May 30,
2007
China
RoHS Differs from EU RoHS
So,
what’s the difference between China RoHS and the European Union’s (EU) RoHS?
More to the point – are you covered for China RoHS if you are able to comply
with the EU directive? Unfortunately, the answer is blurry. If your products
and components are compliant with EU RoHS, you might be covered for China’s
version – but that’s a fuzzy “might.” One thing for certain – you’ll have to
jump though new hoops to meet the rules of the China legislation.
The
first phase of China RoHS went into effect last March – that’s the labeling
phase where the six hazardous substances have to be spelled out. It’s a mystery
when the next phase goes into practice. That phase will include product testing
at Chinese labs. Yet even in the first phase of China RoHS, companies are still
struggling with the requirements of the law. “For companies already familiar
with EU RoHS, China RoHS is quite different,” says Michael Kirschner, president
of Design Chain Associates, a San Francisco firm that helps companies with
environmental compliance. “They both focus on the same six substances, but
that’s the only point where they’re the same.”
For
one, China RoHS focuses on different products than EU RoHS. So far, the China
law doesn’t include the full range of products that the EU directive
identifies. “In terms of products, China RoHS is more targeted to electronic
information products, where the EU RoHS also includes other product
categories,” says Emily Wang, marketing manager at Pacific Oaks Technology Inc.
in South Pasadena, Calif., a firm that helps companies comply with
environmental regulations. The EU RoHS law goes much further than China RoHS in
identifying products that are subject to restrictions. Even toys are included
in the EU directive.
Exemptions
are another point of difference between the China and EU rules. The EU
directive clearly spells out exemptions, including whole industries such as
aerospace, defense and medical devices. China has not yet revealed any
exceptions. “Exemptions are a major distinction. For EU RoHS, the exemptions
were detailed,” says Wang. “That’s not the case right now with China. We don’t
know yet what exemptions China will have.” China has promised to produce a
catalog of exemptions, but no date has been set for the catalog’s release.
Kirschner
doesn’t think China is in a hurry to release the catalog and move to the
testing phase of the law. “They have not set a date for restrictions, nor have
they come out with a catalog that shows what will be restricted, so I don’t think
phase two is a priority,” says Kirschner. He notes that China is busy now
trying to educate the Chinese electronics industry that the law exists.
When
phase two goes into enforcement, China plans to do actual testing of all
electronic information products aimed at China’s domestic market. “When phase
two kicks in, you better make sure your product is compliant because a Chinese
laboratory will test the product,” says Wang.
As
a companion to the labeling requirement that is now in affect, companies have
to analyze the presence of the six substances and disclose them in a table.
“The disclosure law is not a restriction law. You just have to disclose whether
your product contains any of the six substances,” says Kirschner. “You have to
go through an analysis and produce a table of the substances and disclose where
they are (in the product).”
Another
part of phase one that is different from EU RoHS is the declared environmental
use period. Manufacturers have to determine at what date the product has reached
the end of its useful life. While the date is viewed as a time when some of the
six hazardous materials might start leaking from the product, in actuality, the
date corresponds more with an estimate of when the product will not longer be
used. “They have six methods for determining the environmental use date, none
of which are scientifically sound,” says Kirschner. “The date is based more or
less on when you expect to throw the product away.”
At
the Design Chain Associates website (designchainassociates.com), you can view
an English translation of China RoHS and page through frequently asked
questions about the regulation.
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