Draft China RoHS Catalogue published - October 2009



The Chinese Government published the first draft catalogue of Electronic Information Products that will be subject to China RoHS substance restrictions on the 9th October 2009.


The restrictions should have come into force ten months after adoption of this legislation, unless changes were made. However these have not been adopted as of yet and are likely to be replaced by China RoHS “2”.


  • Scope:
    • The scope is limited to telephones and all types of printers that attach to a computer.  All types of phones are covered including mobiles, landline telephones and networked handsets. 


  • Substances:
    • The restricted substances are the “RoHS 6” covered by EU RoHS – lead, cadmium, mercury, hexavalent chromium, PBB and PBDE (excluding deca-BDE). 


  • Concentration limits:
    • The limits are essentially the same as EU RoHS (0.1% in homogeneous materials except cadmium which is 0.01%) but these limits are also applicable to coatings (including multiple layers as one material) and for very small components (<4mm3 being regarded as one material).


  • Exemptions:
    • A list of exemptions is provided for each of the three product categories in the catalogue (see below).
    • There are ten of the EU RoHS exemptions (similar but not identical wording) that would be permitted for mobile handsets, the same ten for “telephones” and twelve permitted for computer printers (the same ten as for telephones plus one allowing “mercury in straight fluorescent lamps for special purposes” and one for lead in flat fluorescent lamps for LCDs).
    • Mobile handsets and telephones: EU exemptions - 5, 6 (split into 3 covering steel, aluminium and copper alloy) 7a, 7c, 13, 14, 15 and 23.
    • Computer printers: EU exemptions - 3, 5, 6 (split into 3 covering steel, aluminium and copper alloy) 7a, 7c, 13, 14, 15, 20 and 23.


  • Testing:
    • The catalogue refers to SJ/T 11363-2006 (replaced by GB/T 26572-2011) which is the maximum concentration limit standard and this standard in turn refers to SJ/T11365-2006 (replaced by GB/T 26125-2011) for test methods for RoHS analysis so these methods will need to be used to determine whether products comply.


  • Entry into force:
    • These obligations will enter force ten months after the legislation is adopted by the Chinese Government.  However, since these proposals were published there has been no announcement of when they will enter force.


China RoHS “2”


If you thought that progress was slow on the implementation of the so called “China RoHS Catalogue” first published in September 2009 but not yet in force, then now there is “China RoHS 2” to consider. A draft was published in July 2010 and now it is a question of which version of China RoHS will be taken forward and, if so, will the other be rejected (or amended) once and for all?


On 16 July 2010, the Ministry of Industry and Information Technology released the “draft measures for the pollution control of electrical and electronic product” the so called China RoHS2 for public consultation. Among other things, the proposed measures would amend the coverage of products by modifying the definition from “electronic information product-EIP” to “electrical and electronic product-EEE”.


This new definition largely corresponds to EEE in the EU RoHS Directive and within the same scope of designed for use with a voltage rating not exceeding 1500Vdc and 1000Vac. This is a much broader scope than before but, so far, there is no indicative list of products. However, they may not produce one if it is felt that everything electrical is in scope. The six restricted substances remain the same as EU RoHS but one difference is that accessories will be included as well as component parts.


What is apparent is that China RoHS is evolving to cover all electrical and electronic products and not just electronic information products as defined in ‘China RoHS 1’.


Another interesting observation is that there is no mention of the China Compulsory Certification (CCC) in the July 2010 draft. This draft would also change the title of the Catalogue from “key management catalogue for the control of pollution by electronic information product” to read the “standard product catalogue for the pollution control of electrical and electronic product. So the scope of EU RoHS will expand to 11 categories including open scope due to the recast as will China RoHS because of these proposals though, no timescales are known at present.



Please note:

The information contained in this document is of a general nature and is not intended to address the circumstances of any individual or entity. Although we endeavour to provide accurate and timely information, there is no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.


©2012 Premier Farnell plc. Permission is granted for reproduction in whole or in part providing Premier Farnell plc is credited. Written in collaboration with ERA Technology Ltd (www.era.co.uk)
May 2012




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