The EU RoHS Directive issued in 2003 and the Chinese RoHS Directive issued in 2006 have the same goal - to reduce the use of harmful elements in electronic products. Both directives strictly limit the use of certain chemicals [including lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBBs) and polybrominated biphenyl ethers (PBDE)]. The framework of the directives is similar (for example, the scope of application of the directives). There are many differences in the specific content of the directives. For example, the two Directives require different authentication methods and different identification methods. The Chinese RoHS Directive requires that the packaging part be included, while the EU RoHS Directive does not require packaging.
An important component of China's RoHS Directive is the promulgation of key catalogues in the plan. The key catalogue will define in detail the product catalogue controlled by the instructions and the timetable for execution. The catalogue is currently scheduled for release in autumn 2008, but it is not known whether it will be released on schedule. The specific content that will be included in the catalogue is not known at present. For example, as far as the information we have at present is concerned, it is not certain that the products to be included in the key catalogue will be finished products, raw materials or electronic components. In addition, another important component of the directory is a list of exempted products. The majority of electronic manufacturers hope that this list of exemptions will be consistent with the exemptions in the EU RoHS Directive, so that they can continue to sell products that meet the EU RoHS requirements in China without having to make another change in product design and process.
The main differences between the two instructions at present
One of the main differences between the two directives is the responsible party for the product. The EU Directive stipulates that the manufacturer of the product must ensure that the product meets the requirements of the Directive. In China's RoHS Directive, manufacturers and sellers of products may be punished for producing or selling products that do not meet the requirements of the Directive.
Before the promulgation of the key catalogue of the RoHS directive in China, the directive did not specifically restrict the use of harmful substances. Its main function was to require manufacturers to correctly label their products with or without harmful elements according to the requirements of the directive. The Chinese RoHS Marking Directive, which was officially implemented on March 1, 2007, is a new attempt in the world. At the same time, some of the products covered by the Directive are exempted from the EU RoHS Directive. For example, medical equipment and measurement and control instruments are exempted from EU directives, but they are also required to be identified in Chinese RoHS directives. The labeling Directive requires all manufacturers to complete the execution within one year after the issuance of the directive, and then many detailed regulations on the execution of the directive are gradually followed after the one-year time limit. Because the execution time is too urgent, the supply chain of the whole electronic products has also caused a certain panic.
As part of China's RoHS labeling requirements, all products must be shipped with a form (or from the manufacturer's website) to indicate whether they contain harmful substances. This form (see Figure 1) contains the main parts and components that make up the product. It should also indicate whether the harmful substances contained in the product are below the specified content (marked by O) or above (marked by X). This form must be in Chinese.
In addition to the above tables, the product must be labeled (if the product size is too small, the label can be attached to a random file) to show the environmentally friendly use time (EFUP). The label is shown in two forms in the following figure.