China RoHS: Is a Table of Supplier Data Required?

Question: My company manufactures goods for import to China. To comply with the China Restriction of Hazardous Substances (RoHS) requirements, do we need to create a table of supplier data as supporting documentation?

Valerie Kuntz: China RoHS requires a hazardous substances table in simplified Chinese (sometimes colloquially called the “tic-tac-toe table”), which indicates whether the product contains substances from any of the six specific substance groups. If the information in the table covers all of the product’s component parts, then separate tables for the component parts are not required. However, you can choose to request tables from your suppliers if you’d like.

Assuming your company is creating one final table for the product itself (which is standard practice), the data you need from your suppliers is fairly simple. They need to provide information about any over-threshold substances in their parts, and they should also provide contact information and/or a signature based on your company’s preferences.

Article is current as of 2020-07-24.

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