RoHS in China: Understanding Global Restriction of Hazardous Substances in Electronics

Table of Contents

What Is China RoHS?

RoHS stands for Restriction of Hazardous Substances and restricts the use of several hazardous materials in electronic and electrical equipment. The RoHS directive was originally issued in the European Union but similar laws have been passed in other countries, including China.

China RoHS, also known as Administrative Measure on the Control of Pollution Caused by Electronic Information Products (EIP), works to reduce the negative environmental and health effects of hazardous substances by restricting their use in electronics.

china flag - rohs china

All electronic products sold on the Chinese market, including imported products, must comply with China-RoHS.

China RoHS 1 – The original legislation included six materials deemed to be hazardous to human health and the environment. 

China RoHS 2 – The original legislation was superseded by China RoHS 2 or Restriction of the Use of Hazardous Substances in Electrical and Electronic Products Regulation. China RoHS 2 expanded the scope of the regulation to include more devices, described below.

Which Hazardous Substances Are Restricted by China RoHS?

China RoHS restricts six hazardous materials that must be used below a specific threshold. Each material except cadmium may only be used in amounts lower than 1000ppm. Cadmium’s limit is 100ppm.

The materials include:

Products Restricted by China RoHS

The original China RoHS included only products listed as an Electronic Information Product (EIP).

Any listed products require an assessment of conformity with China RoHS. Products include:

  1. Refrigerators
  2. Air conditioners
  3. Washing machines
  4. Electric water heaters
  5. Printers
  6. Photocopiers
  7. Fax machines
  8. Televisions
  9. Monitors
  10. Microcomputers
  11. Mobile communication devices
  12. Telephones

The passage of China RoHS 2 greatly expanded the scope of the legislation to include any product that falls under the definition of electronics. This expansion worked to bring China RoHS regulations in line with the EU’s RoHS 3, which also expanded the categories of products restricted by RoHS to include all electrical and electronic equipment (EEE).

Compliance with China RoHS

Who is Responsible for Compliance?

Any manufacturer, importer, or distributor of electronic and electrical products sold in China must be compliant with China RoHS. Even small components of EEE, such as cables or other sub-assemblies, must comply with RoHS standards. 

It is the manufacturer’s responsibility to ensure their product complies with China RoHS. 

Steps for Compliance with China RoHS

Manufacturers of electronic products have two options to prove their compliance: self-declaration and/or third-party testing.

  1. Self Declaration: Similar to the EU RoHS directive, companies that manufacture electronic products must create a declaration of conformity. This declaration is a legal document that states the manufacturer has taken all the necessary steps to comply with China RoHS.

The manufacturer must sign the declaration before the product is put on the market. By doing so, the manufacturer takes responsibility for ensuring compliance.

  1. Third-party Testing: The product and its components are tested by an outside laboratory in China. This step also involves a factory inspection. After the testing process, the certification must be approved by an authority agency. The manufacturing company will then receive a China RoHS Certificate that is valid for five years.

The testing process also includes follow-up testing and inspection, often at least once a year, to ensure continued compliance.

China RoHS Labeling Requirements

Products that are compliant with China RoHS are marked with a different label than products that do not comply. 

efup label - china rohs

Only products that will be used by an end-user, and not components, must be labeled. However, suppliers of components must pass along the relevant compliance information to manufacturers.

Products that contain restricted substances below the allowable thresholds (and are therefore China RoHS compliant) receive a green label, sometimes referred to as a Green eLabel. The green label is optional.

Products that contain toxic substances above the allowed thresholds must be marked with an orange label. These are called EFUP labels, as they include the product’s environmental protection use period (EFUP). The EFUP is the number of years the product can be used safely before hazardous substances begin to leak out.

The orange EFUP label features a circle with the EFUP number inside. For example, a product that will become unsafe in fifty years will feature a large number “50” in the label.

Why is RoHS Important?

RoHS’s importance can be summarized into three main areas of impact: the market, the environment, and consumer health. While China RoHS creates increased costs for sellers and buyers of electronics, the law also protects the natural environment and human health.

1) The Market

RoHS raises costs for sellers and buyers of electronic products alike. 

Manufacturers must use less hazardous and often more expensive methods to produce RoHS-compliant products. Additionally, hiring a third-party laboratory to ensure RoHS compliance may be costly. This is equally true for manufacturers in China or who are importing their products into China.

Buyers also experience increased prices of electronics in their day to day lives as a result of China RoHS.

Of course, these increased prices come hand in hand with safer, more environmentally friendly devices.

2) The Environment

The restricted materials listed in China RoHS act as environmental pollutants that often end up in landfills. By limiting the amount of these hazardous substances that may be used, RoHS protects the environment and increases the amount of electronics that can be recycled safely.

RoHS works in tandem with China’s recycling law, ​​Regulations for the Administration of the Recovery and Disposal of Waste Electric and Electronic Products (Order No. 551). This law is concerned with the proper recycling of waste electric and electronic products (WEEP). China’s WEEEP law is very similar to the EU’s WEEE law.

Read more: What is WEEE?

3) Consumer Health

RoHS works to protect consumers of EEE and broader communities from the harmful health effects of hazardous materials. RoHS aims to minimize health impacts caused by EEE in every stage of a product’s lifecycle, from production to use to disposal.

Several materials restricted by RoHS create toxic waste and occupational hazards that negatively impact human health. Restricted substances not only harm workers in production and recycling phases, but also can create health concerns for users of end products.

Comparison Table: How Does China RoHS Differ from EU RoHS?

ChinaEuropean Union
Restricted SubstancesCadmium (Cd), Mercury (Hg), Lead (Pb), Hexavalent Chromium (Cr VI), Polybrominated Biphenyls (PBB), Polybrominated Diphenyl Ethers (PBDE)All six restricted in China, plus four more: Bis(2-Ethylhexyl) phthalate (DEHP), Benzyl butyl phthalate (BBP), Dibutyl phthalate (DBP), Diisobutyl phthalate (DIBP)
Scope: Restricted ProductsAnything that falls under the definition of an electronic productAnything that falls under the definition of electrical and electronic equipment (EEE)
LabelingProducts using restricted substances below the threshold may affix a green label to the outermost packaging. Products using restricted substances above allowed thresholds must affix an orange EFUP label to the outermost packaging.A CE marking is required on all RoHS-compliant products.

Read more: What is the CE Marking?
ExemptionsNo exemptions exist for any products included in the list of Electronic Information Products (EIP) listed above.Exemptions exist for several types of products, such as active implantable medical devices. A full list is available in Article 2 of RoHS 2 (Directive 2011/65/EU).
Conformity: Proving ComplianceCompliance with China RoHS may be self-declared or confirmed by a Chinese laboratoryCompliance with EU RoHS can be self-declared

Read more about RoHS in the EU: What is RoHS?

Rules similar to RoHS have spread to many other regions, including India, South Korea, the UAE, Vietnam, Japan, and the United States including California and New Jersey. It is important for electronic companies to remain aware of shifting hazardous substance legislation in markets around the world.

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