i want to learn about RoHS Compliance Definition. It is obligation or opsional for cable.



thanks,

It is depend on your type of cable but nowaday it is obligation.

Generally

The definition and aim of the RoHS directive is quite simple. The RoHS directive aims to restrict certain dangerous substances commonly used in electronic and electronic equipment. Any RoHS compliant component is tested for the presence of Lead (Pb), Cadmium (Cd), Mercury (Hg), Hexavalent chromium (Hex-Cr), Polybrominated biphenyls (PBB), and Polybrominated diphenyl ethers (PBDE). For Cadmium and Hexavalent chromium, there must be less than 0.01% of the substance by weight at raw homogeneous materials level. For Lead, PBB, and PBDE, there must be no more than 0.1% of the material, when calculated by weight at raw homogeneous materials. Any RoHS compliant component must have 100 ppm or less of mercury and the mercury must not have been intentionally added to the component. In the EU, some military and medical equipment are exempt from RoHS compliance.

RoHS Training Seems to Be Effective in UK

Chris Smith heads the National Weights and Measures Laboratory (NWML), which is in charge of RoHS enforcement in the UK. Smith recently told the media 99 percent of products examined by the NWML are meeting 99 percent of the requirements. This means that since the RoHS directive came into action in the EU in July 2006, the majority of companies are complying with the directive.

According to Smith, most companies who have not been compliant have become so after only some RoHS training. Only a few firms have had to be prosecuted in order to ensure compliance. Smith notes that the most common faults in UK companies tend to be higher-than-permitted levels of hexavalent chromium and unacceptably high levels of lead in plastic components. NWML determines RoHS compliance using documentation and a screening system which includes the use of a metal analyzer as well as other equipment.

RoHS Means Differences in China

EU RoHS vs China RoHS

Although RoHS training and compliance seems to be a success story in the EU, in China it is still news. The first phase of China RoHS compliance – a phase which involves "mark and disclosure" processes for products – was implemented in February 2007. China's Ministry of Information Industry (MII) is defining RoHS compliance in that country and may head the RoHS compliance testing. So far, the MII has not mentioned any exemptions for RoHS compliance, which means that medical and military equipment may also be tested and forced to comply with RoHS definitions.

It looks as though China will define RoHS compliance differently than the EU. China requires all components and products that meet RoHS compliance regulations to carry a logo – a green "e" in a circle. Products and components which fail to meet RoHS compliance regulations will carry a different logo and are required to clearly list all the hazardous substances in the product. Each product not meeting RoHS compliance definitions also needs to list its Environmental Protection Use Period (EPUP), or the number of years that the hazardous substances will not leak or cause any damage or injury (under normal use of the product).

So far, it is unknown how RoHS compliance will work in China, although some have voiced concern about the lack of RoHS training and the lack of warning tech companies have had about new regulations. The sheer size of the Chinese tech market may also make compliance testing and enforcement challenging.

RoHS specifies maximum levels for the following six restricted materials:

    Lead (Pb): < 1000 ppm
    Mercury (Hg): < 100 ppm
    Cadmium (Cd): < 100 ppm
    Hexavalent Chromium: (Cr VI) < 1000 ppm
    Polybrominated Biphenyls (PBB): < 1000 ppm
    Polybrominated Diphenyl Ethers (PBDE): < 1000 ppm

WEEE stands for Waste from Electrical and Electronic Equipment. WEEE Directive 2002/96/EC mandates the treatment, recovery and recycling of electric and electronic equipment (90% ends up in landfills). All applicable products in the EU market must pass WEEE compliance and carry the "Wheelie Bin" sticker.

China is difference,

China RoHS from wiki

China RoHS (Restriction of Hazardous Substances), officially known as Administrative Measure on the Control of Pollution Caused by Electronic Information Products[1] is a Chinese government regulation to control certain materials, including lead.

All items shipped to China now have to be marked as to whether the items contained in the box are compliant or non-compliant. The Electronic Information Products (EIP) logo or other label is used to mark parts and assemblies that do not contain unacceptable amounts of substances identified by the regulations, and that are environmentally safe. Units that do contain hazardous substances are marked with the EIP logo including an Environment Friendly Use Period (EFUP) value in years.

China RoHS banned substances

There are currently six substances considered environmentally hazardous by the China RoHS directive.

    Lead
    Mercury
    Cadmium
    Hexavalent Chromium
    Polybrominated Biphenyls
    Polybrominated Diphenyl Ethers



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32002L0095

Directive 2002/95/EC of the European Parliament and of the Council of 27 January 2003 on the restriction of the use of certain hazardous substances in electrical and electronic equipment

Official Journal L 037 , 13/02/2003 P. 0019 - 0023

Directive 2002/95/EC of the European Parliament and of the Council

of 27 January 2003

on the restriction of the use of certain hazardous substances in electrical and electronic equipment

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,

Having regard to the Treaty establishing the European Community, and in particular Article 95 thereof,

Having regard to the proposal from the Commission(1),

Having regard to the opinion of the Economic and Social Committee(2),

Having regard to the opinion of the Committee of Regions(3),

Acting in accordance with the procedure laid down in Article 251 of the Treaty in the light of the joint text approved by the Conciliation Committee on 8 November 2002(4),

Whereas:

(1) The disparities between the laws or administrative measures adopted by the Member States as regards the restriction of the use of hazardous substances in electrical and electronic equipment could create barriers to trade and distort competition in the Community and may thereby have a direct impact on the establishment and functioning of the internal market. It therefore appears necessary to approximate the laws of the Member States in this field and to contribute to the protection of human health and the environmentally sound recovery and disposal of waste electrical and electronic equipment.

(2) The European Council at its meeting in Nice on 7, 8 and 9 December 2000 endorsed the Council Resolution of 4 December 2000 on the precautionary principle.

(3) The Commission Communication of 30 July 1996 on the review of the Community strategy for waste management stresses the need to reduce the content of hazardous substances in waste and points out the potential benefits of Community-wide rules limiting the presence of such substances in products and in production processes.

(4) The Council Resolution of 25 January 1988 on a Community action programme to combat environmental pollution by cadmium(5) invites the Commission to pursue without delay the development of specific measures for such a programme. Human health also has to be protected and an overall strategy that in particular restricts the use of cadmium and stimulates research into substitutes should therefore be implemented. The Resolution stresses that the use of cadmium should be limited to cases where suitable and safer alternatives do not exist.

(5) The available evidence indicates that measures on the collection, treatment, recycling and disposal of waste electrical and electronic equipment (WEEE) as set out in Directive 2002/96/EC of 27 January 2003 of the European Parliament and of the Council on waste electrical and electronic equipment(6) are necessary to reduce the waste management problems linked to the heavy metals concerned and the flame retardants concerned. In spite of those measures, however, significant parts of WEEE will continue to be found in the current disposal routes. Even if WEEE were collected separately and submitted to recycling processes, its content of mercury, cadmium, lead, chromium VI, PBB and PBDE would be likely to pose risks to health or the environment.

(6) Taking into account technical and economic feasibility, the most effective way of ensuring the significant reduction of risks to health and the environment relating to those substances which can achieve the chosen level of protection in the Community is the substitution of those substances in electrical and electronic equipment by safe or safer materials. Restricting the use of these hazardous substances is likely to enhance the possibilities and economic profitability of recycling of WEEE and decrease the negative health impact on workers in recycling plants.

(7) The substances covered by this Directive are scientifically well researched and evaluated and have been subject to different measures both at Community and at national level.

( The measures provided for in this Directive take into account existing international guidelines and recommendations and are based on an assessment of available scientific and technical information. The measures are necessary to achieve the chosen level of protection of human and animal health and the environment, having regard to the risks which the absence of measures would be likely to create in the Community. The measures should be kept under review and, if necessary, adjusted to take account of available technical and scientific information.

(9) This Directive should apply without prejudice to Community legislation on safety and health requirements and specific Community waste management legislation, in particular Council Directive 91/157/EEC of 18 March 1991 on batteries and accumulators containing certain dangerous substances(7).

(10) The technical development of electrical and electronic equipment without heavy metals, PBDE and PBB should be taken into account. As soon as scientific evidence is available and taking into account the precautionary principle, the prohibition of other hazardous substances and their substitution by more environmentally friendly alternatives which ensure at least the same level of protection of consumers should be examined.

(11) Exemptions from the substitution requirement should be permitted if substitution is not possible from the scientific and technical point of view or if the negative environmental or health impacts caused by substitution are likely to outweigh the human and environmental benefits of the substitution. Substitution of the hazardous substances in electrical and electronic equipment should also be carried out in a way so as to be compatible with the health and safety of users of electrical and electronic equipment (EEE).

(12) As product reuse, refurbishment and extension of lifetime are beneficial, spare parts need to be available.

(13) The adaptation to scientific and technical progress of the exemptions from the requirements concerning phasing out and prohibition of hazardous substances should be effected by the Commission under a committee procedure.

(14) The measures necessary for the implementation of this Directive should be adopted in accordance with Council Decision 1999/468/EC of 28 June 1999 laying down the procedures for the exercise of implementing powers conferred on the Commission(,

HAVE ADOPTED THIS DIRECTIVE:

Article 1

Objectives

The purpose of this Directive is to approximate the laws of the Member States on the restrictions of the use of hazardous substances in electrical and electronic equipment and to contribute to the protection of human health and the environmentally sound recovery and disposal of waste electrical and electronic equipment.

Article 2

Scope

1. Without prejudice to Article 6, this Directive shall apply to electrical and electronic equipment falling under the categories 1, 2, 3, 4, 5, 6, 7 and 10 set out in Annex IA to Directive No 2002/96/EC (WEEE) and to electric light bulbs, and luminaires in households.

2. This Directive shall apply without prejudice to Community legislation on safety and health requirements and specific Community waste management legislation.

3. This Directive does not apply to spare parts for the repair, or to the reuse, of electrical and electronic equipment put on the market before 1 July 2006.

Article 3

Definitions

For the purposes of this Directive, the following definitions shall apply:

(a) "electrical and electronic equipment" or "EEE" means equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields falling under the categories set out in Annex IA to Directive 2002/96/EC (WEEE) and designed for use with a voltage rating not exceeding 1000 volts for alternating current and 1500 volts for direct current;

(b) "producer" means any person who, irrespective of the selling technique used, including by means of distance communication according to Directive 97/7/EC of the European Parliament and of the Council of 20 May 1997 on the protection of consumers in respect of distance contracts(9):

(i) manufactures and sells electrical and electronic equipment under his own brand;

(ii) resells under his own brand equipment produced by other suppliers, a reseller not being regarded as the "producer" if the brand of the producer appears on the equipment, as provided for in subpoint (i); or

(iii) imports or exports electrical and electronic equipment on a professional basis into a Member State.

Whoever exclusively provides financing under or pursuant to any finance agreement shall not be deemed a "producer" unless he also acts as a producer within the meaning of subpoints (i) to (iii).

Article 4

Prevention

1. Member States shall ensure that, from 1 July 2006, new electrical and electronic equipment put on the market does not contain lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE). National measures restricting or prohibiting the use of these substances in electrical and electronic equipment which were adopted in line with Community legislation before the adoption of this Directive may be maintained until 1 July 2006.

2. Paragraph 1 shall not apply to the applications listed in the Annex.

3. On the basis of a proposal from the Commission, the European Parliament and the Council shall decide, as soon as scientific evidence is available, and in accordance with the principles on chemicals policy as laid down in the Sixth Community Environment Action Programme, on the prohibition of other hazardous substances and the substitution thereof by more environment-friendly alternatives which ensure at least the same level of protection for consumers.

Article 5

Adaptation to scientific and technical progress

1. Any amendments which are necessary in order to adapt the Annex to scientific and technical progress for the following purposes shall be adopted in accordance with the procedure referred to in Article 7(2):

(a) establishing, as necessary, maximum concentration values up to which the presence of the substances referred to in Article 4(1) in specific materials and components of electrical and electronic equipment shall be tolerated;

(b) exempting materials and components of electrical and electronic equipment from Article 4(1) if their elimination or substitution via design changes or materials and components which do not require any of the materials or substances referred to therein is technically or scientifically impracticable, or where the negative environmental, health and/or consumer safety impacts caused by substitution are likely to outweigh the environmental, health and/or consumer safety benefits thereof;

(c) carrying out a review of each exemption in the Annex at least every four years or four years after an item is added to the list with the aim of considering deletion of materials and components of electrical and electronic equipment from the Annex if their elimination or substitution via design changes or materials and components which do not require any of the materials or substances referred to in Article 4(1) is technically or scientifically possible, provided that the negative environmental, health and/or consumer safety impacts caused by substitution do not outweigh the possible environmental, health and/or consumer safety benefits thereof.

2. Before the Annex is amended pursuant to paragraph 1, the Commission shall inter alia consult producers of electrical and electronic equipment, recyclers, treatment operators, environmental organisations and employee and consumer associations. Comments shall be forwarded to the Committee referred to in Article 7(1). The Commission shall provide an account of the information it receives.

Article 6

Review

Before 13 February 2005, the Commission shall review the measures provided for in this Directive to take into account, as necessary, new scientific evidence.

In particular the Commission shall, by that date, present proposals for including in the scope of this Directive equipment which falls under categories 8 and 9 set out in Annex IA to Directive 2002/96/EC (WEEE).

The Commission shall also study the need to adapt the list of substances of Article 4(1), on the basis of scientific facts and taking the precautionary principle into account, and present proposals to the European Parliament and Council for such adaptations, if appropriate.

Particular attention shall be paid during the review to the impact on the environment and on human health of other hazardous substances and materials used in electrical and electronic equipment. The Commission shall examine the feasibility of replacing such substances and materials and shall present proposals to the European Parliament and to the Council in order to extend the scope of Article 4, as appropriate.

Article 7

Committee

1. The Commission shall be assisted by the Committee set up by Article 18 of Council Directive 75/442/EEC(10).

2. Where reference is made to this paragraph, Articles 5 and 7 of Decision 1999/468/EC shall apply, having regard to Article 8 thereof.

The period provided for in Article 5(6) of Decision 1999/468/EC shall be set at three months.

3. The Committee shall adopt its rules of procedure.

Article 8

Penalties

Member States shall determine penalties applicable to breaches of the national provisions adopted pursuant to this Directive. The penalties thus provided for shall be effective, proportionate and dissuasive.

Article 9

Transposition

1. Member States shall bring into force the laws, regulations and administrative provisions necessary to comply with this Directive before 13 August 2004. They shall immediately inform the Commission thereof.

When Member States adopt those measures, they shall contain a reference to this Directive or be accompanied by such a reference on the occasion of their official publication. The methods of making such a reference shall be laid down by the Member States.

2. Member States shall communicate to the Commission the text of all laws, regulations and administrative provisions adopted in the field covered by this Directive.

Article 10

Entry into force

This Directive shall enter into force on the day of its publication in the Official Journal of the European Union.

Article 11

Addressees

This Directive is addressed to the Member States.

Done at Brussels, 27 January 2003.

For the European Parliament

The President

P. Cox

For the Council

The President

G. Drys

(1) OJ C 365 E, 19.12.2000, p. 195 and OJ C 240 E, 28.8.2001, p. 303.

(2) OJ C 116, 20.4.2001, p. 38.

(3) OJ C 148, 18.5.2001, p. 1.

(4) Opinion of the European Parliament of 15 May 2001 (OJ C 34 E, 7.2.2002, p. 109), Council Common Position of 4 December 2001 (OJ C 90 E, 16.4.2002, p. 12) and Decision of the European Parliament of 10 April 2002 (not yet published in the Official Journal). Decision of the European Parliament of 18 December 2002 and Decision of the Council of 16 December 2002.

(5) OJ C 30, 4.2.1988, p. 1.

(6) See page 24 of this Official Journal.

(7) OJ L 78, 26.3.1991, p. 38. Directive as amended by Commission Directive 98/101/EC (OJ L 1, 5.1.1999, p. 1).

( OJ L 184, 17.7.1999, p. 23.

(9) OJ L 144, 4.6.1997, p. 19. Directive as amended by Directive 2002/65/EC (L 271, 9.10.2002, p. 16).

(10) OJ L 194, 25.7.1975, p. 39.

ANNEX

Applications of lead, mercury, cadmium and hexavalent chromium, which are exempted from the requirements of Article 4(1)

1. Mercury in compact fluorescent lamps not exceeding 5 mg per lamp.

2. Mercury in straight fluorescent lamps for general purposes not exceeding:

>TABLE>.

3. Mercury in straight fluorescent lamps for special purposes.

4. Mercury in other lamps not specifically mentioned in this Annex.

5. Lead in glass of cathode ray tubes, electronic components and fluorescent tubes.

6. Lead as an alloying element in steel containing up to 0,35 % lead by weight, aluminium containing up to 0,4 % lead by weight and as a copper alloy containing up to 4 % lead by weight.

7. - Lead in high melting temperature type solders (i.e. tin-lead solder alloys containing more than 85 % lead),

- lead in solders for servers, storage and storage array systems (exemption granted until 2010),

- lead in solders for network infrastructure equipment for switching, signalling, transmission as well as network management for telecommunication,

- lead in electronic ceramic parts (e.g. piezoelectronic devices).

8. Cadmium plating except for applications banned under Directive 91/338/EEC(1) amending Directive 76/769/EEC(2) relating to restrictions on the marketing and use of certain dangerous substances and preparations.

9. Hexavalent chromium as an anti-corrosion of the carbon steel cooling system in absorption refrigerators.

10. Within the procedure referred to in Article 7(2), the Commission shall evaluate the applications for:

- Deca BDE,

- mercury in straight fluorescent lamps for special purposes,

- lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signalling, transmission as well as network management for telecommunications (with a view to setting a specific time limit for this exemption), and

- light bulbs,

as a matter of priority in order to establish as soon as possible whether these items are to be amended accordingly.

(1) OJ L 186, 12.7.1991, p. 59.

(2) OJ L 262, 27.9.1976, p. 201.


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alla i added picture your topic.

RoHS 2 and what it means – by Voltimum

Inadequately treated e-waste poses environmental and health risks. The original RoHS Directive (2002/95/EC), concerning the Restriction of Hazardous Substances in Electrical and Electronic Equipment (EEE), was adopted by the EU in February 2003 and brought into force 1st of July 2006 to limit the concentrations of hazardous substances found in EEE. This is because they are harmful to the environment, especially when - as in the past especially - they were often found in EEE that was dumped in landfills at the end of life.

Since 1st July 2006 it has been unlawful to place any new EEE on the EU market containing more than certain permitted levels of lead, mercury, hexavalent chromium, cadmium, polybrominated biphenyls and polybrominated diphenyl ethers.

Now, the RoHS Directive has been re-cast to become Directive 2011/65/EU (RoHS II), and Member States now have 18 months to transpose the new rules. Here, James Hunt explains the basics of it and how it differs from the previous incarnation of the RoHS directive:

Many companies seem not to be aware of RoHS II's scope, the obligations of distributors and the associated sample testing requirements. The RoHS Directive covers a broad spectrum of products, including complete electrical and electronic products as well as individual parts, raw materials - and also packaging.
Closely related to the Waste from Electrical and Electronic Equipment Directive (2002/96/EC - WEEE) the RoHS Directive regulates hazardous substances in EEE while WEEE regulates the disposal of that EEE.

About RoHS II:

In December 2008 the EU Commission issued its proposal for a re-cast of the existing ROHS Directive in order to tackle the fast increasing waste stream of such products. The reasons for the re-cast are to increase the amount of e-waste that is properly treated and to reduce the volume being disposed. Other important aims are to ensure coherence with newer policies and legislation (e.g. chemicals and the new legislative framework for the marketing of products in the EU), as well as to reduce administrative burdens. RoHS II was published in the Official Journal on 1 July 2011.

RoHS II is an updated version of RoHS. While there are no additions to the six restricted substances, so that it will continue to ban lead, mercury, cadmium, hexavalent chromium and the flame retardants Polybrominated biphenyls (PBB) and Polybrominated diphenyl ethers (PBDE), the ban on these chemicals in EEE has now been extended to a much wider range of products. Where there are alternatives available it is not acceptable to expose people or the planet to dangerous substances.

RoHS2 will work closely with REACH. Controlled substances such as HBCDD, DEHP, BBP and DBP by REACH might also be added to RoHS II list in the future.

The previous RoHS Directive covered several categories of electrical and electronic equipment including household appliances, IT and consumer equipment, but it has now been extended to all electronic equipment, cables and spare parts. Exemptions can still be granted in cases where no satisfactory alternative is available. RoHS II will, therefore, improve the safety of a great many other devices, including thermostats, medical devices and control panels, and will prevent the release of such hazardous substances into the environment. In this way, RoHS II will improve consumer safety, health and environmental protection, and the way in which the rules will work at national level. The list of banned substances will be reviewed on a regular basis.

The important parts of RoHS II are as follows:

A gradual extension of the rules to all EEE, cables and spare parts, with a view to full compliance by 2019

A review of the list of banned substances by July 2014, and periodically afterwards

Clearer and more transparent rules for granting exemptions from the substance ban

Improved coherence with the REACH Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals

Clarification of important definitions

CE marking denoting compliance with European norms reserved for electronic products that also respect RoHS requirements.
Because of this significant extension in scope, RoHS allows transition periods of up to eight years for the new products affected by the rules.

RoHS II exemptions:

RoHS II exempts various types of electrical and electronic equipment. One such is solar photovoltaic (solar PV) panels, which are exempt to help the EU reach its renewable energy and energy efficiency objectives. Others include equipment essential to the security and protection of Member States, including arms, munitions and war materials intended specifically for military use, equipment designed to be sent into space, large scale stationary industrial tools and similar. Besides these general exempt EEE, there are certain specific exemptions of restricted substances in specific applications.

CE marking:

RoHS II is a CE Mark Directive, so CE marking must be fixed to all finished products, as per Module A of Annex II of 768/2008/CE. The responsibility is now shared between manufacturers and importers and distributors. CE declaration remains the manufacturer's obligation, while the release of compliant products onto the EU market becomes the responsibility of importers and distributors.

Note that the WEEE Directive has also been re-cast - see elsewhere in this VoltiTECH.

What does it mean for electrical contractors' and installers' working practices? Well, not a great deal (apart from ensuring that you use properly compliant non-counterfeit CE marked EEE at all times), but it is important to know the rules. In some cases, you will also be involved in returning EEE for proper disposal at end of life, but that is the province of the closely related WEEE Directive - see elsewhere in this VoltiTECH. Finally, RoHS 11 will provide a better environment for yourselves, your families and your working environment.

For information, go to:
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And:
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Also see Alastair Ramsay's article elsewhere in this VoltiTECH.

RoHS Compliance Definition

The definition and aim of the RoHS directive is quite simple. The RoHS directive aims to restrict certain dangerous substances commonly used in electronic and electronic equipment. Any RoHS compliant component is tested for the presence of Lead (Pb), Cadmium (Cd), Mercury (Hg), Hexavalent chromium (Hex-Cr), Polybrominated biphenyls (PBB), and Polybrominated diphenyl ethers (PBDE). For Cadmium and Hexavalent chromium, there must be less than 0.01% of the substance by weight at raw homogeneous materials level. For Lead, PBB, and PBDE, there must be no more than 0.1% of the material, when calculated by weight at raw homogeneous materials. Any RoHS compliant component must have 100 ppm or less of mercury and the mercury must not have been intentionally added to the component. In the EU, some military and medical equipment are exempt from RoHS compliance.

RoHS Training Seems to Be Effective in UK

Chris Smith heads the National Weights and Measures Laboratory (NWML), which is in charge of RoHS enforcement in the UK. Smith recently told the media 99 percent of products examined by the NWML are meeting 99 percent of the requirements. This means that since the RoHS directive came into action in the EU in July 2006, the majority of companies are complying with the directive.

According to Smith, most companies who have not been compliant have become so after only some RoHS training. Only a few firms have had to be prosecuted in order to ensure compliance. Smith notes that the most common faults in UK companies tend to be higher-than-permitted levels of hexavalent chromium and unacceptably high levels of lead in plastic components. NWML determines RoHS compliance using documentation and a screening system which includes the use of a metal analyzer as well as other equipment.

RoHS Means Differences in China

Although RoHS training and compliance seems to be a success story in the EU, in China it is still news. The first phase of China RoHS compliance – a phase which involves "mark and disclosure" processes for products – was implemented in February 2007. China's Ministry of Information Industry (MII) is defining RoHS compliance in that country and may head the RoHS compliance testing. So far, the MII has not mentioned any exemptions for RoHS compliance, which means that medical and military equipment may also be tested and forced to comply with RoHS definitions.

It looks as though China will define RoHS compliance differently than the EU. China requires all components and products that meet RoHS compliance regulations to carry a logo – a green "e" in a circle. Products and components which fail to meet RoHS compliance regulations will carry a different logo and are required to clearly list all the hazardous substances in the product. Each product not meeting RoHS compliance definitions also needs to list its Environmental Protection Use Period (EPUP), or the number of years that the hazardous substances will not leak or cause any damage or injury (under normal use of the product).

So far, it is unknown how RoHS compliance will work in China, although some have voiced concern about the lack of RoHS training and the lack of warning tech companies have had about new regulations. The sheer size of the Chinese tech market may also make compliance testing and enforcement challenging.

EU RoHS vs. China RoHS

In 2006, the Chinese Ministry of Information Industry circulated the long-awaited "Management Methods for Controlling Pollution Caused by Electronic Information Products Regulation" (usually called "China RoHS"). Manufacturers, importers, and some retailers will have to adhere to the China RoHS regulations after March 2007. The China RoHS is similar to the EU RoHS in that it restricts certain hazardous substances in consumer products and in packaging materials.

However, the China RoHS is in fact quite different from its EU counterpart in a few significant ways. In fact, China RoHS was developed entirely separately from the EU regulations and in many ways is stricter. China RoHS includes automotive medical devices, manufacturing equipment, components, electronics, radar equipment, certain raw materials, and packaging materials. However, China RoHS does not include home appliances and toys within its regulations (although components of these products might have to comply with China RoHS).

China RoHS will be implemented in a few phases. The first phase, which begins in 2007, will require companies to simply indicate on product labels whether a product contain specific restricted materials. The second phase will restrict specific substances in products. However, the exact timeframe for this second phase has not yet been revealed. So far, there are four types of marks or labels required on products:

    A label indicating whether any of the six hazardous substances – lead, mercury, cadmium, hexavalent chromium, PBB, or PBDE – are present in the product. If they are present, another label is needed which indicates the "Environment-Friendly Use Period" (EFUP) – the date until which the hazardous substances will not leak or cause environmental pollution.
    A table in the manual, packaging, or documentation of the product that shows which hazardous materials are in the product and which components contain the materials. This is a much stricter requirement than the EU RoHS and may require additional testing and product research to determine.
    The type of packaging material used needs to be described on the outside packaging.
    If a EFUP label is needed, a date of manufacture must be clearly marked on the product.

There are other differences between the EU and China RoHS regulations as well. The China regulations make everyone in the supply chain responsible for non-compliance, while only importers, manufacturers and some retailers are subject to penalties in the EU version. The China RoHS also requires more disclosure – the Certificates of Compliance from suppliers that are adequate under EU regulations may not be enough. If you ship affected products into China your product will need to be tested by one of the approved labs in China and your product will need CCC accreditation (China Compulsory Certification) as well. The testing for compliance might be very extensive, too – you may need to test not only every component of your product, but also the materials in every component.

Some companies are wondering how strictly China RoHS will be enforced. China, after all, does not have an outstanding record of enforcing anti-counterfeiting and intellectual property laws. It would be dangerous for companies to assume that China RoHS is in letter only. China actually enforces its environmental laws quite strictly and the fact that China RoHS is stricter in many ways that its EU counterpart suggests that China RoHS will in fact be enforced quite closely.

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