China RoHS

In February 2006, China Ministry of Information Industry (MII) officially published Order No.39: Administrative Measures on the Control of Pollution from Electronic Information Products (EIP), i.e. China RoHS. Ten years later, the second version of China RoHS, ‘Administrative Measures for Restriction of Use of Hazardous Substances in Electrical and Electronic Products’ was published. Similar to EU RoHS, China RoHS regulates the concentration of certain hazardous substances contained in electrical and electronic products. But one distinction of China RoHS is its two-phase management manner.

  1. Phase I characterised with its requirements of labeling and information disclosure, which took effect on March 1, 2007. In this phase, one of two different types of labels shall be affixed to show whether products contain any hazardous substances over concentration threshold. In another word, in this phase, China RoHS does not restrict the application of hazardous substances as long as appropriate label and information have been provided. As shown in above figure, the green symbol represents the concentration of any hazardous substances does not exceed the limits, while the orange one symbolises that the product contains certain hazardous substances over the limits.
  2. In phase II, products falling under ‘The Standard Achieving Management Catalogue ’ shall be prohibited from containing certain hazardous substances over the limits if put into China’s market after Nov. 1, 2019, apart from the requirements of labeling and information disclosure regulated in phase I. Accordingly, products in ‘The Standard Achieving Management Catalogue’ are subject to certain conformity assessment route to demonstrate their compliance. So far the catalogue consists of 12 product categories, including refrigerators, air conditioners, washing machines, water heaters, printers, copiers, fax machines, TV sets, monitors, microcomputers, cell phones, telephones.

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.

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