Taiwan issued on July 3, 2015 a World Trade Organization (WTO) Technical Barriers to Trade (TBT) notification providing additional details about Taiwan RoHS requirements. The proposed requirements are to be implemented under the Taiwan “Commodity Inspection Act”. The notification proposes a requirement that certain EEE products must conform with Taiwan BSMI standard CNS 15663 “Guidance to reduction of the chemical substances in electrical and electronic equipments” and in particular, Section 5 “marking of presence”. The TBT notification lists the following products as proposed to be included within scope of the requirements:
- Automatic data processing machines,
- printers,
- photo-copying machines,
- televisions,
- monitors, and
- monitors used in an automatic data processing.
The requirement will include marketing and documentation requirements which have been summarized in the TBT notification as:
The certificate holders/applicants of the commodities shall follow the requirements stipulated in Section 5 “Marking of presence” of CNS 15663 and clearly mark “the presence conditions of the restricted substance” on the body, packages, stickers, or the instruction books of the commodities. For those who utilize website as a means to announce “the presence conditions of the restricted substance” of the commodities shall also clearly mark the website address on the body, packages, stickers, or the instruction books of the commodities.
Before 1 May 2017, the certificate holders shall prepare documents related to the location of the marking, sample of the marking, and the “Declaration of the Presence Condition of the Restricted Substances Marking” to apply for replacing certificate(s) from the BSMI or its branches.
These marking requirements are similar to China RoHS, but not identical. The WTO notification includes the document “Proposal for inspection requirements including marking of the presence conditions of the restricted substance on the legal inspection for 6 kinds of IT/AV products” and the template “Declaration of the Presence Condition of the Restricted Substances Marking” (in Chinese).
The TBT notification indicates that the proposed date of adoption is “to be determined”; although the proposal does indicate a 1 May 2017 date by which certificate holders shall prepare documents with respect to the location of the marking, etc.
The final date for comments to the TBT notification is August 31, 2015.
Contact ECD Compliance, for additional information on the proposed regulation and services to assess your environmental product compliance requirements, keep you up to date on the impact to your products and markets and to implement compliance procedures.