China Proposes First Batch of Electrical and Electronic Equipment Subject to Requirements under China RoHS

Summary

China’s Ministry of Industry and Information Technology published on 29 June 2017 the Invite for Response to the Proposed Management Catalog of Electrical and Electronic Equipment Subject to Restrictions on Use of Hazardous Substances (First Batch) and Proposed List of Exempt Applications of Hazardous Substances Identified in the Management Catalog (公开征求对《电器电子产品有害物质限制使用达标管理目录（第一批）》（征求意见稿）及《达标管理目录限用物质应用例外清单》意见) (the Proposal). The proposed catalog and list specify the scope of application for requirements under the Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products (China RoHS), including the first batch of products which will be subject to the China RoHS restrictions. Additional electrical and electronic equipment (EEE) products will be published continuously by the MIIT.

3E Review

Proposed Management Catalog of Electrical and Electronic Equipment Subject to Restrictions on Use of Hazardous Substances (First Batch)

The Proposed Management Catalog of Electrical and Electronic Equipment Subject to Restrictions on Use of Hazardous Substances (First Batch) (the Proposed Catalog) would provide the following information for a total of 12 types of EEE:

• product name;
• product description and definition;
• scope of application for product.

EEE identified in the Proposed Catalog includes the following:

• refrigerators
• air-conditioners
• washing machines
• water heaters
• photocopier
• printers
• fax machines
• monitors
• personal computers
• cell phones
• telephones
• televisions

Manufacturers, sellers, and importers of EEE identified in the Proposed Catalog would be required to comply with the restrictions on the use of hazardous substances as provided under the Requirements on Concentration Limits for Certain Restricted Substances in Electrical and Electronic Products (电子电气产品中限用物质的限量要求) (GB/T 26572-2011).

Proposed List of Exempt Applications of Hazardous Substances Identified in the Management Catalog

In addition to the Proposed Catalog, the Proposal includes the Proposed List of Exempt Applications of Hazardous Substances Identified in the Management Catalog (the Proposed List). The Proposed List, once adopted, would provide exemptions for the use of hazardous substances in certain products. For instance, the use of mercury in single-capped fluorescent lamps with a power rating of less than 30 watts would be permitted, provided that the mercury contained in each lamp does not exceed 2.5mg.

Public comments on the Proposal can be submitted to the Ministry of Industry and Information Technology by 28 July 2017. Interested parties may submit their comments via one of the following methods:

• by phone: +86 10-68205340
• by fax: +86 10-68205340
• by email: hbc@miit.gov.cn

Background information

Under the Management Measures on the Restricted Use of Hazardous Substances in Electrical and Electronic Equipment (电器电子产品有害物质限制使用管理办法) (Management Measures), the Ministry of Industry and Information Technology (MIIT) is responsible for the issuance of a management catalog that specifies the scope of EEE in which the use of hazardous substances is restricted. This catalog must provide information regarding the types of EEE subject to restrictions, types of restricted substances, deadlines for the implementation of these restrictions, as well as applicable exemptions to these restrictions.

Restricted hazardous substances as defined under the Management Measures include the following:

• lead and its compounds;
• mercury and its compounds;
• cadmium and its compounds;
• hexavalent chromium and its compounds;
• polybrominated biphenyls;
• polybrominated diphenyl ethers; and
• other hazardous substances published by the government.

3E Analysis

Companies that manufacture, sell or import electrical and electronic equipment (EEE) must note that a total of 12 types of EEE have been proposed to be subject to the restrictions under China RoHS. Examples of these EEE include washing machines, printers, and personal computers. More products will follow. Affected companies are recommended review the Proposal and submit any comments that they might have to the Ministry of Industry and Information Technology by 28 July 2017. 

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