“china rohs” development and tendency report · • saic state administration for industry and...

In-corporate with, 合作方

Orgalime - The European Engineering Industries Association, Brussels

ZVEI - German Electrical and Electronic Manufacturers’ Association, Frankfurt am Main

European Electrical and Electronics Industry

欧洲电气电子行业机构

“China RoHS” Development and Tendency Report

“China RoHS” Regulation - China Administration on the Control of Pollution

Caused by Electronic Information Products (ACPEIP)

EuropElectro “China RoHS” Work Group

Version: 14 January 2013

Change Records

Document Name Version Organization Author Reasons

EuropElectro China RoHS Work Group Telephone conference meeting Time: 10:30am 19th Dec 2007 20071219 EuropElectro Wang Xu first issue

“China RoHS” status summary report-EuropElectro China RoHS WG 20071227 EuropElectro Wang Xu

summary the regulation status/WG meeting on 19 Dec 2007 and 20 Dec 2007 visit CQC

“China RoHS” Development and Tendency Report 20091009 EuropElectro Wang Xu

MIIT solicited public comments on KEY CATALOUGE of RoHS CCC

“China RoHS” Development and Tendency Report 20101009 EuropElectro Wang Xu

MIIT solicited public comments on “China RoHS” revision

“China RoHS” Development and Tendency Report 20121204 EuropElectro

Wang Xu & Ma Lin

China Legislative Affairs Office solicited public comments on draft revision of “China RoHS” regulation on 4 June 2012

New

15/01/2013 China RoHS Development and Tendency Report | P 2

• AQSIQ General Administration of Quality Supervision, Inspection and Quarantine of P. R.C.

• CESI China Electric Standardization Institute

• CNCA Certification Accreditation Administration of P.R.C.

• CQC China Quality Center

• GAC General Administration of Custom

• MEP Ministry of Environment Protection of P.R.C.

• MIIT Ministry of Industry &Information Technology of P.R.C.

• MOF Ministry of Finance of P.R.C.

• MOFCOM Ministry of Commerce of P.R.C.

• MOST Ministry of Science and Technology of P.R.C.

• NDRC National Development and Reform Commission

• SAC Standardization Administration of P.R.C.

• SAIC State Administration for Industry and Commerce of P.R.C.

• Local CIQ Entry-Exit Inspection and Quarantine Bureau • Local QTS Quality and Technical Supervision Bureau

Abbreviation


EuropElectro China RoHS Work Group Target

The work group shall concentrate on common interests of the member companies.

The work group’s target is to promote the self-declaration of conformity and find out

“how can industry to compliance with ‘China RoHS’” from manufacturer.

Our Work Group Tasks (Updated per meeting on 15 August 2012)

1. Track and influence transparency of the “China RoHS” compliance process - e.g. “China RoHS” CCC process; key management catalogue - and organize members to be earlier aware of the risk;

2. Lobby MIIT regulators in an earlier phase to accept the “exclusion” and “exemption” scopes allowed in EU RoHS Directive in China RoHS;

3. Determine that China RoHS is accordant with EU RoHS directive;

4. Continue to conclude our industry position in legislation process;

5. Promote the self-declaration of conformity in “China RoHS”;

6. Comparison report between the EU RoHS2 directive and the “China RoHS” Regulation.


Report Structure


1. “China RoHS” Implementation Diagram – Overview

2. Highlights – What’s NEW (valid from end of October 2010 to December 2012)

3. Legislative Purpose

4. Scope

5. Economic Operators’ Obligations

6. Compliance with “China RoHS” Regulation – Conformity Assessment,

Standard, Label

7. Market Surveillance

8. Regulators’ Actions to Promote “China RoHS”

9. “China RoHS”-related Materials


1st phase: Information Disclosure duty

2nd Phase : Compliance duty

In current valid version: CCC is the conformity assessment requirement. (not start yet)

In latest draft revision version: the conformity assessment system for “China RoHS” will be established. (still under discussion)

“China RoHS” Implementation Overview Diagram

In general, there are 2 phases to implement China RoHS, (status by

December 2012)

28 Feb 2006 1 Mar 2007 Estimated on ??/??/??

Product Scope:

<Classification of EIP> 10

Category product

“China RoHS” Regulation - China Administration on the Control of Pollution Caused by Electronic

Information Products(ACPEIP) was published

Report Structrue


1. “China RoHS” Implementation Diagram – Overview 2. Highlights – What’s NEW (valid from end of October 2010 to December 2012)

3. Legislative Purpose 4. Scope



Standard, Label




Highlights: What’s NEW (valid from end of October 2010 to December 2012)

- Index

1. “China RoHS” development schedule

2. Revision of “China RoHS” regulation

3. Product scope for information disclosure duty

4. Key management catalogue for compliance duty

5. Conformity assessment model

6. EuropElectro’s actions


2009

2010

2011

2012

“The draft 1st Batch Key Management Catalogue for Electronic Information Products Pollution Control “ issued for public comments

“SJ/Z 11388-2009: General guidelines of environment-friendly use period of electronic information products” and lead-free solder industrial standards issued

Implementation Opinion on State-promoted China RoHS Voluntary Certification

MIIT called for public comments on Revision of “China RoHS” Regulation (2010 draft version) via WTO/TBT

The implementation rule, product scope and exemption of State-promoted China RoHS Voluntary certification issued

The Legislative Affairs Office of China called for public comments on Revision of “China RoHS” Regulation (2012 draft version)

Certification body list and test laboratory list for State-promoted China RoHS Voluntary certification issued. The China voluntary certification officially started

MIIT called for public comments on draft “Normative Document on Enterprise’s Declaration of Conformity on the Pollution Control of Electrical and Electronic Products” from 24 July to 22 August


- “China RoHS” development schedule - 1

New

New

CNCA & MIIT jointly China RoHS expert WG established


2003

2004

2005

2006

2007

The former MII started to draft “China RoHS” Regulation

MIIT “China RoHS” standards WG established

“China RoHS” implementing standards: “SJ/T11364—2006 Marking for control of pollution caused by electronic information products”, “SJ/T 11363—2006 Requirements for concentration limits for certain hazardous substances in electronic information products”, “SJ/T 11365-2006 Testing methods for hazardous substances in electronic information products” drafted


- “China RoHS” development schedule - 2

“China RoHS” Regulation (2006 version) published

“China RoHS” implementing standards: “SJ/T11364—2006 Marking for control of pollution caused by electronic information products”, “SJ/T 11363—2006 Requirements for concentration limits for certain hazardous substances in electronic information products”, “SJ/T 11365-2006 Testing methods for hazardous substances in electronic information products” published

“China RoHS” Regulation (2006 version) implemented

CESI, CQC RoHS voluntary certification launched


2008 “The Establishment Procedure of Key Management Catalogue for Electronic Information Products Pollution Control” issued


- Revision of “China RoHS” regulation - 1

Regulators’ Actions:

● MIIT called for public comments on Revision of “China RoHS” Regulation (2010 draft version) via WTO/TBT on 21 October 2010.

● The Legislative Affairs Office of China called for public comments on Revision of “China RoHS” Regulation (2012 draft version) on 4 June 2012.

New

Status: NOT published yet by December 2012


New in the recent 2012 draft version VS 2010 draft version (the following Articles are referred to the ones in the 2012 draft version)

● China RoHS Information Label Specifications (Article 13, 14, 15)

● Conformity Assessment (Article 21)

● Clear the Requirements in the Penalty Provisions ( Article 25)

New



- Revision of “China RoHS” regulation - 2

Electrical & Electronics Product equipment and auxiliary products dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields, and equipment designed for use with a voltage rating not exceeding 1 000 Volt for alternating current and 1 500 Volt for direct current.


- Product scope for information disclosure duty

Electronic Information Product products produced with electronic information technologies, including electronic radar products, electronic communication products, radio and television products, computer products, home electronic products, electronic measurement devices products, special electronic products, electronic element and component products, electronic application products, electronic material products, etc., as well as the parts and components thereof.

New

Current valid version (2006 version)

Latest draft version (2012 draft version)

What is the Difference between the two versions? The product scope is enlarged to all equipment and auxiliary products with a voltage rating not exceeding 1 000 Volt for alternating current and 1 500 Volt for direct current.


vs

Regulator’s Action:

● On 9 October 2009, MIIT issued the draft 1st batch of “key management catalogue of China RoHS” for public comments by 9 November 2009.

It consists of mobile phone, telephone and printer.

BUT, it has not been officially published yet.


- Key management catalogue for compliance duty

Status: NOT published yet by December 2012



- Conformity assessment model

information disclosure duty compliance duty

current valid version (2006 version)

latest draft version (2012 draft version)


to disclose the “China RoHS” info. No conformity assessment requirements

“China RoHS CCC”, NOT start yet

NO Change, same as previous version

The “China RoHS” conformity assessment requirements not clear the conformity assessment system for “China RoHS” will be established. Referred to “Article 21” of 2012 draft version

New vs

The 1st phase

The 2nd phase

“China RoHS” Regulation

What is the Difference between the two versions? In the 2nd phase of compliance duty , the conformity assessment system for “China RoHS” will be established according to ‘article 21’ in the 2012 draft version.



- EuropEelctro’s actions - 1

• Communication with Regulators:

- EuropElectro invited and accompanied MIIT delegation to visit European commission, EU association and industry to study EU RoHS in October 2010.

- EuropElectro delivered speeches on 2011 MIIT China RoHS WG meeting in Xi'an in May 2011. for more…

- EuropElectro facilitated CNCA and MIIT RoHS delegation to visit Orgalime and the European Commission on 15 - 16 November. for more…

• Position Paper: - EE-2010002 EuropElectro Industry Position Paper - EuropElectro’s Position Paper on the

“Measures for Administration of Pollution Control of Electronic Electrical Products (Exposure Draft)”(CN+EN) - download

- EE-2012001-EuropElectro’s Position Paper on the Revision of China RoHS 2012-06-04 Exposure Draft Version (CN+EN) - download

- EE-2012002-EuropElectro Position Paper on “Normative Document on Enterprise’ Declaration of Conformity on the Pollution Control of Electrical and Electronic Products 2012-07-24 exposure draft version (CN+EN) – download

• Information: - Report “China RoHS” development information in EuropElectro Newsletter - download

newsletter

• EuropElectro WG: - EuropElectro China RoHS WG is keeping active.

http://www.europelectro.org/news-events/detail/article/2011-miit-china-rohs-working-group-meeting-in-xian/

http://www.europelectro.org/news-events/detail/article/europelectro-facilitates-cnca-and-miit-rohs-delegation-to-visit-orgalime-and-the-european-commission/

http://www.europelectro.org/library/



http://www.europelectro.org/news-events/

http://www.europelectro.org/news-events/



- EuropEelctro’s actions - 2

• Memberships of TC/WG: EuropElectro is active as member of the following TC/WG - MIIT “China RoHS” WG - MIIT&CNCA joint “China RoHS” voluntary certification expert WG - IEC/TC 111 and its China mirror TC – SAC/TC 297

• Seminar/Conference/Telephone Conference: - EuropElectro China RoHS WG’s Tele-conference to review WG task list on 4 August 2011 - EuropElectro China RoHS WG’s Tele-conference to discuss the positions on “China RoHS”

regulation (2012 draft version) on 14 June 2012 - EuropElectro China RoHS WG’s Tele-conference to discuss the positions on “Normative

Document on Enterprise’ Declaration of Conformity on the Pollution Control of Electrical and Electronic Products” on 15 August 2012

• Status Report: - “China RoHS” Development and Tendency Report – updated in January 2013

• Others: - CN-EN Vocabulary List of Frequently Used RoHS-Related Words – summarized by

EuropElectro & MIIT “China RoHS” WG - download For all the details about our “China RoHS” activities, please visit http://www.europelectro.org/working-groups/wg-china-rohs/


http://www.europelectro.org/working-groups/wg-china-rohs/







Report Structrue





4. Scope



Standard, Label




Legislative Purpose

For the purposes:

• controlling and reducing the pollution caused by the wasted products to the environment

• promoting the production and sale of low-pollution electrical & electronics products

• protecting the environment and human health


Report Structrue





4. Scope



Standard, Label




Electrical & Electronics Product equipment and auxiliary products dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields, and equipment designed for use with a voltage rating not exceeding 1 000 Volt for alternating current and 1 500 Volt for direct current.


- Product scope for information disclosure duty

Electronic Information Product products produced with electronic information technologies, including electronic radar products, electronic communication products, radio and television products, computer products, home electronic products, electronic measurement devices products, special electronic products, electronic element and component products, electronic application products, electronic material products, etc., as well as the parts and components thereof.

New



What is the Difference between the two versions? The product scope is enlarged to all equipment and auxiliary products with a voltage rating not exceeding 1 000 Volt for alternating current and 1 500 Volt for direct current.


vs

Scope -Exemption


product scope for information disclosure duty

key management catalogue for compliance duty




No exemption

Exemption indicated in the draft 1st batch of the key management catalogue



vs

The 1st phase

The 2nd phase

‘China RoHS’ Regulations

What is the Difference between the two versions? There is no differences between the two versions.


Scope -Exclusion

product scope for information disclosure duty

key management catalogue for compliance duty



No exclusion

No exclusion



vs

The 1st phase

The 2nd phase

‘China RoHS’ Regulations


Scope - Restricted hazardous substances -1

The term "toxic or noxious substances or elements" shall refer to the following substances or elements contained in electronic information products: a. lead; b. hydrargyrum; c. cadmium; d. HexChrome; e. PBB; f. PBDE; g. other toxic or noxious substances or elements prescribed by the state.



Scope - Restricted hazardous substances -2

Substance: Max. concentration value (%) in the homogeneous material: (Note: According to content from GB/T 26572-2011, not regulated in the regulation)

Substance Concentration Limits (wt%)

Cadmium (Cd) 0,01%

Lead (Pb) 0,1%

Mercury (Hg) 0,1%

Chrome VI (Cr VI) 0,1%

Polybrominated biphenyls (PBB) 0,1%

Polybrominated diphenyl ethers (PBDE) 0,1%


Report Structrue





4. Scope



Standard, Label




Economic Operators’ Obligations

Economic Operators Regulators


Manufacturer Importer Distributor

MIIT NDRC MEP MOFCOM GAC SAIC AQSIQ


Manufacturer Importer Distributor

MIIT NDRC MEP MOF MOFCOM MOST GAC SAIC AQSIQ

New

New


Report Structrue





4. Scope



Standard, Label




Compliance with “China RoHS” Regulation - Conformity assessment

Standard Regulation Constitution

Conformity

Assessment

Key points in Current valid version (2006 version)

Regulator: MIIT + 6 ministries Regulation: “China RoHS” Regulation

Standard body: • IEC/TC 111 China

mirror TC: SAC/TC

297 (GB)

• MIIT (JB)

• AQSIQ (SN)

• Not yet • 1st phase: Information

disclosure • 2nd phase: China RoHS

CCC

• AQSIQ • SAIC • Local CIQ • Local QTS

Key points in Latest draft version (2012 draft version)

Regulator: MIIT + 8 ministries Regulation: “China RoHS” Regulation

Standard body: • IEC/TC 111 China

mirror TC: SAC/TC

297 (GB)

• MIIT (JB)

• AQSIQ (SN)

• Not yet • 1st phase: Information

disclosure • 2nd phase: under

construction.

• AQSIQ • SAIC • Local CIQ • Local QTS

Market access

Market Surveillance


Catalogue: Key management catalogue

MIIT issued the draft 1st batch of “key management catalogue of RoHS (draft)” for public comments

by 9 November 2009. It consists of mobile phone, telephone and printer. BUT, it has not been

officially published.

Compliance with “China RoHS” Regulation - “China RoHS” CCC

Not Start yet!


Compliance with “China RoHS” Regulation - RoHS standardization activity in China

SAC

MIIT AQSIQ

Electric industry standard work Group for China RoHS (secretariat: CESI) SJ standard

Inspection and quarantine industry standards (for RoHS)

SN standard

IEC/TC 111 Environmental standardization for electrical and electronic product and systems

Material declaration for electrical and electronic equipment

WG 1

Material declaration for electrical and electronic Equipment

design for electrical and electronic products and systems

Test methods for hazardous substances equipment

China Mirror IEC TC 111 Environmental standardization for electrical and electronic prod ucts and systems

China mirror IEC/TC 111 (SAC/TC297) Environmental standardization for electrical and electronic products and systems

SC1 (secretariat: CQC)

Material declaration for electrical and electronic equipment

SC 2

systems

SC 2 (secretariat: CEEIA)

Environmentally conscious Design for electrical and electronic equipments and systems

SC 3 (secretariat: CESI)


WG 3


WG 4

GHG

SC 4 (secretariat : CQC)

Environment/Recycle and reuse of electrical and electronic products and systems

SC 5 (secretariat: CNIS)

Environment assessment of electrical and electronic products and systems


“China RoHS” Standards List (updated in December of 2012) - GB (National Standards) - Part 1

Standard No. Standard Name Valid Date

GB/T 24050-2004 Environmental management--Vocabulary 1-Oct-04

GB/T 20861-2007 Terminology of waste product recovery 1-Sep-07

GB/T 23686-2009 Environmentally conscious design guide for electrical and electronic products 1-Dec-09

GB/T 21273-2007

Environmentally conscious design - Integrating environmental aspects into

design and development of electro technical products (IEC Guide114:2005 )

1-Jun-08

GB/T 26669-2011 Environmentally conscious design for electrical and electronic products -

Glossary 1-Dec-11

GB/T 26671-2011 Guide for environmentally conscious design assessment of electrical and

electronic products 1-Dec-11

GB/T 28179-2011 Environmentally concious design for electrical and electronic product -

Indentification of environmental aspects 1-Jun-12

GB/T 26572-2011 Requirements of concentration limits for certain restricted substances in

electrical and electronic products 1-Aug-11

GB/T 23690-2009 Procedure for the declaration of materials in products of the electro technical

and electronic industry 1-Dec-09


Standard No. Standard Name Valid

Date

GB/Z 26668-2011 Material declaration of electronic and electrical products (IEC 62474

CDV:2010) 1-Dec-11

GB/T23685-2009 General technical specifications of recovering for waste electrical and

electronic equipment 1-Dec-09

GB/Z 20288-2006 General disassembly requirements for testing hazardous substances in

electrical and electronic products 12-Jan-06

GB/T 26125-2011

Electrical and electronic products - Determination of six regulated

substances (lead, mercury, cadmium, hexavalent chromium, polybrominated

biphenyls, polybrominated diphenyl ethers) (IEC 62321:2008)

1-Aug-11

GB/Z 21274-2007 Determination of regulated substances (Lead, Mercury and Cadmium) in

electrical and electronic equipment 1-Jun-08

GB/Z 21275-2007 Determination of regulated substance (hexavalent Chromium) in electrical

and electronic equipment 1-Jun-08

GB/Z21276-2007 Determination of restricted substances - Polybrominated biphenyls and

polybrominated diphenyl ethers in electrical and electronic equipment 1-Jun-08

GB/Z21277-2007 Rapid screening of lead, mercury, chromium, cadmium and bromine of

regulated substances in electrical and electronic equipment-X-ray

fluorescence spectrometry

1-Jun-08

“China RoHS” Standards List (updated in December of 2012) - GB (National Standards) - Part 2


Standard No. Standard Name Valid Date

SJ/T 11364-2006 Marking for control of pollution caused by electronic information

products 6-Nov-06

SJ/Z 11388-2009 General rule for environmental protection use term of electronic

information products 1-Jan-10

SJ/T 11389-2009 Lead-free flux for solder 1-Jan-10

SJ/T 11390-2009 Test method for lead-free solder 1-Jan-10

SJ/T 11186-2009 General specification for soldering pasts 1-Jan-10

SJ/T 11391-2009 Tin alloy powder used for the solder of the electronic products 1-Jan-10

SJ/T 11392-2009 Chemical composition and morphology of Lead-free solder 1-Jan-10

Revision of SJ/T 11364-2006 Marking for control of pollution caused by electrical and electronic

products (Draft) xx-xx-20xx

“China RoHS’ Standards List (updated in December of 2012) - Industrial Standards


Compliance with “China RoHS” Regulation

- Label


Disclosure duty Compliance duty


Not clear


Not clear

Not clear

Totally RoHS free

+ Hazardous substance

content table

More than MCV

Report Structrue





4. Scope



Standard, Label




Market Surveillance

AQSIQ and SAIC take their own responsibilities for the market surveillance as their usual duties.


Report Structrue





4. Scope



Standard, Label




1) IS VOLUNTARY! for this Voluntary certification, there are • No custom control • No market surveillance in domestic market 2) The risk of this certification to be referred in requirements of China government procurement

or other incentive policy is still high.

Regulators’ Actions to Promote “China RoHS” - State-promoted China RoHS Voluntary Certification

Start from July 2012!


Regulators’ Actions to Promote “China RoHS” - Manufacturer’s Declaration of Conformity (Under discussion)

Not Start yet!

MIIT solicited public comments on draft “Normative Document on Enterprises’ Declaration of Conformity on the Pollution Control of Electrical and Electronic Products (2012-07-24 exposure draft version)” from 24 July – 22 August. Executive Summary: ● MIIT is in its consideration of adopting the “manufacturer self-declaration of conformity” in

the “China RoHS”. ● It is not a real “manufacturer self-declaration of conformity” model of regulation. ● EuropElectro is supportive of the technical standards, which are referred to in the declaration

of conformity in the China RoHS Regulation, being identical with relevant IEC and EN standards adopted in the EU RoHS 2 directive.

For the detailed information, please refer to EuropElectro Position Paper on draft “Normative Document on Enterprises’ Declaration of Conformity on the Pollution Control of Electrical and Electronic Products (2012-07-24 exposure draft version)”


http://www.europelectro.org/position-papers/







Report Structrue





4. Scope



Standard, Label




“China RoHS”-related Materials

Law: • Law of the People's Republic of China on Promoting Clean Production - CN • Law of the People's Republic of China on the Prevention and Control of Environmental Pollution

by Solid Wastes - CN

Department Rule: • Measures for Pollution Control of Electronic & Electrical Products (2006 version) - EN CN • Draft Measures for Pollution Control of Electronic & Electrical Products (2010 draft version) - EN

CN • Draft Measures for Pollution Control of Electronic & Electrical Products (2012 draft version) - EN

CN

Supporting documents: Catalogue-related documents: • Catalogue for Pollution Control of Electronic & Information Products (referred in 2006 version) -

CN • Establishment Procedure for Key Management Catalogue for Electronic Information Products

Pollution Control - CN • Draft 1st Batch of Key Management Catalogue for Electronic Information Products Pollution

Control - EN CN


Supporting documents: State-promoted China RoHS Voluntary Certification-related documents: • Implementation Opinions on State-promoted China RoHS Voluntary Certification – CN • Implementation Rules on State-promoted China RoHS Voluntary Certification - EN CN • Product Scope & Exemption List of State-promoted China RoHS Voluntary Certification - EN CN • Test Laboratory of State-promoted China RoHS Voluntary Certification(First batch)- CN • Certification Body of State-promoted China RoHS Voluntary Certification(First batch)- CN Manufacturer’s Declaration of Conformity-related documents: • Draft Normative Document on Enterprise’ Declaration of Conformity on the Pollution Control of

Electrical and Electronic Products - EN CN

“Note: EN – EuropElectro unofficial translation CN – Official document Should you need the EuropElectro unofficial translation, please visit our website www.europelectro.org.“


http://www.europelectro.org/

Let’s discuss: How can industry compliance with “China RoHS”? 制造商须怎样符合中国的RoHS呢?

What can EuropElectro Do for You?


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“china rohs” development and tendency report · • saic state administration for industry and...

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