China RoHS: Can EU RoHS Data be Used?

Question: My company has a compliance program for the EU Restriction of Hazardous Substances (RoHS) Directive, but now some of our customers are also requesting China RoHS compliance information. Can the information we have collected for EU RoHS due diligence be used to show compliance with China RoHS?

Valerie Kuntz: Depending on the type of products your company sells, you may be able to use EU RoHS 2 compliance information to answer a number of questions for China RoHS 2 declarations. However, there are some differences between the two directives. For example:

  • The scope may differ between the two directives as some products excluded from the EU legislation are in scope of China RoHS.
  • The directives have different exemptions and exemption numbers.
  • China RoHS only includes the original six substances from the EU directive; phthalates have not been added.
  • Under China RoHS, only 12 categories are required to be below the threshold levels. Other products may be above threshold as long as the information is communicated to the next level in the supply chain.
  • China RoHS has different requirements for labeling and hazardous substance tables for finished products. Customers may ask your company to provide this table or information so they can complete the table for the finished product.

As long as these differences are understood and kept in mind, EU RoHS compliance information can be used as a starting point for responding to China RoHS 2 compliance requests.

Article is current as of 2020-05-29.

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