ in China. Thus, you will be completely released from the burdensome communication job with China authorities and have a specialist working on your behalf in China to actively manage the whole process. Furthermore, a life-cycle service is available on request to have you completely covered including possible surveillance afterwards.

In response to the requirement of ‘Implementation Arrangements’ in Phase II, Certrip came up with an implementation flowchart to clearly guide you the basic steps to comply with China RoHS. Please do not hesitate to contact us for any questions or specific request.