Powering Up for China RoHS

Manufacturers need to be aware of the key differences between EU and China RoHS.

Soon, a year will have passed since Europe's RoHS start date of July 2006. A majority of electronics companies have figured out exactly what they needed to do to meet the EU RoHS Directive, so it's become pretty much business as usual.

However, just as things started to settle on the European front, China RoHS went into effect on March 1, 2007. And just as there was lots of confusion about European RoHS regulations, even more confusion exists in China—some Chinese RoHS standards have only been finalised in the last few months.


The Ministry of Information Industry (MII) of the People's Republic of China has begun issuing standards for their equivalent of the RoHS Directive. The official title of their legislation is "Management Methods for the Control of Pollution from Electronic Information Products," but it's more commonly referred to as China RoHS. Fortunately, this standard covers the same six substances as the EU RoHS Directive: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyl (PBB), and polybrominated diphenyl ether (PBDE). It also uses the same maximum concentration values (MCV) of these substances.

However, China RoHS distinctly differs with EU RoHS on three rather large fronts: 1) Marking 2) No technical exemptions 3) It includes all electronic products


Products such as medical equipment or large-scale stationary electronic tools were entirely exempt from EU RoHS, but nothing electronic seems to be exempt from China RoHS. Standalone power supplies and systems like Power-One's telecom power products also weren't covered by EU RoHS.

However, this didn't prevent many of our customers who wanted to be green from insisting on receiving RoHS-compliant products. Therefore, although the scope of China RoHS expanded to cover all electronics, the industry was headed that way in any event. For instance, it's getting harder and in some cases impossible to find components that have lead (Pb) termination plating.


Because many parts used in today's electronic equipment lack good substitutes for one or more of the six banned substances, the EU RoHS has many exemptions for specific applications. Examples are cadmium for use on electrical contacts found in relays or lead as an alloy in steel, aluminum, or copper. As of last count, there were 28 exemptions, with several more under active consideration. China RoHS, on the other hand, has no list of substance application exemptions.


Per the China Marking Standard SJ/T11364—2006, electronic end products sold into China after March 1, 2007 must show one of two logos.

The first of these logos signifies a product with none of the six substances above the MCV. However, the vast majority of electronic products today use one or more of the EU RoHS Directive exemptions, such as lead in ceramics, high temperature solder, or component glass, and they contain levels of some of the substances in excess of the China RoHS MCVs. As a result, very few electronic products can use this logo.

The second logo is used on a product with one or more of the six substances above the MCV. The number in the centre of the logo is the Environmental Protection Use Period (EPUP) as defined in Paragraph 3.5 of the Marking Standard SJ/T11364- 2006. The EPUP is the time in years for which hazardous/toxic substances will not, under normal operating conditions, leak from the product, or the product will not change in such a way as to result in severe environmental pollution, injury to health, or great damage to property.

Much uncertainty remains as to what number should be used for EPUP. As of this writing, the standard entitled General Rule of Environment-Friendly Use Period Electronic Information Products, which defines how to arrive at this number, is still in draft form. In fact, its appendix, which will provide the some average EPUPs for various product types, has no numbers. Power-One has seen its customers in different industries, from medical equipment and IC production to servers and telecom equipment, picking numbers that range from 10 to 50 years. Power-One decided to use 25 years for the EPUP.


There's a general belief that all electronic products sold in China must have one or the other of the aforementioned logos, but that's not correct. Only end products will require those. The following is from an English translation on the AeA (American Electronics Association) Web site of the China Marking Standard SJ/T11364—2006, Paragraph 4: "With respect to the electronic information products that are purchased for manufacturing. Suppliers need not provide the aforementioned marking, but shall supply to the purchaser all necessary information required for marking. Correspondingly, the purchasers \[in this case\] shall mark the electronic information products they manufacture and the scope of marking shall include that for the electronic information products purchased for manufacturing."

Like most components, most of Power-One's dc-dc converters and ac-dc power supplies are embedded in their customer's product and fit the description of a "product purchased for manufacturing." Thus, Power- One doesn't mark these types of products with an EPUP logo. However, the company's power systems and power-system components, such as rectifiers, controllers, and field replaceable units (FRUs), which includes all of our hot-swap front-end and CompactPCI power supplies, can be sold as standalone items. As such, these products are all marked with the China RoHS EPUP logo.


Another requirement is to provide a Hazardous Substance Disclosure Table with EPUPlabeled products. This table lists a few major parts and subassemblies of the product, and notes where these contain any of the six substances over the MCV. To comply with China RoHS, the table must be in Chinese, but many companies provide these tables in English as well for clarity. A copy of the applicable table can be included in the shipping documents or as a label on these products. Even if a particular product doesn't require an EPUP marking and the table, the end customer will need that information to complete the table for the end product.


Aside from the product marking and documentation, all packaging material must be marked with the applicable Packing Recycling Marks as specified in still another standard: China National Standard GB 18455-2001. Most plastic insert and cardboard carton manufactures currently provide these types of markings. Examples of these markings are:


The product and package marking and related disclosure tables are the only China RoHS requirements that go into effect on March 1, 2007. For the future, China is establishing laboratories throughout the country, where testing of products for RoHS substances will take place. MII also developed a uniform testing standard for these laboratories to use. Once MII starts to publish lists of specific products that must meet the RoHS MCV requirements, known as the Catalogue for Pollution Control in Key Electronic Information Products, these products will have to be tested and certified by the Chinese labs. The first batch of products to be listed in this catalog has yet to be decided; it's expected that this will begin no earlier than October 2007.

Power-One believes that the interpretations of the various China RoHS standards discussed are correct and used them to put together the Power- One RoHS Policy (see http://www.powerone.com/about/rohs.html). However, it's strongly advised that discretion be used and that the actual documents be consulted before deciding on any form of China RoHS policy for your company's designs and products.

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