China RoHS Directive and Product Markings

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For Electrical Products that Export to China
The Chinese government’s Restriction of Hazardous Substances (RoHS) regulation – officially titled “Administrative Measure on the Control of Pollution Caused by Electronic Information Products Regulation” – was developed independently of Europe's RoHS directive, though there is a substantial overlap between the two regulations. Manufacturers exporting products to China should note that some product types covered by China RoHS are not within the scope of European RoHS. For China RoHS requirements, there are no exemptions for labeling compliance, although, for the EU RoHS, exemptions are allowed on products where these dangerous chemicals are deemed essential. Areas that these include are products for use in space, military items, large industrial tools, permanent solar panels, transport vehicles, medical devices, and research and development equipment. 

China RoHS was published in March 2006 and became effective on March 1, 2007 by the Ministry of Industry and Information Technology of China. The most recent version was published on July 17, 2016 which expanded the scope from Electronic Information Products (EIP) to Electrical and Electronic Products (EEP). The requirement is to use a marking to disclose the presence and location of any of the six identified hazardous substances present in a product. Heavy metals such as lead (Pb), cadmium (Cd), and mercury (Hg), as well as brominated flame retardants, phthalates, and chromium, are restricted substances, and only a certain concentration of them is allowed during the manufacture of equipment. The six substances are:

  • Lead (Pb)
  • Cadmium (Cd)
  • Mercury (Hg)
  • Hexavalent chromium (Hex-Cr)
  • Polybrominated biphenyls (PBB)
  • Polybrominated diphenyl ethers (PBDE)

China RoHS as of 2016 does allow for a few technology exemptions, much like Europe’s RoHS directive.

Full Compliance in China RoHS
For China RoHS, the Environmentally Friendly Use Period (EFUP) label or the green ‘e’ label, along with the content and names of hazardous substances must be disclosed either within product instructions or included as a separate document. This details that a product’s electronic components will not leak or mutate suddenly under normal operating conditions and will not result in serious pollution or cause serious bodily injury.

According to the China RoHS articles, products must be labeled accordingly with:

  1. Names, content levels, and recyclability of harmful materials (article 12)
  2. Recyclability (fully, partially, and non-recyclable)  (article 12)
  3. Product safety periods (date range product is safe to use) (article 13)

Mandatory Products
RoHS compliance labels are only to be used on equipment that has passed the requirements set. Under the EU RoHS directive, manufacturers must declare compliance with the CE mark. They differ according to the hazardous material and the concentration used. Mandatory compliance is applicable to the following products as of 2016:

  • Air conditioners
  • Electric water heaters
  • Fax machines
  • Miniature computers
  • Mobile communication devices
  • Monitors
  • Photocopies
  • Printers
  • Refrigerators
  • Telephones
  • Televisions
  • Washing machines

There’s no room for error in design here. Either you will be in compliance or you won’t. Clarion Safety's China RoHS labels conform exactly to the design rules set by the Chinese government’s regulations.

Effective Safety Symbols, Signs, and Labels