China – China RoHS 2 Takes Effect

China RoHS 2 came into effect on July 1, 2016. On the same date, the revised China RoHS marking standard SJ/T 11364-2014 “Marking for the Restriction of Hazardous Substances in Electrical and Electronic Products” also came into effect. The implementation of SJ/T 11364-2014 had been on hold since its publication in 2014, awaiting the China RoHS 2 regulation to catch up.

The FAQ document published by MIIT in May 2016 clarifies some of the questions raised by the China RoHS 2 regulation (The Management Methods).  Our June Monthly Environmental Report started to provide a summary of some key pieces of information in the FAQ document.  Some  information (for general indication)  based on unofficial English translation is provided below (refer to original Chinese document for official FAQ):

  • Products must comply to the new China RoHS 2 requirements if their final date of manufacture is on or after July 1, 2016. The FAQ explicitly states (Q6) that this is also the case for imported products and that the enforcement date does not have anything to do with the date of customs clearance or when the product is sold.
  • Accessory products referred to in the definition of “Electrical and electronic products” is intended to mean components, parts, and materials used in or with the EEP. This will include spare parts used to repair, refurbish, or upgrade a product. Accessory products that are part of the EEP must comply with the requirements of the Methods. (Q10)
  • Batteries are generally included in the scope of the Methods (Q15);
  • Electric wires and cables, even if sold on their own, are included in the scope of the Methods (Q16);
  • Consumables are in scope of the Methods if they are provided with the EEP or if they need to be powered up to operate. (Q17)
  • The requirements for efficient resource utilization and ease of recycling and disposal in Articles 9 and 10 of the Methods, are provided to encourage environmentally conscious design (ECD) of products. There are no mandatory requirements at this time. (Q52)
  • Article 12 specifies that product packaging comply with relevant standards. The FAQ (Q53) clarifies that at the present time, this Article is to to encourage ECD of the product packaging.