Comparison EU RoHS - China RoHS

Why "RoHS-compliant" does not apply internationally

A major challenge in business practice is compliance with the relevant conformity requirements. Internationally non-harmonized regulations further complicate this task. As a manufacturer based in Europe, it is often assumed that compliance with European legislation covers the majority of international conformity requirements. A fallacy, as is becoming increasingly clear.

Not only because of the different labeling requirements, but also because the substance requirements differ, even with internationally comparable legal acts. As an example, the European RoHS Directive 2011/65/EU is compared below with the Chinese Decision No. 32 - Administrative Measures on the Restriction of the Use of Hazardous Substances in Electrical and Electronic Equipment.

Scope of application


EU	PR China
Open scope, all electrical and electronic equipment (EEE)	Open scope, all electrical and electronic products (EEP) Stricter requirements for products in the so-called management catalog

Restricted substances


EU	PR China
Lead (0.1%) Mercury (0.1 %) Cadmium (0.01 %) Hexavalent chromium (0.1 %) Polybrominated biphenyls (PBB) (0.1 %) Polybrominated diphenyl ethers (PBDE) (0.1 %) Di(2-ethylhexyl)phthalate (DEHP) (0.1 %) Butyl benzyl phthalate (BBP) (0.1 %) Dibutyl phthalate (DBP) (0.1 %) Diisobutyl phthalate (DIBP) (0.1 %)	Lead (0.1 %) Mercury (0.1 %) Cadmium (0.01 %) Hexavalent chromium (0.1 %) Polybrominated biphenyls (PBB) (0.1 %) Polybrominated diphenyl ethers (PBDE) (0.1 %) Planned, not yet regulated: Di(2-ethylhexyl) phthalate (DEHP) (0.1%) Butyl benzyl phthalate (BBP) (0.1 %) Dibutyl phthalate (DBP) (0.1 %) Diisobutyl phthalate (DIBP) (0.1 %)

Exceptions

PR China

Limited in time, extension to be applied for by the industry
If the exemption relates to specific device categories, these are referenced

Relate only to the products in the management catalog
EEPs outside the management catalog do not have to adhere to the limit values of the substance restrictions or the exemptions, it must only be stated in the declaration where the limit values are exceeded.
Adopted by the EU RoHS in 2017 as it stood at the time and has not been amended since. Therefore not congruent with the currently valid version of the EU RoHS exemptions.

Labeling


EU	PR China
CE marking for finished EEE	Marking of the conformity assessment (certification label) "Environmentally friendly use period" for products outside the management catalog that exceed the limit values Green e for products outside the management catalog that comply with the limit values

Declaration


EU	PR China
EU Declaration of Conformity for finished ESPD	Declaration including information on which component contains which substance for products that exceed the limit values

Conclusion

There are many parallels between EU RoHS and China RoHS. Products that are to be transferred from the European to the Chinese market must be provided with appropriate labels and declarations or conformity assessments must be carried out in accordance with Chinese standards for products in the management catalog. For products that are to be imported from the Chinese into the European market, the different substance restrictions and scopes of application of the products and exemptions, as well as the requirements for the technical documentation, must be observed in addition to the labels and declarations.

If you have any questions about EU RoHS and China RoHS , please do not hesitate to contact us.

Author

Linda Kritzler (B. A.)
Material & Environmental Compliance Consultant

Detail