On the 21st of January 2016 the Ministry of Industry and Information Technology of the People’s Republic of China (MIIT) officially issued “Management Methods for the restriction of the use of hazardous substances in electrical and electronic product” . The new management methods had a transitional period and will come into force from the 1st of July 2016. So that enterprises may easily understand and follow the relevant requirement of the “measures” MIIT issued a FAQ “Management Methods for the restriction of the use of hazardous substances in electrical and electronic product” on the 16th of May. The “Measures”will come into force soon, related enterprises need to ensure that products produced on and after the 1st of July comply with the requirement.

Enterprise to Deal With Practice – First step “Mark”

The “measures” still use the “two steps to go” idea, “the first step” requiring a mark and disclosure of any of the six identified hazardous substances and their locations within the product (According SJ/T11364-2014); “the second step” is a requirement to restrict the six identified hazardous substances in the production of “Compliance Management Catalogue”.

If the product does not contain any hazardous substances it needs the Green symbol with “e” in it.

If the product contains certain hazardous substances, it needs the Orange symbol with a number in it, at the same time providing information on the hazardous substances in the product instructions.

1. under normal conditions, Marking should be moulded into, or printed on the production;

2. If it is not possible to place the marking on the product for reasons of size or shape then the information should be included in the  product instructions;

3. “Product instructions” include：paper instructions、optical disk type electronic instruction, or packaging;

4. Production “Purchase for product” need not follow “marking requirement”， According to the customer requirement declaration of hazardous substances information can be included on the company’s website (only applies to production “Purchase for product”).

Note, above “contain” means that the hazardous substances exceeds the limit determined by GB /T 26572.

China RoHS 2.0 Next Step Work Focus

1. “Compliance Management Catalog” (First batch) The list of products estimated to be produced by October 2016, Reference《Waste of electrical and electronic equipment disposal catalog 》(2014 Edition);

2. Exemption list of application of hazardous substances in products;

3. “Compliance Management Catalog” applicable product conformity assessment mode.

Suggestion

The “measures” coming into force have a great influence on the affected enterprises during production, sale, and import of electrical and electronic products in the People’s Republic of China. Enterprises need to understand and master the technology content of the new management method, carry out a supply chain survey. Thus ensuring that the organisation is compliant when the management method comes in force.