Presented by:Bruce CalderVP of Consulting Services

New China RoHS RegulationOverview and explanation

Overview - Agenda• New China RoHS Law

• Overview

• Structure

• Products for export

• China RoHS Standards

• New standard

• Hierarchy

• Scope

• Labels & Tables

• Placement

• Structure

• Options

• Examples

• Summary

Webinar is 50 minutes with 10 minutes of Q&A

(hopefully)

Claigan Overview

• Principal Services- Consulting

- Laboratory testing

- Data gathering

• Experience- Wide range of professional, medical, industrial,

and consumer companies

RoHS, REACH SVHC, REACH Registration, Conflict Minerals, Batteries, Packaging, Persistent Organic Pollutants, Proposition 65, California Transparency in Supply Chains, UK Modern Slavery, and more….

Claigan - Update Services• Monthly or Quarterly

Updates - Custom webinar

- On the changes in requirements

- Impacts to your specific products

- Monthly or Quarterly

- Interactive

Monthly (or Quarterly) Updates• Webinar for just your company

• and interactive

• Based on changes in restricted materials compliance requirements

- Legislative

- Enforcement

• Optional- Recording of web meeting

New China RoHS Law Published• On January 6, the New China RoHS law was published

- “Electrical and electronic products Restriction of Hazardous Substances Management Measures”

- Goes into effect 1 July 2016

• Highlights- New definition of EEE (same as EU RoHS)

- EU RoHS scope of products

- Table and labelling- To the new China RoHS standard (SJ/T 11364-2014)

- Not restrictions (yet)

- Conformity assessment replacing in country testing

General Comment on China RoHS• We are going to discuss a Chinese law

- Based on an English translation of a Chinese attempt to better align with a translation of EU RoHS, and

- In which the practical details are included in industry standards, and

- Is intended to have a government FAQ later this year.

• So- Don’t jump to any final conclusions regarding the text

China RoHS

China RoHS Law(Electrical and electronic products

Restriction of Hazardous Substances Management Measures)

SJ/T 11364-2014Product Labelling Standard(Marking for the restriction of hazardous

substances in electrical and electronic products)

Mandatorylabelling of content and recyclability

Packaging marking if mandatory standard exists

GB/T 18455-2010Package recycling marking

Standard only ‘recommended’

Restriction of substances if catalog exists

No catalogs at this time

Restriction CatalogsProducts and Exemptions

China RoHS - Scope• Electronic and Electrical Products (EEP)

- Devices and accessory products with rated working electrical voltages that do not exceed 1500V direct current and do not exceed 1000V alternating current and function by means of current or electromagnetic fields and generate, transmit and measure such currents and electromagnetic fields.

• Very similar to EU RoHS

• Components likely no longer directly in scope• We will see in the FAQ

Products for Exports from China

• Common industry panic- Exclusion for products for export removed

- and

• Scope wording-

- Article 2 - These Methods are applicable to the production, sale, and import of electrical and electronic products within the territory of China.

Scope• Do you remember the confusion around

- (b) "producer" means any person who -- (i) manufactures and sells electrical and electronic equipment under his own brand;

- (ii) resells under his own brand equipment produced by other suppliers, a reseller not being regarded as the "producer" if the brand of the producer appears on the equipment, as provided for in subpoint (i); or

- (iii) imports or exports electrical and electronic equipment on a professional basis into a Member State.

• It looks like we are looking at an English translation of a Chinese government attempt to paraphrase the confusing definition of a producer from the original EU RoHS into Chinese law- PS - China is not about to risk their electronics exports industry

- More details expected in the eventual government FAQ

Producer Definition - Re-visiting• New China Regulation

- Article 2 - These Methods are applicable to the production, sale, and import of electrical and electronic products within the territory of China.

• Old RoHS Directive- (b) "producer" means any person who -

- (i) manufactures and sells electrical and electronic equipment under his own brand;

- (ii) resells under his own brand equipment produced by other suppliers, a reseller not being regarded as the "producer" if the brand of the producer appears on the equipment, as provided for in subpoint (i); or

- (iii) imports or exports electrical and electronic equipment on a professional basis into a Member State.

New China RoHS Standard• In late 2014, China RoHS standard was updated

- SJ/T 11364-2014

-

- from SJ/T 11364-2006

• Standard into force- 1 January 2015

- But held in abeyance until new law was published in 2016

• Major changes- Scope change

- Removal of mandatory recycling marking

- Further specifics on table and label

Notes on Chinese Standards• GB

- “Guobiao" standards

- National standards

• SJ- Professional standard for electronics

• /T- tuījiàn, "recommended"

- Ansi

China RoHS - Substance Thresholds• Substance threshold are identical to the EU RoHS

Directive 2011/65/EU- Only difference is there are no exemptions

- Not a restriction

- Declaration only

• Restricted substance thresholds (GB/T 26572)- Pb 1000 ppm

- Hg 1000 ppm

- Cd 100 ppm

- CrVI+ 1000 ppm

- PBB 1000 ppm

- PBDE 1000 ppm

• How do you communicate if your product has a restricted substance above the threshold?

• All EEP that are sold in China shall be marked with China RoHS logos

- The ‘E’ inside the circular chasing arrow indicates a product does not contain any restricted substances above the threshold. This logo is usually green.

- A logo with a number inside the circular chasing arrows indicates that there is a restricted substance present above the prescribed threshold. This logo is usually orange.

- When these logos are used, the product is not intended for the regular waste stream

New China RoHS Standard - Logos

China RoHS - Logos• The number inside the logo is the Environmental Friendly Use Period (EFUP)

• EFUP (Environmental Friendly Use Period) is the expected safe use life span (in years) of the product where the substance will not leak out and cause human or environmental harm

• The EFUP may be displayed in years ranging from 1-5 and then from 5 to 50 in five year increments

• The size of the logos must not be less than 5mm x 5mm

• The ratio of the font inside to the inner and outer circle is 5:8:12

• The product must also have

• Date of manufacture

Date of Manufacture• The date of manufacture is the starting point for the EFUP period

• Format• Year, or

• Year / month, or

• Year / month / day, or

• Year / week, or

• as part of a serial code that include date information

• Location• Same location requirements as EFUP number

China RoHS - Logos• Location of logo has been elaborated on

- Ideally on the front of the product or another recognizable location

- The mark may be moulded, painted, printed or on a sticker

- Recommended colours of the logos are specified, but may appear how the manufacturer wishes (Orange and Green)

• If the product is an odd shape • Too small (less than 5mm x10mm2 ) • Unable to be marked due to surface or function - The markings may be placed in the:

• Manual

• Website

• steps must be provided in the manual to access the China RoHS info

• CD/DVD

• Packaging material

• Additional new option for digital display is available for products with screens

China RoHS - Digital Display option• Logo must appear for 2s if displayed upon boot up

• If displayed along with other info, - duration and size of the logo must be appropriate so the logo is

distinguishable

• May be viewed through the user interface- The table must be able to be viewed as well

- Instructions must be able to point the user to this information

• This information must be read only

• Manufacturer must retain the digital data for the product 3 years after its life span.

China RoHS - Hazardous Substance Table• Tables

- Must be included with the shipment either as a

• separate sheet, in the manual, website referenced by manual, or digitally available on the product

- Main attributes of hazardous substance table unchanged

- New standard to be referenced in table

- Some additional specifics on size and requirements

• The height of the Chinese characters and symbols used in the marking shall be clear and legible and not be smaller than 1.8 mm

- Only required if there is a declarable substance. Not required for ‘e’ products

• Simple Chinese required

China RoHS - Hazardous Substance Table

Standards

Optional Explanation of ‘X’s

“Hazardous Substances”“Part Names”

Table - Variations 2016 - Logitech

Table - Variations 2016 - TE

Table - Variations 2016 - MSI

Summary• Scope

- All products under scope of EU RoHS

- Text is confusing, but looks to apply to all in scope products placed on the market in China.

• Table- We need to update our table in test reports to the new standard

- Some allowance for customization

• Table and EFUP- More options on placement

• Packaging and restrictions- Packaging marking recommended only

- Material restrictions and exemptions in future catalogs

Claigan - Update Services• Monthly or Quarterly

Updates - Custom webinar

- On the changes in requirements

- Impacts to your specific products

- Monthly or Quarterly

- Interactive

Claigan Overview

• Principal Services- Consulting

- Laboratory testing

- Data gathering

• Experience- Wide range of professional, medical, industrial,

and consumer companies

Q&A

www.claigan.cominfo@claigan.com

RoHS, REACH SVHC, REACH Registration, Conflict Minerals, Batteries, Packaging, Persistent Organic Pollutants, Proposition 65, California Transparency in Supply Chains, UK Modern Slavery, and more….