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Roland Sommer Explains the Differences Between EU RoHS and China RoHS

Rob Spiegel -- Design News, April 5, 2007

The road to compliance with China RoHS is complicated. Being compliant with the European Union’s RoHS is not sufficient to guarantee compliance with China RoHS. In this Q&A, Roland Sommer, managing director of RoHS-International in New Zealand, explains some of the differences between EU RoHS and China RoHS. Here he lists the main differences in stage one. This is the second of a three-part interview with Roland Sommer.

Design News: What other differences are there between EU RoHS and China RoHS?

Roland: Sommer: The similarities are that the six banned substances are the same, and that DECA BDE is excluded from both China and EU RoHS. The EIP-A material category is the same as the EU Homogeneous material definition (but China RoHS has 2 additional classifications). There are very few other similarities. “China RoHS” is a term coined by the western world. The Chinese legislation does not use the term RoHS at all, the legislation is titled “Measures for the Administration of Pollution Control of Electronic Information Products.” Undoubtedly "China RoHS" is heavily based on EU RoHS but apart from the targeted substances and elements there is very little else in common. The main differences for stage one are:

China RoHS:

Requires labeling
Requires date of manufacture
Disclosure, not prohibition (at present)
Scope is different
No exemptions apart from DECA BDE
Definition of Homogeneous material is different
Enforcement will be different
Batteries are in scope
Packaging is in scope

Stage two will require testing and certification for all products listed in the (yet to be released) Catalogue.

Due to the complexities of China RoHS and the level of confusion with the information available, RoHS-International has developed a set of China RoHS Guidance Notes. These are similar to those prepared by the DTI in the UK for EU RoHS. The Guidance Notes are 26 pages long and have proved to be very popular since their release in December 2006, especially with the larger multinational corporations. The China RoHS Guidance Notes are available for download from www.rohs-international.com for a small charge.

This is part two of a three-part article. Part three will look at details of the China RoHS declarations tables.

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