The China RoHS 2 conformity assessment requirements came into effect on November 1, 2019.  Manufacturers and importers of EEE products that are in the batch 1 product list had to either (1) complete voluntary certification with an accredited certification lab or (2) complete necessary registration and document submission for self-declaration.

China RoHS 2 Batch 1 Products

The batch 1 products that are in scope of the substance restrictions and conformity assessment obligations include: Refrigerator, Air conditioner, Washing machine, Electric water heater, Printer, Copier, Fax machine, TV set, Monitor, Microcomputer, Mobile phone, and Telephone.

China RoHS 2 Self-Declaration

For the self-declaration path, the manufacturer (or importer) registers on a centralized government system known as the “China RoHS Public Service Platform”.  The manufacturer then submits a completed self-declaration form and technical documentation demonstrating conformance to the substance requirements. There were several unknowns as to exactly how the system would operate and what documents had to be submitted, but that become clearer once the platform went live in early October. The China RoHS Public Service Platform is accessible at http://chinarohs.miit.gov.cn

During a recent presentation on the self-declaration approach, two types of documentation were discussed: (1) a Product Test Report or (2) Suppliers Conformity Report based on hazardous substance assessment of assemblies, parts and components.  This second approach is like European self-declaration using EN 50581/ IEC 63000. In fact, China adopted the IEC 63000 standard on restricted substance technical documentation as a China National standard (GB/T 36560-2018) for this purpose.

The completed self-declaration form needs to be submitted in simplified Chinese.

Figure 3: China RoHS Public Service Platform

Manufacturers should carefully review official publications and guidance in order to ensure that they are meeting the compliance requirements for China RoHS 2.