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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