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Seconded European Standardization Expert in China Project (SESEC)

SESEC III

China Rohs II

Dr. Betty XU

SESEC III 03 November 2016


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Measures for the Limited Use of Hazardous Substances in Electrical & Electronic Products

SESEC Project Introduction

Introduction of Measure for the administration of the

restricted use of hazardous Substances Contained in

Electrical and Electronic products

MIIT document “FAQ for China Rohs II”

Standards in China Rohs II

Future development and observation

Dr. Betty XU, SESEC III

03 November 2016


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SESEC IIIWhat is it about ?

SESEC III is a project co-financed by the European

Commission (EC), the EFTA and the three European

Standardization Organisations CEN, CENELEC and

ETSI. It builds on two previous phases, SESEC I (2006-

2009) and SESEC II (2009-2012). The project is

managed by CEN, supported by a Steering Committee

involving all partners.

© CEN-CENELEC 2010 3Dr. Betty XU, SESEC III

03 November 2016


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The SESEC initiative supports EC policy and ESOsstrategic objectives in China. Its ultimate goal is theenhancement of EU-China dialogue andcooperation in the field of standardization.

It is notably expected to support the FrameworkCooperation Agreement in place between the ESOs andSAC

SESEC IIIWhat is it about ?


03 November 2016


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SESEC IIIWhat is the goal?

The SESEC initiative is concretely expected to:

Promote European and international standards in China

Improve contacts between Project Partners and different levels of the Chinese administration, industry and standardization bodies

Improve the visibility and understanding of the European Standardization System (ESS) in China

Gather regulatory and standardization intelligence

Undertake technical lobbying


03 November 2016


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SESEC IIIPrioritized areas

Internet of Things (IoT) & Machine-to-Machine (M2M) communication

communication networks & services

cybersecurity & digital identity

Smart Cities (including transport, power grids & metering)

electrical & electronic products

general product safety

medical devices

cosmetics

energy management & environmental protection (including eco-design & labelling, as well as environmental performance of buildings)

Seconded European Standardization Expert in China (SESEC)


03 November 2016


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Introduction of Measure for the administration of

the restricted use of hazardous Substances

Contained in Electrical and Electronic products





03 November 2016


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Management Methods for Restricted Use of Hazardous Substances in Electrical and Electronic Products (hereinafter referred to as “China Rohs II") were published on January 6, 2016 and was formally enforced on July 1, 2016.

Replace “Measures for the Control of Pollution from Electronic Information Products” (hereinafter referred to as “China Rohs I") , which was published by MIIT on February 28, 2006

Similar labelling and disclosure requirementsas China Rohs I, but now applied to a muchlarger scope of products

Introduction of China Rohs II


27 Sept 2016


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Signed by 8 ministries

MIIT (Ministry of Industry and Information Technology)

NDRC

MOST

MOFCOM

Ministry of Environment Protection

Ministry of Finance

General Administration of Customs

AQSIQ

Introduction of China Rohs II


27 Sept 2016


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Superior legislation of Measures for the

administration

1.Cleaner Production Promotion Law of the People’s

Republic of China

2.Law of the People's Republic of China on the

Prevention and Control of Environment Pollution

Caused by Solid Wastes

3.Regulation on the Administration of the Recovery

and Disposal of Waste Electrical and Electronic

Products


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Principal revised contents of

Measures for the administration

Name of the legislation

Measures for the Control of Pollution from Electronic

Information Products

Measures for the Administration of the Restricted Use of the Hazardous

Substances Contained in Electrical and Electronic Products

Application scope

of products

Electronic information products electrical and

electronic products

（both include related materials，components、parts/assembly, auxiliary and so on）

Selected products in the catalog need to fulfill the Requirements of concentration limits for certain restricted substances in electrical and

electronic products (GB/T 26572-‐2011)

Upgraded model：release in batches、timely adjustment

Conformity assessment

（certification） model

“Products included in the Major Control List are obligated to perform

certification and control management ”

Electric and electronic products included in the Catalog shall

fulfill “Conformity assessment models” regulated by the

government

Catalog of Products that Have

Met the Requirements for

Restricted Use of Hazardous

Substances in Electrical and

Electronic Products


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• China RoHS1 only covered “Electrical Information

Products (EIP)” falling into 10 product categories

Product scope

• China RoHS2 Article 3: “electrical and electronic equipment”

“equipment with voltage rating <1,500 V DC and <1,000 V

AC which is dependent on electric currents or

electromagnetic fields” + auxiliary products

(EEP definition is the same as EU Rohs II)

• China RoHS2 excluded “ EEP and auxiliary

products relevant to power generations,

transmissions and distributions. “


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1. Equipment concerning electric energy production,transmission and

distribution:power plant,power transmission and distribution plant，

system and equipment for power supply and distribution in buildings;

2.Electronic equipment for military use;

3. Electrical and electronic equipment for special environment or extreme

environment；（like ultra – low temperature …）

4.Electrical and electronic equipment for exporting outside China；

5.Temporarily imported electrical and electronic equipment or that for

maintenance (not for sale)

6.Prototype for research and development or testing

7.Samples and display products for exhibition but not for sale.

Product scope


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Some EU-unregulated products may be concerned byChina RoHS II

Products excluded from scope of EU RoHS2 may be in scope of China

RoHS2:

• Large-scale industrial tools

• Large-scale fixed installations

• Monitoring and control instruments

• Some Lamps

• active implantable medical devices;

• photovoltaic panels …

• … …

China RoHS 2Scope

China RoHS 1Scope

Some EU-regulated products may not be concerned by China RoHS II

Product excluded from scope of China Rohs II• EEP and auxiliary products relevant to power generations,

transmissions and distributions. “


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Electrical and electronic products sold in the Chinese

mainland market, except Hong Kong, Macao and Taiwan.

“Products placed on the Chinese mainland market”

placed on the market

Applicable countries and regions

Production date after July 1 2016.

Applicable for imported products.

Time of implementation


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MCV values are the same as EU Rohs II

• Prescribed Maximum Concentration Value (MCV) of substances use in

homogeneous material of electrical equipment:

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Regulated substances Maximum Concentration Value(MCV)

Lead/lead compounds - (Pb) < 1 000 ppm (0,1%)

Mercury/mercury compounds - (Hg) < 1 000 ppm (0,1%)

Hexavalent chromium compounds - (Cr(VI)) < 1 000 ppm (0,1%)

Cadmium/cadnium compounds - (Cd) < 100 ppm (0,01%)

Polybrominated biphenyl flame retardants - (PBB) < 1 000 ppm (0,1%)

Polybrominated diphenyl ether flame retardants - (PBDE) < 1 000 ppm (0,1%)

GB／T 26572 -20 11 Requirements of concentration limits for

certain restricted substances in electrical and electronic products


Phase 1: After July 1st 2016 & No “Catalogue” yet

• No “Catalogue” yet, so No Restrictions Yet

• Products produced after July 1 2016, Self Declaration”

Disclosure process + Corresponding marking requirements

• Products produced before July 1 2016, (better prove it)1. Newly covered by China Rohs II but not China Rohs I, no need Self

Declaration” Disclosure process + Corresponding marking requirements

2. Covered by China Rohs I and II, Self Declaration” Disclosure process +

Corresponding marking requirements

• Products under the Catalogue must fulfill MCV values

• Uses of restricted hazardous substance classes

• Restricted use times

•“Conformity assessment system” ( certification models not known)

China Rohs II implementation

Phase 2: “Catalogue” published (do not know when yet)


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Marking requirements:

• All EEP must be labelled (in the recommended color – mini 5mm x 5mm)

• Can be on the products or on the package

• auxiliary products (not on the market) do not need to label but need to make Declaration of Conformity (on the manual or on website)

— with green environmentally friendly symbol if all homogenous

materials in all parts of the EEP contain less than MCV

• no need of Declaration of Conformity, as all homogenous

materials in all parts of the EEP contain less than MCV

=< MCVs

SJ/T 11364-2014 “Marking for the restriction of the use of hazardous substances in electrical and electronic product ”

（Substitute SJ/T 11364-2006)


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Marking requirements:

— OR with orange symbol and Environmental Protection Use

Period (EPUP) if any homogenous material in any part of EEP

contains more than MCV (necessity to provide DoC).

How to define “Environmental Protection Use Period (EPUP)”?

• EPUP is the period during which the RoHS substances “will not leak

or mutate”

• EPUP is theoretically defined by Manufactures, no need of

government approval

• EPUP for China Rohs I covered products, refer to the method

specified in “SJ/Z 11388-‐2009 General guidelines of environment--

‐friendly use period of electronic information products’’ to fix the term

of environmental use of products.

> MCVs


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Declaration of Conformity

(DOC must be in Chinese language, here attached is the translation)


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03 November 2016


Background

• Since its publication, China Rohs II has faced many questions and misunderstandings.

• To enable the parties involved to understand various clauses of the China Rohs II, The Department of Energy Saving and Comprehensive Utilization of MIIT published a “ frequently asked questions” (FAQ)

• 56 questions were answered.

‹#›


03 November 2016


Two official documents, and only these two official documents currently shall be referenced by manufactures.

• Measure for the administration of the restricteduse of hazardous Substances Contained inElectrical and Electronic products

• Frequent Q&As on Management Methods for Restricted Use of Hazardous Substances in Electrical and Electronic Products

‹#›


Key take-aways from FAQ

Q 2, 3, 10, 11, 12 and 53 Product scope

• Packaging materials is not in the products scope anymore

Q10 & Q11 “auxiliary products” and “auxiliary products” for Power Generation, transmission and distribution (not in the scope)

Q14 & Q19 electric transportation machinery and tools (not in the scope, e.g. e-bicycle, e-car, e-products inside the car)

‹#›



Q8 &Q9 How to define “Environmental Protection Use Period (EPUP)”

• The manufactures defines, as no standards or recommendations for the electrical products (EEP) yet.

• Electronics products “SJ/Z 11388-‐2009 General guidelines of environment-‐friendly

use period of electronic information products’’

• Newly covered products government recommendation will be published

• Some companies defined as 25 years

‹#›



Q 23 Overseas company sells their products to its Chinesesubsidiary regarded as “place on the market”, need to do China Rohs II.

Q27 and Q31 responsibilities for the up stream suppliers (Doc and other technical information)

Q33 Non- electrical “auxiliary products” and Whole products (only indispensable Non- electrical “auxiliary products need to DoC)

Q 34 electrical “auxiliary products” and Whole products (Doc)

‹#›



Q36-44 Marking and Labelling• Marking and the disclosure table are ONLY necessary for

sales to end customers of end products, i.e. Finished

Goods

• Producers of EEPs within the supply chain, i.e.

subassemblies/ modules/ ODM/ OEM, and component

manufacturers do not need to mark their products; But

must provide relevant information to their customers so they

can mark/label appropriately

• Color of the labels (green or orange, recommended only)

• Q 56 the manufacturer of end products should bear the

responsibility … if non-compliance to the regulation

‹#›



Q 48-51 “Catalog”

• The China Rohs II experts group will have next meeting in next week discussing the catalog products

• Third party certification is expected as “CESI”, the main drafter of China Rohs II and its “Catalog”, is also testing labs.

‹#›


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03 November 2016



1. GB/T 26572-2011: Requirements of concentration limits

for certain restricted substances in electrical and electronic

products (previously SJ/T 11363-2006)

2. GB ／ T 26125--2011 （ IEC 62321 ： 2008 ， IDT)

Electrotechnical products – Determination of levels of sixregulated substances (lead, mercury, cadmium, hexavalentchromium, polybrominated biphenyls, polybrominated diphenylethers)

3. SJ/T 11364-2014: Marking for the Restricted Use of

Hazardous Substances in Electronic and Electrical Products

(supersedes SJ/T 11364-2006)

4. SJ/Z 11388-2009 General guidelines of environment-

friendly use period of electronic information products

‹#›



1. Some arguments from CEEIA (China electrical

equipment Industry association)

2. Current Customer checking and Market Surveillance

situation on China Rohs II

3. Lobby activities from industries for the “Catalog”

products

4. Lobby activities for conformity assessment model

MIIT Order 32 (Chinese RoHS II) - Regulatory Intelligence Report

‹#›


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SESEC联系信息Dr. Betty XU

Seconded European Standardization Expert in China (SESEC)

A project co-funded by CEN, CENELEC, ETSI, EC and EFTA

Beijing office: Room 2080, Beijing Sunflower TowerNo.37, Maizidian Street, Chaoyang District,Beijing 100125, P.R. China

Phone: +86 10 85275366-802

Fax: +86 10 8527 6363

Mobile:+86 185 118 20197

E-mail: [email protected]

徐斌博士

欧盟驻华标准化专家机构总监

办公室地址：北京麦子店西街37号，盛福大厦 2080 室

电话： +86 8527 5366 -802

传真: +86 10 8527 6363

手机:+86 185 118 20197

电子邮件: [email protected]


27 Sept 2016

mailto:[email protected]

mailto:[email protected]


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