China Restriction of Hazardous Substances Compliance Deadline 1 November 2019

China RoHS 2 became effective on 01 July 2019, but the deadline for companies to perform conformity assessments and upload evidence for the “China RoHS 2: Qualification Management Catalogue (First Batch)” is 01 November 2019.

The “First Batch” includes 12 product types:

  • Refrigerators
  • Air conditioners
  • Washing machines
  • Electric water heaters
  • Printers
  • Copiers
  • Fax machines
  • TVs
  • Monitors
  • Micro-computers
  • Handheld phones for mobile communication
  • Telephone sets

Under China RoHS 2, companies must have performed compliance assessments by either a voluntary third-party certification or self-declaration method and upload sufficient evidence ahead of the November 1, 2019 deadline or within a specified time after being placed on the market in China.

The platform and usage guide went live on October 8, 2019 and are currently available in Chinese:

The legislation also introduces two new logos; one to indicate a third-party assessment has been completed (i.e., by an accredited test facility) and the second for self-declaration.

Third-Party Assessed:                                                  Self-Declaration:

Third-party organizations with product certifications should upload the relevant information within five working days of the product approval/certification. Companies that have chosen to self-declare must submit information, along with relevant supporting technical materials, to the platform within 30 days after their products are placed on the market.

Find out how TPP can help you meet your compliancy goals regarding China RoHS 2 and more at TPP – Total Parts Plus.

FAQ 1: What is China RoHS 2?

China RoHS 2 restricts the same 6 hazardous substances as EU RoHS 2 and affects electrical and electronic devices, components and accessories manufactured after July 1, 2019. Devices in scope have a rated working electrical voltage that does not exceed 1500V direct current and does not exceed 1000V alternating current and functions by use of, generates, transmits and measures current and electromagnetic fields.

Coverage includes products manufactured in or imported into China. However, it DOES NOT include products exported from China.

The EEP (Electrical and Electronic Equipment) categories in scope of China RoHS 2:

  • Communication equipment, fixed or mobile
  • Professional broadcast and TV equipment
  • Computer and office equipment
  • Household appliances
  • Electronic instruments for monitoring and control applications
  • Industrial electrical and electronic equipment, including monitoring and control equipment
  • Power tools
  • Medical electronics and devices
  • Lighting products, including electric light sources (lamps) and luminaires
  • Sports and entertainment products

See MIIT “Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products” (commonly known as China RoHS 2) for full requirements.

 FAQ 2: What are the main differences between China RoHS 2 and EU RoHS?

  • Unlike EU RoHS, where disclosure to enforcement authorities is only required upon request – China’s new requirement is to disclose and declare conformity via a public service platform
  • Unlike EU RoHS, large-scale stationary industrial tools and fixed installations are NOT EXCLUDED
  • Unlike EU RoHS, ALL PRODUCTS must have a hazardous substance disclosure table that details each substance contained regardless of exemption or categories outside scope of China RoHS 2
  • Unlike EU RoHS which combined RoHS marking into the CE mark – China REQUIRES a separate hazardous substance label, appropriate EFUP (Environment-Friendly Use Period) marking and disclosure table shipped with the product
  • Unlike EU RoHS which restricts substances at the product level – China RoHS 2 restricts substances at the homogeneous material level (i.e., pieces/parts used within the product)

FAQ 3: What are the main differences between China RoHS 1 and 2?

  • Batteries were excluded in China RoHS 1, but NOT EXCLUDED in China RoHS 2.
    • If they are permanently attached to the device, they are covered by the products disclosure table and EFUP (Environment-Friendly Use Period) declaration
    • If they are replaceable, they REQUIRE their own EFUP declaration and disclosure table
  • Summary of labeling requirements:
    • MUST include the date of manufacture
    • MUST state that hazardous substances are present or not (i.e., none uses the green “E”)
    • MUST define the EFUP if substances are present (i.e., uses the orange “5” to “50”)

  • Hazardous Substances Disclosure Table:

See GB/T 26572 for detailed concentration limits for hazardous/restricted substances in EEP.
SJ/T 11364-2014 for detailed marking requirements, determining EFUP and recyclability.

Find out how TPP can help you meet your compliancy goals regarding China RoHS 2 and more at TPP – Total Parts Plus

SAVE THE DATE – RBA and RMI Annual Conference 2019

Total Parts Plus will be attending the 11th Annual Conference of the Responsible Business Alliance (RBA) and the Responsible Minerals Initiative (RMI) held October 21 and 22 at the Santa Clara Convention Center in San Jose, California.


As RBA’s biggest event of the year, this conference will focus on corporate social responsibility in global supply chains with top speakers from industry, civil society, and government. During the program, conference participants will gain valuable insight on the progress to date of RMI’s collective efforts as well as how companies can make better decisions when it comes to mineral sourcing and corporate social responsibility.


Please stop by our booth to see how TPP can support your company with Conflict Minerals and Environmental Compliance.


For more information visit the RBA & RMI Conference website:


To register for the 2019 RBA and RMI Annual Conference:


The Responsible Minerals Initiative is an Initiative of the Responsible Business Alliance (RBA) and is a multi-industry initiative of over 380 member companies. Its members contribute to the development and international uptake of a range of tools and resources focused on minerals supply chain due diligence, including independent third-party assessment programs for smelters, Minerals Reporting Templates, supply chain risk assessment tools, Country of Origin data, and guidance documents on responsible sourcing of tin, tantalum, tungsten and gold, and cobalt.


Final Report for assessment of two RoHS exemption requests (Pack 16) published

The final report on the study to assess two exemption requests in Annexes III and IV to the RoHS Directive (2011/65/EU) have been prepared by Oeko-Institut e.V and peer reviewed by Fraunhofer Institute IZM and published on the European Commission’s CIRCABC website as well as on Oeko’s own website.

The report was prepared under the Framework Contract: “Assistance to the Commission on technical, socio-economic and cost-benefit assessments related to the implementation and further development of EU waste legislation” and outlines the outcome of the assessment of the renewal of exemption IV.42 and the request for a new exemption for lead and hexavalent chromium compounds in electric and electronic initiators of explosives for civil (professional) use.

The key outcomes include a recommendation for extension of exemption IV.42 to 30 June 2026, from the original expiry date of 30 June 2019. Regarding the requested new exemption for lead and hexavalent chromium in electric and electronic initiators of explosives for civil (professional) use, the authors recommend a narrower scope of the exemption to be valid for five years. The exemption is recommended to apply not to all lead and hexavalent chromium compounds but to lead diazide, lead styphnate, lead dipicramate, orange lead (lead tetroxide), lead dioxide in electric and electronic initiators of explosives and barium chromate in long time pyrotechnic delay charges, both for civil (professional) use.

18 SVHCs proposed for authorization

The European Chemicals Agency (ECHA) has on October 1st, recommended 18 substances of very high concern (SVHCs) to be included in REACH Annex XIV, the Authorisation List. The substances are toxic for reproduction, endocrine disrupting, carcinogenic, very persistent and very bioaccumulative (vPvB) or respiratory sensitisers or a combination thereof. The substances have been included in the recommendation due to their intrinsic properties combined with high volume and widespread uses according to ECHA, potentially posing a threat to both human health and the environment.

ECHA considered comments from public consultation (September-December 2018) and the Member State Committee when making the decision on which substances from the Candidate List to include in the Authorisation List and their respective sunset dates in their recommendation to the European Commission.

The annex to ECHAs press release on the matter lists the 18 substances concerned and the full recommendation includes more details on the substances such as CAS number as well as recommended sunset dates and reasons for inclusion in the recommendation. The final decision on the inclusion now lies with the European Commission in collaboration with Member States and the European Parliament.

For more information on how TPP can assist you in evaluating your products for SVHCs and Authorized substances click here or contact us.

New RoHS Directive Amendment and Category 11 Product Type

On Monday, 22 July 2019, EU Directive 2015/863 added 4 new restricted substances as well as product Category 11 to the original list of 6 substances and original 10 categories laid out in Directive 2002/95/EC and amended by Annex II of Directive 2011/65/EU.

What does that really mean for manufacturers and importers?

The new directive is applicable to all new electrical and electronic products placed on the European Union market – regardless of being imported or manufactured in the EU, and it requires that products bearing the ‘CE’ mark are presumed to comply with the directive (in the absence of evidence to the contrary).

Any EEE products not covered by the original Categories 1-10 come into scope as Category 11 products (i.e., 2-wheeled electric vehicles, electronic cigarettes, cannabis vaporizers, vape pens, electrical cables less than 250V, etc.) and have slight differences when compared to the other categories:

  • All products, regardless of their import date, must comply after 22 July 2019 (stock from before 22 July 2019 may no longer be sold in the EU unless already compliant).
  • No allowances are made for non-compliant spare parts after 22 July 2019.

What are the 10 restricted substances?

The original 6 substances consisted of 4 heavy metals and 2 flame retardants:

  • Lead (Pb) – a heavy metal used in printed circuit boards, paints, and pigments.
  • Mercury (Hg) – a heavy metal used in lighting and automotive switches.
  • Cadmium (Cd) – a heavy metal used in plastic pigmentation and photocells.
  • Hexavalent Chromium (CR VI) – a heavy metal used to prevent corrosion of metal finishes.
  • Polybrominated biphenyls (PBBs) – flame retardant used in appliances, electronics, and textiles.
  • Polybrominated diphenyl ethers (PBDEs) – flame retardant used in electronics and furniture.

All the new additions are phthalates – a plasticizing compound used to add flexibility and durability:

  • Bis(2-Ethylhexyl) phthalate (DEHP) – used in cable insulation and as a softener for PVC.
  • Butyl benzyl phthalate (BBP) – used in flexible adhesives, coatings, inks, and vinyl products.
  • Dibutyl phthalate (DBP) – used in flexible varnishes, nail polish, and variety of rubbers and paints.
  • Diisobutyl phthalate (DIBP) – used in printing inks, adhesives, and cosmetic applications.



What are the effective dates?

Effective Date


22 July 2019

1: Large Household Appliances (LHA)

22 July 2019

2: Small Household Appliances (SHA)

22 July 2019

3: IT and Telecoms Equipment

22 July 2019

4: Consumer Equipment

22 July 2019

5: Lighting Equipment

22 July 2019

6: Electrical and Electronic Tools

22 July 2019

7: Toys, Leisure and Sports Equipment

22 July 2021

8: Medical Devices

22 July 2021

9: Monitoring and Control Equipment (including Industrial)

22 July 2019

10: Automatic Dispensers

22 July 2019

11: Other EEE not covered above (catch-all)


Are there exemptions or transition periods?

Category 8 and 9 products have 2 years remaining and fall into scope on 22 July 2021. There are additional exemptions for specific applications or industries; the current status is reported on the European Commission website.

How can Total Parts Plus help?

TPP provides customers with dedicated resources for the time-consuming tasks of surveying suppliers, out of scope assessments, conducting analytical research, validating data, and monitoring exemptions.

TPP customers also have access to our extensive database of pre-approved compliant parts via our web-based Compliance Management Module (CMM) which empowers companies to easily manage and monitor their environmental compliance data.

How do you get started?

Contact Total Parts Plus to learn more or schedule a demo.
Call:       +1.850.244.7293

TPP Application Update

TPP has added an XML API feature for the reporting of RoHS II (2011/65/EU) compliance including the amendment added by Directive (EU) 2015/863. The change was implemented in the TPP XML API test account May 23rd, 2019 to allows customers to implement the feature before the amendment takes effect July 22nd, 2019.

The attribute RoHS10 was added to the parts elements for material content response and reflects the RoHS II compliance status to current 6 RoHS II substances and the 4 phthalates added by Directive (EU) 2015/863. The 10 indicates the current number of substances restricted. 

If you have questions or comments, please contact:

Cathy Iler                                                                             Nikki Johnson                   

850.244.7293 x 1005                                                        850.244.7293 x 1036                             

TPP verified as an IPC 1752A WAM 1, 2 & 3 solution provider 2018

The IPC 1752A standard is used extensively for communicating compliance information throughout the supply chain for electrical and electronic products. To meet changing industry requirements and legislation, the standard is regularly updated and maintained by industry experts.

IPC introduced an annual review process for solution providers in 2014 in which a review committee of industry experts verify that companies IPC 1752A XML files comply with current requirements.

All solution providers are invited to submit example XML files reporting IPC 1752A Class A, C and/or D in Request/Reply and/or Distribute mode. The review committee inspects, comments and verifies that the files submitted;

  • Comply with IPC 1752A XML file format
  • Use IPC 1752A lists of regulated substances and exemption correctly

The standard includes an XML Schema outlining the structure and rules to be followed in the IPC 1752A declaration files. It specifies types of data elements to be included as well as the order in which they must be reported. To accurately communicate materials information using the standard, correct use of defined industry naming conventions is critical. It is also essential to accurately use the dynamic lists of regulated substances and exemptions for compliance with the standards.

Total Parts Plus is pleased to announce that we are a verified solution provider of IPC 1752A Class A, C and D declarations in both Request/Reply and Distribute mode in the 2018 review process and we look forward to participating in the upcoming 2019 process starting in April.

TPP provides a free IPC 1752 generator located here and an IPC 1752 generator available for purchase which includes features not provided in the free tool.  For more information on TPP’s IPC 1752 generator tools or IPC 1752 collection and generation services, contact our sales department here or email  To find out more about the solution provider review process visit IPC Materials Declaration Data Exchange Standards.

RoHS project, Pack 17 – Assessment of three exemption requests

A project assessing three exemption requests with regards to the RoHS directive’s Annex IV has been initiated by Oeko-Institut e.V. – Institute for Applied Ecology. The Annexes of the directive are to be adapted based on scientific and technical progress as outlined in Article 5 and the Environment Directorate-General of the European Commission has requested assistance in providing scientific and technical support for the evaluation of exemption requests with regards to RoHS2 from a consortium led by the Oeko-Institut.

Two of the three requests are for new exemptions of Bis-(ethylhexyl) phthalate (DEHP) for use in certain medical equipment applications, called on by COCIR and GE Healthcare. The third request is for the renewal/amendment of the existing exemption 31a (Annex IV) and also addresses DEHP as well as Di-isobutyl phthalate (DIBP) and Benzyl butyl phthalate (BBP) and their use in spare parts for repair or refurbishment of medical devices, called for by COCIR.

The evaluation is to be performed in co-operation with the European Commission and stakeholders from the electrical and electronic industry, NGO’s and independent experts through a project specific website as well as mailing lists for which stakeholders can register as well as workshop or meetings as needed. A stakeholder consultation is expected to be launched in March and the project will end in August.

For more information visit Oeko-Institut’s RoHS Evaluations website.

Are you ready for the inclusion of phthalates to RoHS2?

As adopted 31 March 2015, the European Commission Delegated Directive (EU) 2015/863 will take effect this year, amending annex II of Directive 2011/65/EU to include four phthalates.

From 22 July 2019 the four phthalates Bis(2-ethylhexyl) phthalate (DEHP), Butyl benzyl phthalate (BBP), Dibutyl phthalate (DBP) and Diisobutyl phthalate (DIBP) will be restricted under RoHS2 for all EEE with the exception of category 8 and 9 (medical devices and monitoring and control instruments, for which the restrictions will apply from 22 July 2021).

DEHP, BBP, DBP and DIBP will individually have a maximum tolerated concentration value of 0.1% by weight in homogeneous materials. Phthalates are mainly used as plasticizers and found as additives in plastics, adhesives, paints, rubbers and similar materials, making them flexible and stretchable, for example vinyl resins such as PVC often found in cable coatings.

To place electrical and electronic equipment containing any of the phthalates on the market after 22 July you must apply for an exemption with the European Commission or find an alternative substance. Does your products contain any of the four phthalates? Find out how TPP can assist you in staying current with changes to the RoHS directive here.

Cobalt- Updates Regarding Reporting and Restriction

At the end of 2018, the Responsible Minerals Initiative (RMI) released version 1.1 of the Cobalt Reporting Template (CRT) following the findings of a working group formed in 2017 focusing on the responsible sourcing of cobalt. Reports made prominent concerns over child labor and unsafe working conditions in the cobalt mining industry. The CRT was developed for the voluntary collection of cobalt data through industry supply chains. 

Cobalt is used extensively in lithium-ion batteries in mobile phones, tablets, laptops and automobiles. The CRT is intended to facilitate exchange of data within the cobalt supply chain, making it more transparent with regards to the origin of the cobalt as well as smelters and refiners used.

The CRT differs from the today widely applied Conflict Minerals Reporting Template (CMRT) in that the it addresses cobalt specifically whereas the CMRT addresses tin, tantalum, tungsten and gold. The CMRT follows the IPC-1755 Conflict Minerals Data Exchange Standard for compliance with Section 1502 of the Dodd-Frank Act.

The IPC-1755 standard is currently being updated to include reporting for Conflict Affected and High Risk Areas (CAHRAs) for the new EU Conflict Minerals Regulation coming into force January 1, 2021. The CRT will be discussed by the IPC 2-18H Conflict Minerals Data Exchange Task Group, co-chaired by Nikki Johnson of TPP, at IPC APEX next week to determine if it should be incorporated in the Conflict Minerals Data Exchange Standard, if a new standard should be written or if IPC will take no action until there is legislation which requires reporting of cobalt.

Meanwhile, ECHA calls for comments on its proposed restrictions on the manufacture and placing on the market of five cobalt salts in industrial and professional applications in a public consultation accepting early comments in March 2019. The proposal includes restriction on cobalt sulfate, cobalt dinitrate, cobalt dichloride, cobalt carbonate and cobalt di(acetate) as substances on their own or in mixtures in concentrations equal to or above 0.01% by weight.

In this ever-evolving climate of reporting and restrictions, TPP can help you stay informed and proactively manage compliance.