1. CHINA-RoHS
Requirements and Differences
from RoHS 2002/95/EC
The Chinese
Polution Act has been
released on 28. February 2007.
It regulates the use of similar
substances as the European RoHS
guide lines: lead, cadmium,
chromium VI, mercury or PBB/PBDE
polybrominated flame inhibitors.
The
regulation is mainly valid
for manufacturers, importers and
dealers of products that put
products in circulation within
China. The regulation starts in
two steps beginning March 1,
2007. The first step includes
the unique declaration of the
products. The second step
defines the limitation of the
substances and their control.
The requirements of the CHINA-RoHS
differ from the
EU-RoHS in following
subjects.
- China- RoHS does not
allow any exception for
products in the so called
„Electronic Information
Products“ (EIP) group.
- Products for end
customers need to be
labeled. Suppliers need not
provide the mentioned
marking but shall supply to
the purchaser all necessary
information required.
- The limitations of the
restricted substances are
not yet defined. They will
be similar to the limits of
the EU-ROHS but the CHINA-ROHS
does not allow any
exemptions for substances
that don't be conform to the
guide line.
- The packaging materials
of the outermost packaging
shelf have to be marked with
the respective recycling
logos according
GB-18450-2001.
- All information
according to CHINA-RoHS has
to be available in Chinese.
- The CHINA-RoHS
conformity has to be
confirmed by a Chinese
laboratory, while the
conformity with the EU-RoHS
could be assured with self
declaration.
- EIP products shall be
marked with pollution
control logos in accordance
with the standard SJ/T11364-2006
beginning 1. March 2007. The
declaration is different for
products with relevant
substances below the
accepted threshold and the
ones above it. If a product
does not contain any toxic
or hazardous substances it
will be marked with the
green logo (Picture 1). Logo
2( Picture 2) is normally
orange and indicates that
the material contains
certain toxic or hazardous
substances and can be used
safely during its
environmental protection use
period (EFUP). This duration
is given with the figure in
the logo and is counted in
years (e.g. 50 = 50 years
EFUP). Components that are
intended to be used directly
by an end customer need to
be labeled, while component
suppliers do not need to
provide the mentioned
marking but they shall
supply all necessary
information required to the
purchaser.
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Picture
1: CHINA-RoHS conform
(free of toxic or
hazardous substances)
|
Picture 2: not
CHINA-RoHS conform
(contain toxic or
hazardous substances)
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Lead (Pb)
|
0.1 % by weight
|
= |
1000 mg/kg
|
= |
1000 ppm
|
|
Mercury
(Hg) |
0.1 % by
weight |
= |
1000
mg/kg |
= |
1000 ppm
|
|
Cadmium
(Cd) |
0.01 %
by weight |
= |
100
mg/kg |
= |
100 ppm
|
|
Chromium
VI (Cr VI) |
0.1 % by
weight |
= |
1000
mg/kg |
= |
1000 ppm
|
|
PBB,
PBDE |
0.1 % by
weight |
= |
1000
mg/kg |
= |
1000 ppm
|
The prescriptive limits for
the substances will be
presumably be similar to the
thresholds within the EU-RoHS.
The values of each substance
have to be indicated in a list.
They now require the indication
of the exact material content
and testing will be confirmed by
a product related test
certificate.
2.
CO-TEHC ELE
's Approach
CO-TEHC ELE
indexes in Step 1
all CHINA-RoHS conforming
products on the website with the
mentioned logo (Picture 1)
according to internal
information. The symbol links to
this information page for
detailed status information and
product overview lists. The
detailed content information
will be provided for by
product content sheet . They
are available upon customer
request. Content sheets
outermost packaging material
will be marked with the
necessary Recycling symbols.
In Step 2
CO-TEHC ELE
will assure the
availability of the so called.
„Key Product Catalogue“ with the
information about the mentioned
hazardous substances for each
product. An accredited Chinese
laboratory will provide this
information with the independent
product analysis that needs to
be completed.
3. CHINA-RoHS
conformity of
CO-TEHC ELE
Components
3.1 CHINA-RoHS
Declaration
CO-TEHC
ELE.
does not offer
products to the market that are
intended to be used directly by
the end customer. This means
that the products will not have
to be marked nor does the
packaging needs to carry the
pollution control logos. All
required Information will be
assured by indicating the
products within the catalogue on
the web and making product lists
available for download from the
website.
3.2 Explanation of the
RoHS-Product List
CO-TEHC
ELE
provides the
necessary information within the
RoHS product lists on the
website. The list the actual
status of the conformity will be
listed for the various product
lines (Type) by the part
numbers. Beside the CHINA-RoHS
information, the list also
contains the information about
the EU-RoHS conformity. The
lists are the same in structure
for the different product groups
of the CO-TEHC
ELE range and will be
updated frequently by the
product managers. Following is a
sample of the product group
fuses. .
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Compliant :
products
will be
delivered CHINA-RoHS
conform, i.e.
all stock items
of CO-TECH ELE.
companies world
wide are free of
toxic or
hazardous
substances. |
|
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Top
4. RoHS-
Product Lists of CO-TECH ELE.
Components
5.
CO-TECH ELE. Component Material
Declaration
Customers increasingly
want to know what materials a
component is comprised of.
CO-TECH ELE.
has therefore adopted the
Umbrella Specifications
initiative of the German
Electrical & Electronic
Manufacturers' Association (ZVEI
– Zentralverband der deutschen
Elektronikindustrie) and is
making available Product Content
Sheets.
A Product Content Sheet is
being established for all
product types, giving details of
the materials contained in the
component. It confirms that the
product complies with all of the
EU's current material
prohibitions. To achieve this
CO-TECH ELE.
makes use of the official EICTA
materials prohibition list,
which defines the legal
regulations as they relate to
the electronics industry.
In addition, the Product Content
Sheets declare whether a
component is already CHINA-RoHS
and RoHS 2002/95/EC-compliant.
Example of a „Product Content
Sheet“
MST 250
These Product Content Sheets are
confidential and made available
on request only.
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6.
Packaging Declaration
The packaging material is also the subject of the declaration requirement.
The indication is according the
requirements of
GB-18450-200 resp. DIN.
The ECFIC Environmental Group
defined on its meeting on
November 13. 2006 that only the
external packaging material of
EIP products requires to be
labeled (primary and secondary
packaging). The fixing material,
internal packaging material and
filling material need not to be
labeled. The label should be
placed on the external surface.
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