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Consultation on China RoHS Proposal ends on 17 June 2015

Young & Global Partners reports that on 18 May 2015, the Measures on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Products (电器电子产品有害物质限制使用管理办法) was re-published by the Ministry of Industry and Information Technology for public consultation, which will end on 17 June 2015. The proposal Measures of 18 May 2015 is another version of the China RoHS proposal after the 4 June 2012 China RoHS II proposal (电子电气产品污染控制管理办法). 

The draft China RoHS proposal of 18 May 2015 would be applicable to the production, sale, and import of electrical and electronic products, and, accordingly, there would not be an exclusion for products that are intended for export (presumably to help ensure that exported products meet the RoHS restrictions imposed by other countries).

The scope of products would be expanded to "electrical and electronic products" excluding power generation, transmission and distribution equipment. The definition of "Electrical and electronic products" refers to devices and accessory products which function by means of current or electromagnetic fields. The definition utilizes the same voltage limits used by the EU RoHS Directive - rated working electrical voltages of no more than 1500 volts direct current and 1000 volts alternating current.

Hazardous substances are defined as the six original RoHS substances, with a seventh entry for other hazardous substances to restrict further substances.

The marking and labelling obligations (e.g., "environmental protection use period") and the table identifying harmful substances and their location in the product would remain. The requirements for the table of hazardous substances would be expanded with clarification.

A Catalog (
) would list products that are subject to substance restrictions. The catalog would be developed and maintained by the Ministry of Industry and Information Technology (MIIT) in consultation with other departments.

A conformity assessment system would be established for ensuring restricted substance conformity of products that are listed in the compliance management catalog, which would replace the CCC certification.

Packaging for all manufactured or imported electrical and electronic products would have to meet all applicable standards and laws. Manufacturers and importers should adopt the use of materials that are non-hazardous, easily biodegradable and/or facilitate recycling/reuse.

The draft is available from the MIIT (in Chinese) and from YGP ( This e-mail address is being protected from spambots. You need JavaScript enabled to view it ). The public comment period ends June 17, 2015.

The previous China RoHS II proposal of 4 June 2002: a) further clarified the definition on "Electrical and Electronic Equipment" (电子电气产品) by virtually adopting the definition of the EU RoHS Directive; b) clarified the definition of "hazardous substances", e.g., from "lead" to "lead and its compounds"; c) provide more authority to the Ministry of Industry and Information Technology to coordinate implementation of China RoHS issues; d) introduction of "product compliance assessment system" on electrical and electronic equipment; e) The Ministry of Industry and Information Technology and the Certification and Accreditation Administration of China will establish "product compliance assessment system". The revised China RoHS II Proposal of 4 June 2012 is under consultation until 10 July 2012.


EU countries postpone classification of Pb-containing mixtures

A committee of EU member state representatives on REACH has agreed to postpone the adoption of a harmonised classification for lead-containing mixtures. The classification was included in the proposed EU Regulation, known as the seventh adaptation to technical progress (7ATP) of the EU CLP Regulation.

The proposed classification says lead-containing mixtures or materials should be classified as a category 1A reprotoxicant at a specific concentration limit (SCL) of 0.03%. Meeting last week, the representatives agreed to withdraw it, so that the proposed Regulation, implementing the 7ATP, could be voted through. 

The vote on the 7ATP had been postponed at the committee’s last meeting, because some countries want a higher concentration limit that will help the recycling of lead-containing materials.

Further work on the testing methods for calculating lead concentration in alloys still needs to be done, before coming to a solution, Chemical Watch understands. Echa is expected to be tasked with the work.

The classification will now be added to the proposal for the ninth ATP. It is not yet clear when these discussions will start. Metals industry representatives welcomed the postponement. “In the next months, we look forward to supporting the EU’s work to evaluate how bioelution tests can be used for classification of inorganic substances and address the lead-specific concentration limit issue, including its potential impact on downstream applications and metals recycling,” says Guy Thiran, Eurometaux director general.

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