A Closer Look at China RoHS: What Manufacturers Need to Comply

Article Highlights:

• China RoHS refers to regulations established by the Chinese government aimed at controlling the use of certain hazardous substances in electrical and electronic products. 
• The original scope of China RoHS covered six substances including Lead (Pb), Mercury (Hg), and Cadmium (Cd)
• Four new phthalates were added to this list following a recent amendment.
• Companies must ensure that the restricted hazardous substances are either absent or within the permissible concentration limits in the products and their components.

What Is China RoHS?

China RoHS (Restriction of Hazardous Substances) refers to regulations established by the Chinese government aimed at controlling the use of certain hazardous substances in electrical and electronic products. These include consumer electronics, telecommunications equipment, and other related devices. The regulations are similar in intent to the European Union's RoHS directive but have some differences, such as labeling requirements. 

Why Was China RoHS Implemented?

China RoHS aims to reduce the environmental impact of electronic waste and protect human health by minimizing the use of hazardous substances in electronics. China RoHS compliance is mandatory for products sold in the country, and non-compliance can result in penalties and restrictions on market access.

What Does the Regulation Cover?

The scope of China RoHS covers a wide range of products and components, assemblies, and parts that depend on electric currents or electromagnetic fields to function. Covered categories include:

•  Home Appliances
• Consumer Electronics
• Telecommunications Equipment
• Lighting Equipment
• Electrical Tools
• Toys and Sports Equipment
• Medical Devices

The Ministry of Industry and Information Technology (MIIT) publishes and updates a specific product catalog that lists products subject to the mandatory requirements of China RoHS. The catalog is periodically updated to include new products and categories. Some items are excluded from the scope of China RoHS, such as certain types of large-scale fixed installations, military equipment, and products for export. 

List of Substances Restricted by China RoHS

The original scope of China RoHS specifically targeted the following hazardous substances in electronic and electrical products:

• Lead (Pb)
• Mercury (Hg)
• Cadmium (Cd)
• Hexavalent chromium (Cr(VI))
• Polybrominated biphenyls (PBB)
• Polybrominated diphenyl ethers (PBDE)

A recent amendment added the following four phthalates to the list:

• Bis(2-ethylhexyl) phthalate (DEHP)
• Butyl benzyl phthalate (BBP)
• Dibutyl phthalate (DBP)
• Diisobutyl phthalate (DIBP)

Manufacturers, importers, and sellers must conduct conformity assessments and maintain documentation to demonstrate compliance with China RoHS regulations. 

What’s the Difference Between China RoHS and EU RoHS? 

With the most recent updates to China’s regulations, China RoHS and EU RoHS are now aligned, covering the same substances and similar categories. Each of the regulations maintains its own exemption list, however, and China RoHS requires in-scope products to be marked to indicate their compliance status with the hazardous substances restrictions. This includes the Environmental Friendly Use Period (EFUP) label indicating the timeframe within which hazardous substances do not pose harm to human health or the environment, as well as concentration limits markings to indicate the presence and concentration of restricted substances. While EU RoHS limits the concentration of these substances allowed on the market, China RoHS aims to communicate the presence or absence of these substances.

What Do Manufacturers Need to Do to Comply?

To comply with China RoHS, manufacturers, importers, and sellers first need to determine if their products fall within the scope of the environmental directive. This can be done by consulting the relevant regulations and the Product Catalog issued by the Ministry of Industry and Information Technology (MIIT).

If China RoHS does apply to their products, companies must ensure that the restricted hazardous substances are either absent or within the permissible concentration limits in the products and their components. This can be done by communicating with suppliers to obtain necessary declarations and information about the materials and components used in their products. Companies must maintain records of test results, material declarations from suppliers, and other documentation demonstrating compliance for the lifetime of the product. They should also regularly review and update compliance processes and related documentation to reflect any changes in regulations, the product catalog, or the composition of their products.

Organizations also need to stay up to date on China RoHS labeling requirements for their products. These include:

• Environmental Friendly Use Period (EFUP) Mark: Indicates the period during which the product can be safely used without causing harm due to the presence of hazardous substances.
• China RoHS Compliance Mark: Indicates whether the product complies with the substance restrictions (green label for full compliance, orange label if the product contains restricted substances within allowable limits).
• Hazardous Substances Table: Often called the "HJ/T 113 Table,” this must appear in the product’s user manual or other accompanying documentation.

If manufacturers are not selling directly in China, they should still be prepared to disclose information regarding the presence of hazardous substances in their products or packaging, or provide accompanying documents for clients that may require this information. By following these steps, manufacturers, importers, and sellers can ensure their products demonstrate China RoHS compliance, thereby avoiding penalties and ensuring continued access to the Chinese market.

See What Parts of Your Supply Chain Are at Risk

Each year, new regulations come into force across major global markets. These regulations, ranging from trade compliance requirements to sustainability directives, can be challenging to track and even harder to understand in terms of their impact on your supply chain.

For end-to-end visibility on your compliance, including new and existing risks, connect with Z2Data’s product specialists for a free demo. Z2Data’s compliance solution enables companies to instantly identify which parts in their BOM are compliant, which aren’t–and which need attention first.

Don't risk missing another regulation or facing shipment delays due to unforeseen compliance issues. Get ahead of risks and prevent them before they prevent you from getting to market. Contact Z2Data’s product specialists today for a free demonstration.