We have a product which is meant for the China market. As per our assessment, we have to put a Hazardous Substance Table on the product to meet the requirements for China RoHS. The product is packed with cardboard and later stretch-wrapped with plastic film. As per the marketing requirements, the Hazardous Substance Table should not be printed in the product manual. Can the shipping department affix the Hazardous Substance Table on the stretch wrap?
According to the rules for China RoHS Hazardous Substance Table, it must be included with the shipment in the following ways:
- Separate sheet.
- In the manual.
- Website referenced by manual.
- Digitally available on the product.
Putting a separate sheet of paper between the cardboard box and the shrink wrap could technically count, but there could be an argument that the notice could be missed when unpacking.
Another option could be to have it on a website that is referenced by the manual. It does not specifically claim the lead in the product manual but gives a link where someone would have to go to look up the information.