Now that we’re all ready for RoHS and WEEE, maybe we can take a few deep breaths and start thinking about the draft rules China. Often referred to as China RoHS, the draft document from the China Ministry of Information Industry starts where the EU directive disappeared and expands the scope considerably. In addition, the National Development Reform Commission (NRDC) is making recycling initiative called the China WEEE by outsiders.
Reading draft China RoHS is actually quite easy. Unofficial translation is clearly written and fairly well mean. 25 articles on 4 pages are much more understandable than the EU Directive was always. Several points stand out.
- Prevention of pollution by eliminating contaminants and require recycling (Chapter 2)
- Cradle-to-Grave scope (Articles 8-10)
- Packaging will be non-toxic, biodegradable and recyclable (Article 10)
- packaging must be marked with the material (10 articles)
- The RoHS 6 (Cd, Cr, Hg, Pb, PBB, PBDE) are prohibited from 1 January 2006 (Article 11)
- Products must be labeled with
- names, content levels and recycling harmful substances (12 articles)
- recycling (full, partial and not recyclable, 12 article)
- Product Safety period (period of the product is safe to use ) (13 article)
- Extraordinary exception allows labeling product manuals or on the packaging (12 articles)
- Producers must dictionaries indexes product safety period for publication (14 articles)
- Producers will be the respective recyclers to recover goods after safety period (15 articles)
- manufacturers will finance recycling ( 16 article)
- parties and individuals can complain about the pollution caused by electronic products (19 articles)
- Violators that fail to make improvements to the complaints may have licenses revoked and their identities present (Article 20)
- Products not properly marked will not be allowed past practices (Article 21)
One note – although Article 11 clearly January 1, 2006 as the starting date, others have said that July 1, 2006 the right of entry into force. In the end, the Chinese authorities lost both dates and only complete catalog promised in 2008.
Another major player in the regulatory arena, Design Chain Associates (DCA), has created a website dedicated exclusively to the China RoHS. Early in October, DCA reported that China had issued a RoHS-like legislation in their draft for industry review. There was just one catch: it’s only available in Chinese
The Chinese government has no interest in providing the official English translation of these documents .. They hold the position that the only official regulations are published in Mandarin. Forces everyone else to either learn Mandarin, arrange for their own significance or buying translate a document from the two known sources.
The DCA is to provide an overview of songs taken from the notification requirement document and translations of the previous draft. The law is very similar to RoHS, but with a disturbing difference. It proposes a catalog of covered categories, to be reviewed annually against RoHS 4-year review cycle. For six RoHS restricted substances, China added the phrase “other toxic and harmful substances” without further definition. There are products labeling requirements contain toxic materials and recycling symbol. Packaging has separate labeling requirements. Finally, as with all previous draft, there are no exceptions.
When it comes to regulatory compliance, the general rule is that the stringent regulations work. That means products will be designed to the most restrictive rules in order to sell into that market. Other markets are then free, as far as compliance goes, because less stringent requirements have been met. At this point it appears that China will be in the top position. Customer compliance requirements have a way of becoming intertwined and reflects all the current rules. So it will be necessary to design for China RoHS and WEEE China selling electronics products internationally. Furthermore, where WEEE is inherently local, WEEE compliance schemes will be universal around the world.