China RoHS Update Up for Public Consultation until August 19

On July 16, 2010, the Chinese government’s Ministry of Industry and Information Technology (MIIT) issued a proposed update to the “Draft Measures for the Pollution Control of Electrical and Electronic Product,” the so-called “China RoHS,” for public consultation until August 19, 2010.

One key feature is that they have changed “Electronic Information Products” to “Electronic and Electrical Products.” They have not defined the new scope yet. Could this be an indication of a desire to more closely align the scope with EU RoHS? Hard to know.

The proposed updates would change the coverage of products by modifying the definition from “Electronic Information Product” to “Electrical and Electronic Product.” The new definition of “Electrical and Electronic Product” is defined in Article 3, as “equipment or its accessories which work with a voltage rating not exceeding 1500 volts for direct current and 1,000 volts for alternating current.”

If the new definition of EEP is adopted, all EEP would be immediately subject to China RoHS because no product categories would be defined. The current China RoHS identifies covered products in a Catalogue. The new definition of EEP is an even broader coverage of regulated products than that which is currently discussed in the EU Recast proposal.

The proposed updates to China RoHS would not change or add to the list of hazardous substances. The six hazardous substances would remain the same, i.e., lead, mercury, cadmium, hexavalent chromium, PBB and PBDE.

The proposed updates to China RoHS would change the title of the Catalogue from “Key Management Catalogue for the Control of Pollution by Electronic Information Product” to “Standard Product Catalogue for the Pollution Control of Electrical and Electronic Product.” This would require some changes to the draft First List of Controlled Electronic Information Products that was released on September 29, 2009. If an electrical and electronic product is listed in the Catalogue, the product is immediately subject to certification, stricter customs clearance and non-use of hazardous substances with some transitional time.

The proposed changes to China RoHS would provide a clear set of requirements for the design, production, packaging and labeling of electrical and electronic products. However, if the Chinese regulatory authorities themselves are not aware of what products could be covered by the new definition of “Electrical and Electronic Product,” the proposed updates to China RoHS would have a significant disruptive impact on industries.

One Comment

  1. Posted July 27, 2010 at 5:11 pm | Permalink

    An English translation is available for sale at

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