No exemptions, except for China

March 1 has now passed, and the first phase of China RoHS is in effect. While the same six substances are restricted to the same concentrations as in the EU RoHS directive, China’s version is markedly different (pun intended). It requires that all “electronic information products” (EIP) be appropriately marked with either a compliant or non-compliant label.

That doesn’t sound that difficult at first.

But don’t assume that China’s view of “electronic information products” is the same as the EU’s. China’s law has a much broader scope, and offers NO EXEMPTIONS, except for its own exports, which do not have to comply. It takes 30-plus pages to list all the categories and types of products that fall within EIP, including semiconductors, large-scale manufacturing equipment, medical products, automotive electronics, components and component materials.

So, the same board or end product that is compliant in the EU only because of an exemption is not compliant in China. And products which contain any of the restricted substances are required to show the number of years before these substances will leak into the environment on a label. This is referred to as the “environment use period,” but the law offers no guidance on how a manufacturer or exporter should determine this number, or how these products will be replaced after this term.

Needless to say, we have only received minimal environment use period information from our U.S. manufacturers. The IT burden of collecting and maintaining, let alone verifying this information, is onerous for all involved. Customers are now requesting that distributors and manufacturers provide the percentage of the banned substances for products that have been identified as being non-compliant. It is difficult to respond to these requests. For one thing, this information was not needed to determine compliance under the EU directive, and so is not readily available. Secondly, the industry has not embraced the use of the IPC 1752 material declaration standard, which was the format that manufacturers would universally use to convey this information. One reason is the concern over revealing what is considered to be intellectual property.

It appears that the only practical way to do business in China is to supply or manufacture compliant EIP, which then require only a simple label. That is what our sister division in China, Premier Electronics, is doing. Premier will soon launch a Mandarin print catalog with 30,000 compliant parts. Through a 10-step quality assurance process that we initiated for EU RoHS, we can verify that these products are 100 percent compliant.

When Phase 2 of China RoHS goes into effect some time toward the end of the year or early next year, compliance will need to be confirmed through a Chinese test house. Some products simply won’t pass, for the simple reason that they can’t currently be manufactured by anyone without using certain banned substances. It may take some time before appropriate substitutes can be found. You may want to check your bill of materials and start redesigning and re-sourcing now if you are using any products that are not 100 percent compliant. While no one knows China’s plans for enforcing the law, this is the common-sense approach.

Is anyone out there selling non-compliant parts in China? If so, what are you doing about labeling? What success have you had acquiring the respective information?  And what do you think of the way China excludes only its own exports? As always, I welcome your comments and questions. For more information about China RoHS, visit www.newark.com/rohs

This blog post was contributed by Jeff Shafer, senior VP of product at Newark (formerly Newark InOne). At Newark, Jeff leads product management, product data, pricing and customer segment strategy, and was instrumental in developing and implementing RoHS compliance initiatives for the company, customers and suppliers.