China's RoHS-like ban on hazardous substances has hit the electronics industry with a loud, confusing thud last fall, leaving scores of unanswered questions. Even exemptions are unclear. China hasn't yet released its catalog of exemptions even though the directive's deadline matches the European Union's (EU) impending July 1, 2006 date.
The labeling rules are unwieldy. OEMs need to include country of origin, estimated "safe-use life" dates, a list of materials in the package, the composition of the box and packaging materials, even the chemicals used in the ink on the box. The labeling rules alone suggest companies may have to design products specifically for China.
China reserves the right to add new materials to the six restricted in the EU's directive and the law doesn't spell out the permissible levels of the banned substances. China's directive can be reviewed for possible revision every year, contrasting with the EU schedule of every three years.
Perhaps the most unsettling provision is the rule that insists products must be tested for compliance before they hit China's shores. Components and products must have a compliance certificate from state authorities before they enter China, so they will be inspected at the port of entry. Many OEMs view China's RoHS law as an obstructive trade practice that gives preferential treatment to China's domestic OEMs which will be able to comply with the law much more easily.