China RoHS Labeling Requirements

Under China RoHS, labeling is only required for the final product. However, information about the 6 listed substances in component products must still be shared (along with their location in the product) if the component products are used to manufacture a final product that is in-scope for China RoHS. Additionally, if the finished product is in scope of the product types defined in the Catalog (the Standard Achieving Management Catalogue for the Restriction of Hazardous Substances in Electrical Appliances and Electronic Products, published by China’s Ministry of Industry and Information Technology), the substance amounts must be below threshold or the product must be compliant by exemption.

There are several different label types in use under China RoHS. The regulation requires all electrical and electronic products (EEPs) placed on the market in China to be evaluated for the presence of the six listed substances and labeled accordingly:

  • Products that contain a listed substance over the threshold must apply an EFUP (Environmentally Friendly Use Period) label. This is an orange number in a circle of two orange arrows; the number corresponds to the number of years the product can be safely used before risking exposure to harmful substances.
  • Products that do not contain any of the listed substances over threshold may use a "Green E" label rather than an EFUP label. This is a green lower-case "e" in a circle of two green arrows.

Additionally, the appropriate Hazardous Substances Table (in Chinese) defining the products and substances over threshold must be available with the product literature.

Additional requirements for product types listed in the Catalog also involve labeling. These products may not contain listed substances above threshold (unless compliant by exemption), and must undergo a conformity assessment. This assessment can be either a voluntary third-party certification or a self-declaration process. Once a product has passed its conformity assessment, it will receive an additional label with the China RoHS mark to affix to the product:

CR1.PNG
This version of the mark (above) indicates the self-declaration process.

CR2.PNG
This version of the mark (above) indicates the third-party assessment process.

Article current as of 2020-04-17.

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