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Current situation

 

 

The latest update of the Implementation Rules of Voluntary Certification on the Pollution Control of Electronic Information Products was issued on 26 July 2011. Its introduction did not bring with it any big surprises. The China RoHS system is still working and the market force has slowly been moving toward extensive (voluntary) certification of electronics products.

 

 

However, as is shown below, the link between compulsory and voluntary China RoHS certification actually makes the word “voluntary” become “quasi-mandatory” or “mandatory”.

 

 

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Amended China RoHS standards

 

 

The following additional China RoHS standards entered into force in July 2011, although these were not widely publicised.

 

  • Standards on the Requirements of Concentration Limits for Certain Restricted Substances in Electrical and Electronic Products (GB/T 26572-2011); and
  • Standards on the Determination of six Regulated Substances (the EU RoHS substances) in Electrical and Electronic Products (GB/T 26125-2011).

 

These changes are indicative that the China RoHS system is slowly evolving to cover all electrical and electronic products, and not just electronic information products. This brings the legislation more into line with the requirements of the EU RoHS (Recast) Directive.

 

 

 

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What is ahead in 2012?

 

 

Other standards due to be reviewed / approved in 2012 are:

 

 

  • Adoption of Draft Measures for the Pollution Control of Electrical and Electronic Product of 16 July 2010 (“China RoHS 2”);
  • Adoption of the Catalog for the Pollution Control of Electronic Information Products (Batch I) of 29 September 2009;
  • Adoption of Conformity Assessment on the Pollution Control of Electronic Information Products – General Rules (GSJJNZT0002);
  • Adoption of Guidance on Risk Assessment for Substances of Certain Hazardous Substances contained in Electrical and Electronic Equipment (GSJJNZT0003);
  • Adoption of Procedural Requirements on the Management of Pollution Control Process of Electronic Information Products (GSJJNZT0004);
  • Adoption of General Rules on the Screening of Restricted Substances in Electrical and Electronic Equipment - X-ray Fluorescence Spectrometry (SJJNZT4306-2010).

 

Future movements

 

 

2012 may well be the year of significant change for China RoHS. Following considerable delay in decision making by Chinese law-makers, pressure is mounting for steps forward as companies grow more agitated by funding unnecessary compliance costs.

 

At present no concrete dates for these changes have been put forward by the Chinese government, so for the time being at least, companies will have to continue to make crucial business decisions under uncertain terms. 

 

 

**PDF version available below**

 

 

 

 

DaeYoung Park is Managing Partner of Young & Global Partners. YGP is a provider of country-specific and industry-specific EHS (environmental, health and safety) regulatory analysis.

 

 

 

 

 

 

 

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