More on the China RoHS Catalogue

The Chinese Government has published the first draft catalogue of Electronic Information Products that will be subject to China RoHS substance restrictions. This draft, published on the 9th October 2009, is for consultation which ends on the 9th November 2009. The restrictions will come into force ten months after adoption of this legislation, unless changes are made.

Scope: The scope is limited to telephones and all types of printers that attach to a computer. All types of phones are covered including mobiles, landline telephones and networked handsets.

Substances: The restricted substances are the "RoHS 6" covered by EU RoHS - lead, cadmium, mercury, hexavalent chromium, PBB and PBDE (excluding deca-BDE according to SJ/T 11363-2006).

Concentration limits: The maximum concentrations are specified by Chinese standard SJ/T 11363-2006. The limits are essentially the same as EU RoHS (0.1% in homogeneous materials except cadmium which is 0.01%) but these limits are also applicable to coatings (including multiple layers as one material) and for very small components (<4mm3 being regarded as one material).

Exemptions: A list of exemptions is provided for each of the three product categories in the catalogue. There are ten of the EU RoHS exemptions that would be permitted for mobile handsets, the same ten for "telephones" and twelve permitted for computer printers (the same ten as for telephones plus one allowing "mercury in straight fluorescent lamps for special purposes" and one for lead in flat fluorescent lamps for LCDs).

Testing: The catalogue refers to SJ/T 11363-2006 which is the maximum concentration limit standard and this standard in turn refers to SJ/T11365-2006 for test methods for RoHS analysis so these methods will need to be used to determine whether products comply.

Entry into force: These obligations will enter force ten months after the legislation is adopted by the Chinese Government. This is not a long period of time as manufacturers and importers will have to have their products tested and certified by approved Chinese test labs before these can be sold in China. There will be insufficient time to modify product designs to comply and so clearly it has been assumed that telephones and printers made by Chinese manufacturers will already meet these substance restriction obligations.

Acknowledgements
Our thanks to ERA Technology Ltd trading as Cobham Technical Services.

Translated from the original Chinese version via Google Translator

Electronics Weekly, a sister publication of EM Asia