Instances for Scoping - RoHS vs China RoHS

Question:

What are the instances where an EIP (Electronic Information Products) will be in scope for China RoHS and not in scope for RoHS?

Answer:

EIP (Electronic Information Products) is no longer the requirement for China RoHS. On July 1, 2016, China RoHS 2 went into effect redefining the products included in China RoHS to Electrical and Electronic Products (EEP) = Equipment dependent on electric current or electromagnetic fields for operation and equipment for the generation, transfer and measurement of such currents and fields, with a working voltage rating not to exceed 1,000 volts alternating current or 1,500 volts direct current.

Excluded China RoHS Products:

  • Equipment related to electric energy production, transmission and distribution, such as systems and devices used for power station, power distribution station and building power supply and distribution;
  • Electrical and electronic equipment used for military purposes;
  • Electrical and electronic equipment used in special or extreme environment;
  • Electrical and electronic equipment used for export
    Note: Electrical and electronic equipment used for export shall comply with provisions related to restricted use of hazardous substances in the country/region of ultimate destination.
  • Electrical and electronic equipment which are temporarily imported or imported for repair, but not for sale;
  • Prototypes used for scientific research / research and development and testing;
  • Samples and exhibits used for exhibition and display, but not for sale.

EU RoHS EEE (Electrical and Electronic Equipment) = equipment which depends on electric currents or electromagnetic fields in order to work properly as well as equipment for the generation, transfer and measurement of such currents and fields falling under the categories set out in Annex I of the directive and designed for use with a voltage rating not exceeding 1000 volts for alternating current and 1500 volts for direct current.

The new definition for EEP is more similar to EU RoHS of EEE. In fact some products that are currently (though temporarily) out of scope for EU RoHS (Industrial Category 9 Monitoring and Control Equipment and Category 11 All other EEE) are in scope for China RoHS.

Unlike EU RoHS where the 6 specific substances are restricted above the threshold unless there is an applicable exemption, there are no specific substance restrictions for China RoHS 2 at this time. China RoHS 2 requires labeling and documentation to notify when a product contains a substance above threshold. In future, they will begin releasing catalogs that will include specific types of products where the listed substances will be restricted and any exemptions they deem necessary.

Source: www.ipc.org/3.0_Industry/3.4_EHS/2016/USITO-Translation-China-RoHS.pdf

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