China RoHS: Still Waiting on Catalogue, Clarity

Not since the European Union implemented its Restriction on Hazardous Substances (RoHS) has a region gotten so much attention from the electronics industry.

For years, the supply chain has been awaiting the details of China's electronics-waste restrictions, known as "China RoHS." Since regulators first announced intentions to limit waste in high-tech equipment, electronics manufacturers have been waiting for clarification and information that identifies restricted products and guidelines for compliance with the environmental directive.

There has been a little progress made on the outline of the mandate, so manufacturers at least know what they are dealing with. Standards have been written, which describe the details needed to comply with China RoHS. For example, the guidelines apply to products imported into China for sale in China and products manufactured in China and sold in China, but exclude those imported into China for re-export or manufacturing of products for export.

China RoHS covers 10 categories of Electronics Information Products (EIPs). These are:

1. Electronic radar products, including air and ship radar
2. Electronic communication products, such as transmitters, navigation, telephones, base stations
3. Broadcast television industry products -- transmitters, camcorders, antennas
4. Computer products -- all types of computers, network equipment, printers, power supplies, CDs, toner cartridges, and the like
5. Household electronic products -- TVs, DVDs, video tapes, CDs, etc.
6. Electronic measuring instrument products -- test equipment, meters, etc.
7. Electronic industry professional products, including production equipment for EIPs, soldering tools, electric and air tools
8. Electronic component products -- passives, PCBs, sensors, connectors, switches, loudspeakers, vacuum tubes, diodes, semiconductors, ICs, electronic circuits, wire and cables, lamps, and batteries
9. Electronic application products -- household equipment (games, microwave ovens), medical devices
10. Electronic professional-use material products, such as the elements used in components, solder, and laminates

All EIPs must be marked to indicate whether any of six substances -- lead, mercury, hexavalent chromium, cadmium, polybrominated biphenyl flame retardants, and polybrominated diphenyl ether flame retardants, which are the same as the EU RoHS -- are present.

The industry has been awaiting a catalogue from China since 2009. It will specifically list the end products that will be subject to restrictions and detail any additional banned substances; define exemptions by products; and determine a timeline for compliance. If a product is not specifically listed in the catalogue, there is no testing or certification required.

China's plan differs from the EU's in a number of ways, according to compliance experts. First, the scope -- the range of products subject to restrictions -- is wider. There will be a list of products that will be given priority for compliance, and enforcement dates may vary by product. And China will require compulsory testing and certification for products listed in the catalogue.

This last item is particularly irksome to industry observers, as China will authorize the testing labs and issue the compliance certificates. The US government and many of the companies that conduct business in China have accused the Chinese government of showing favoritism toward indigenous companies. China's intellectual property rules are more lax than Western nations', and manufacturers fear proprietary information could be revealed during the testing process.

Adding to the confusion around RoHS is China's plan to establish a national electronic information product control certification system. Manufacturers, sellers, and importers of electronics information products will be able to voluntarily apply for a uniform certification of products. It is unclear what the relationship between this voluntary compliance and the upcoming China Compulsory Certification (CCC) phase of RoHS will be.

Additionally, the China RoHS catalogue will focus on finished products, but the voluntary certification can be implemented throughout the whole supply chain, including materials and components. Based on the information so far provided by China, "nobody really has a good interpretation regarding the implications of [the voluntary compliance]," says Michael Kirschner, president of Design Chain Associates LLC (DCA) .

China has not indicated when additional information will be made available.