China RoHS Regulation

China RoHS refers to the directive published by China's Ministry of Information Industry (MII) on March 1, 2006 and titled "Management Methods for Controlling Pollution Caused by Electronic Information Products Regulation."

China RoHS overview

China RoHS, which has an enforcement date of March 1, 2007, establishes a broad regulatory framework for substance restrictions, pre-market certifications, labeling, and information disclosure requirements.

These requirements affect a wide range of products, parts, and components defined as Electronic Information Products (EIP) sold and imported within the People's Republic of China.

Labeling requirements

To satisfy China RoHS labeling requirements, all in-scope products must include labels indicating presence of the restricted substances and, if toxic substances are present, period of safe usage:

Contains no toxic substances Contains toxic substances. Safe use period is 5 years.
Contains no toxic
substances.		 Contains toxic substances.
Safe use period is 5 years.

China RoHS vs. EU RoHS

There are a number of significant differences between the China RoHS and EU RoHS Directives which are causing major concerns to companies pioneering China-specific compliance activities.

China RoHS not only puts tighter requirements on the types of product classes required to comply and requires product pre-certification prior to sale, but it is also reviewed annually (unlike the EU RoHS Directive which is reviewed every four years) and has other elements that are much more stringent than the original RoHS Directive:

  • Labeling and marking: Products in scope must provide labels and marking indicating restricted substances and their location within the product, packaging material content, safe use period, and recyclability information.
  • Restricted substances: To the six EU RoHS restricted substances, China adds "other toxic and harmful substances" with no further definition. Certificates of compliance can no longer be used as the minimum standard for product due diligence.
  • Exemptions: China RoHS has not yet defined any formal exemptions. The Product Catalog, which will define products in scope, will also describe any applicable exemptions.
  • Responsibilities and penalties: Unlike the EU RoHS Directive, the China RoHS law affects the entire supply chain, including manufacturers, distributors, importers, and retailers any of whom may be penalized for non-compliance.

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