Export from EU for Non CE-Marked Product despite EU RoHS Non-Conformance

Question Posed:

Can we continue to sell products that are manufactured in the EU into the US and China? Our products would only be sold to end users in the US and China (not distributors that could export). Our products have been stripped of the CE mark due to EU RoHS non-conformance.

Answer Provided:

As long as they only ship into the US (note: some US states have implemented their own restrictions so that may need to be researched) and China (when the substances are included in the hazardous substance table in their documentation and has a EFUP (Environmental Friendly Use Period) label on the product) they should be fine.

They should be aware that China recently released their draft catalog of products that must meet the restriction requirements.

Comments on the draft are to be submitted by July 28, 2017, which could mean the catalog going into effect shortly thereafter.

The list has 12 product types:

  • refrigerators
  • air conditioners
  • washing machines
  • electric water heaters
  • printers
  • photocopiers
  • fax machines
  • televisions
  • monitors
  • microcomputers
  • mobile communication devices
  • telephones

Reference:  http://www.miit.gov.cn/newweb/n1146285/n1146352/n3054355/n3057542/n3057545/c5707945/content.html

**Article contents valid as of 2017-07-26


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