China ROHS Issues New Mandatory Restrictions on Hazardous Substances

The Ministry of Industry and Information Technology of the People’s Republic of China recently released a new catalog of mandatory restrictions on hazardous substances (RoHS 2 2018). The move comes amid China’s push to reduce environmental pollution both domestically and abroad. China RoHS (also known as Administrative Measure on the Control of Pollution Caused by Electronic Information Products) is a set of Chinese regulatory guidelines that regulate legal thresholds of lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyls (PBBs), and polybrominated diphenyl ethers (PBDEs) in electrical and electronic products. 

What’s new in RoHS 2018

Companies who wish to manufacture, import, or distribute their products in China will need to comply with the new regulations proposed in the recently published RoHS Catalog Notice No. 15 of 2018. These restrictions are the first of their kind to pass in China for stand-alone products, and will undoubtedly expand as the country continues to implement policies to cut down on environmental pollution. As outlined in the RoHS catalog notice, the mandatory restrictions will begin on March 15, 2019.

In the five-page document, which was circulated at the World Trade Organization (WTO) in accordance with Article 10.6, the Ministry of Industry and Information Technology of the People’s Republic of China lists the following as stand-alone products covered under the new RoHS catalog: 

  • refrigerators 
  • air conditioners 
  • washing machines
  • electric water heaters
  • printers, copiers
  • ax machines
  • TVs
  • monitors
  • micro-computers
  • handheld phones for mobile communication
  • telephone sets

For corporations who do business in Europe, the new catalog should pose few problems. The products listed in the new catalog are the same as those listed in Europe’s RoHS rules, and the restrictions are the same. Even so, companies will need to ensure that they are compliant with the new regulations, else face civil and financial penalties such as fines and restrictions on a company’s ability to do future business in China. 

Current China RoHS Marking Requirements

All electronic and electrical products sold in the People’s Republic of China must be marked with one of the two logos mandated by China RoHS. Which logo must be used depends on whether an individual product contains any hazardous substances in excess of the China RoHS concentration limits.

China ROHS marking requirements

  • A green symbol with “e” signifies the product does not contain hazardous substances in excess of China RoHS 2 concentration limits;
  • An orange symbol with an associated number signifies the product contains hazardous substances and can be used safely during a pre-established environmental protection use period. Such products should be recycled after the use period, as indicated by the number displayed (in years).

Changes to China RoHS 2 Marking Requirements

The China RoHS Catalog Notice No. 15 of 2018 explicitly bans any products that exceed the maximum concentration values of a particular hazardous substance. Any product that currently exceeds the maximum concentration values of a specific substance will be barred from the Chinese market beginning in March 2019. This includes products presently placed on the market that comply with the previous China RoHS requirements for hazardous substances. 

Need help understanding the new rules?

China RoHS 2 new catalog means companies will need to analyze their supply chains to ensure the specifications and composition of their products meets the new mandatory regulatory requirements. Need to more information? Contact Us.

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