FAQs

RoHS

RoHS

RoHS is the abbreviation of "The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment." The most common versions include EU RoHS, China RoHS, and Korea RoHS. While their content is largely similar, special attention should be paid to their differences. Compliance should be determined based on the market where the product is sold. Please click the links below to view detailed explanations:

EU RoHS Frequently Asked Questions

The RoHS Directive was officially published on February 13, 2003. EU Member States were required to transpose it into their national legislation by August 13, 2004. This FAQ is intended to assist regulatory authorities in interpreting the RoHS Directive and to provide guidance to industry for compliance with national laws derived from the Directive. The FAQ reflects the views of the European Commission but is not legally binding. Only interpretations issued by the European Court of Justice are legally binding and must be followed. This FAQ will be periodically updated or revised based on Member State implementation and developments in EU waste management policy.

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The RoHS Directive is based on Article 95 of the Treaty. Its purpose is to harmonize the laws of Member States regarding the restriction of hazardous substances in electrical and electronic equipment, protect human health, and promote environmentally sound recycling and disposal of waste electrical and electronic equipment.

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The criteria for equipment to be considered within the scope of the RoHS Directive are as follows:

  • Equipment that depends on electric currents or electromagnetic fields to operate properly, as well as equipment for the generation, transfer, and measurement of such currents and fields.
  • Equipment designed for use with a voltage rating not exceeding 1000 V AC or 1500 V DC.
  • Also includes household light bulbs and lighting equipment.
  • Equipment not covered by specific EU waste management legislation.
  • Spare parts used for the repair or reuse of electrical and electronic equipment placed on the market after July 1, 2006.
  • Military equipment.
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The FAQ provides criteria to determine whether a product falls within the scope of the WEEE and RoHS Directives, but it does not provide product classification standards. Its purpose is to assist producers in making their own assessments. However, the responsibility for determining whether a product falls within the scope lies with the producer, who is best positioned to evaluate the characteristics of their product. If there are any doubts, producers may consult the competent authority responsible for enforcing the legislation in the relevant Member State. Based on its legal foundation, Member States may not introduce additional product categories without prior notification to the European Commission.

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Exemptions apply only to restricted substances contained within electrical and electronic equipment, not to the entire product. The responsibility for determining whether a product qualifies for an exemption lies with the producer, who is best positioned to assess the product's characteristics. If there are any questions regarding the scope of exemptions, producers may consult the competent authority responsible for enforcing the legislation in the relevant Member State.

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Obtaining approval for an exemption involves a lengthy process. Once formally adopted, an exemption is valid for four years and must be reviewed upon expiry in accordance with Article 5(1)(c) of the RoHS Directive. Exemption requests must be clearly defined and should refer to the six restricted substances specified in Article 4(1). Applicants must submit all relevant technical evidence to the European Commission. The Commission will then initiate a public stakeholder consultation for at least eight weeks in accordance with Article 5(2). Based on the outcome of the review process, the Commission will decide whether to submit the exemption proposal to the Technical Adaptation Committee (TAC) for final voting.

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Exemptions apply only to specific applications of substances listed under Article 4(1) of the RoHS Directive, not to entire products. Therefore, regardless of who uses the substance, if the application is listed under a RoHS exemption, it qualifies for the exemption.

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The RoHS Directive does not distinguish between household and non-household electrical and electronic equipment. Therefore, non-household equipment is also within the scope of RoHS.

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The Batteries Directive has similar substance restrictions to RoHS. RoHS restricts six hazardous substances in electrical and electronic equipment, but does not apply to batteries. The Batteries Directive restricts the use of mercury and cadmium in batteries.

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Ink cartridges do not meet the definition of electrical and electronic equipment and are generally considered consumables. Therefore, the RoHS Directive does not apply to ink cartridges.

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Certain electrical and electronic equipment such as audio systems, CD players, and navigation systems can be purchased separately and installed in vehicles. Whether these fall under RoHS or the ELV Directive (2000/53/EC) depends on their design. If the equipment is not specifically designed for use in vehicles, it falls under the RoHS Directive. If it is specifically designed for automotive use (e.g., car audio systems), then it is subject to the ELV Directive.

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For repair of equipment placed on the market before July 1, 2006, RoHS allows spare parts containing restricted substances. However, this does not apply to repair of new equipment placed on the market after July 1, 2006.

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In principle, RoHS allows the use of non-compliant materials for capacity expansion or upgrades of electrical and electronic equipment placed on the market before July 1, 2006, provided that the upgraded equipment is not placed on the market as a new product. If it is marketed as a new product, it must comply with RoHS. However, if it is marketed as a reused product, RoHS does not apply.

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RoHS substance restrictions apply to finished products, not to the manufacturing process.

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RoHS applies only to products placed on the market. Therefore, products manufactured for internal use are not within the scope of RoHS. However, if they are later placed on the market, they must comply with RoHS requirements.

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Radio Frequency Identification systems (RFIDs) meet the definition of electrical and electronic equipment under both the RoHS and WEEE Directives. They fall under Category 3: IT and telecommunications equipment, and therefore RFIDs are within the scope of the RoHS Directive.

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Antennas and cables meet the definition of electrical and electronic equipment under the RoHS and WEEE Directives. All cables or connections within EEE are considered part of the equipment once discarded and therefore fall under WEEE. However, antenna masts and high-voltage transmission towers do not meet the definition of EEE. If a product is integrated into a fixed installation, it is not considered WEEE. On the other hand, modular cabling systems used in audio, data, and video equipment fall under Category 3 (IT and telecommunications equipment) of the WEEE Directive and are also within the scope of the RoHS Directive.

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According to Article 10(3) of the WEEE Directive and Article 4(1) of the RoHS Directive, "put on the market" means the first time a product is made available on the EU market. In other words, it refers to when a producer first supplies or makes a product available to distributors, end consumers, or users in the EU. Furthermore, "first made available on the EU market" refers to individual EEE placed on the market after the RoHS Directive came into force (July 1, 2006), not to new product types or production lines. The concept applies to each individual product, not to product categories or whether they are part of a set or series.

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"Putting on the market" refers to the first time a product is made available on the EU market and is considered as being sold or used in the EU. Therefore, products are not considered "placed on the market" before clearing customs. Additionally, according to guidance under the New Approach and Global Approach directives:

The "Blue Guide" explains situations considered as NOT "placing on the market" (page 18):
  • Transferring products to another manufacturer for further assembly, packaging, processing, or labeling;
  • Products not yet released for free circulation by customs;
  • Products under other customs procedures (e.g., transport, storage, or temporary import);
  • Products in transit;
  • Manufacturer’s stock or products held by an authorized representative that have not yet entered circulation;
  • Therefore, products stored by the manufacturer and not yet distributed are considered "not placed on the market." The key condition is the transition from production to the distribution stage.
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Yes.

  • The maximum concentration values in homogeneous materials are 0.1% (1000 ppm) for lead (Pb), mercury (Hg), hexavalent chromium (Cr6+), PBB, and PBDE, and 0.01% (100 ppm) for cadmium (Cd).
  • "Homogeneous material" means a material that cannot be mechanically disjointed into different materials.
  • "Mechanical disjointing" includes processes such as unscrewing, cutting, crushing, grinding, and abrasive processes.
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According to Article 4(1) of the RoHS Directive, Member States must ensure that products placed on the EU market after July 1, 2006 comply with the directive. However, the RoHS Directive does not specify any particular conformity assessment procedures, certificates, or test methods. Therefore, each Member State is responsible for establishing its own enforcement measures.

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Yes. Companies may voluntarily affix labels to indicate compliance, provided that such labeling does not conflict with EU primary or secondary legislation, such as rules on the free movement of goods.

EU RoHS 2.0 Frequently Asked Questions

To help electronics and IT manufacturers and stakeholders better understand the EU RoHS 2.0 revision proposal, SGS headquarters and ENVIRON jointly held an online seminar on January 26, 2010. The following is a summary of key questions and responses raised by participants during the seminar, for reference only.

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The CE marking stands for the French term "Conformité Européenne," meaning "European Conformity." When a manufacturer affixes the CE mark to a product, it indicates that the manufacturer declares the product complies with all applicable EU regulations.

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The current exemptions are still under review. Please refer to the recommendation report published in February 2009 by the Oeko-Institut (German Institute for Applied Ecology), which is available on the European Commission’s RoHS website. The European Commission has not yet formally adopted the proposed expiry dates in the report.

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The definition of "risk" has not yet been finalized in the RoHS 2.0 directive and is still under discussion in the European Parliament and Council.

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Manufacturers are not required to retroactively ensure compliance for EEE products already on the market. However, distributors should avoid selling products that may not comply with RoHS requirements.

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Yes. CE marking applies to both B2B (business-to-business) and B2C (business-to-consumer) products.

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If it is not possible to include the information directly on the product, it must be provided on the packaging or in accompanying documentation.

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No, only finished products require CE marking.

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Jill Evans, who proposed the RoHS revision, suggested banning PVC in her report. However, PVC may not be included in the final list of restricted substances in RoHS 2.0.

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The manufacturer determines which risk assessment procedures to use and how to evaluate suppliers.

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RoHS 2 requires the name and address of the importer.

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The earliest possible announcement date was expected in the second quarter of 2011. No official announcement date or document number had been released at that time.

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Original Equipment Manufacturers (OEMs) can collect supplier self-declaration data by verifying the BOM.

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The 14 new SVHC substances were included in October 2009.

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Yes.

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Defense or military equipment remains excluded under RoHS 2.

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Yes.

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No. RoHS 2 is based on self-declaration.

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There should be a website listing complete information on products requiring CE marking. Currently, aerospace products and end items do not require CE marking.

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CE marking applies to all electrical and electronic equipment within the scope of RoHS 2.

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This is still under discussion. The Parliament aims to remove the exemption for large-scale stationary industrial tools, while the Council prefers to maintain the exclusion.

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No. RoHS 2 is primarily based on self-declaration.

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We recommend starting preparations immediately for CE marking requirements under RoHS 2.

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RoHS 2 only requires the first importer placing the product on the EU market to provide their name and address on the product.

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No. A product must comply with all applicable directives in order to bear the CE mark.

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An electronic version of the RoHS 2 draft is available on the European Commission’s RoHS website.

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No. Only finished products require CE marking.

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An annual update of the risk assessment process is recommended.

(Old Version) Mainland China RoHS FAQ

To help electronics and information industry enterprises and stakeholders concerned with pollution control of electronic information products understand the “Administration Measures for the Pollution Control of Electronic Information Products,” the Ministry of Information Industry of China has attempted to respond to some of the main questions raised. The following content is presented in the original document (Simplified Chinese) for reference only.

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There are four similarities between China’s “Measures” and the EU RoHS Directive:
  1. Both are legally normative documents;
  2. The main purpose of both is to control (restrict and reduce) the use of toxic and hazardous substances in electrical and electronic products;
  3. Both involve trade activities (goods trade);
  4. The restricted substances are the same six substances: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), and polybrominated diphenyl ethers (PBDE).
There are seven differences between China’s “Measures” and the EU RoHS Directive:
  1. China’s “Measures” can be directly implemented without being converted into lower-level legal instruments; however, the EU RoHS Directive must be transposed into the laws/regulations of EU Member States before implementation.
  2. China’s “Measures” apply to electronic information products, while the EU RoHS Directive applies to electrical and electronic equipment with AC voltage not exceeding 1000V and DC voltage not exceeding 1500V (excluding medical devices, monitoring and control instruments for now).
  3. China’s “Measures” adopt a “comprehensive inclusion” approach for all electronic information products containing hazardous substances, while the EU RoHS Directive applies mainly to finished electrical and electronic equipment, with requirements for components/materials being indirectly passed through the final product. Therefore, China’s approach is direct restriction, whereas the EU approach is indirect.
  4. China adopts a catalogue-based regulatory system for hazardous substances, formed using an “exhaustive listing” method. The EU RoHS Directive first includes eight categories of WEEE products, and then exempts products where substitution is not yet technically or economically feasible through an exemption mechanism.
  5. China’s “Measures” were issued on February 28, 2006 and implemented on March 1, 2007, with the restriction timeline for hazardous substances not yet determined. The EU RoHS timeline is: Directive issued on February 13, 2003; transposed into Member State law by August 13, 2004; implemented from July 1, 2006. Therefore, EU implementation is earlier than China’s.
  6. China’s “Measures” require both standards and a catalogue for implementation; the catalogue relies on supporting standards. The EU RoHS Directive only requires supporting standards.
  7. China adopts a “two-step” approach: first, self-declaration of environmental information is required; second, products listed in the key management catalogue are subject to strict control, substitution or compliance with limit values, and must pass compulsory certification (3C) before market entry. The EU RoHS Directive relies on self-declaration, but requires immediate compliance with limit values (“one-step” approach).
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The Ministry of Information Industry published the “Classification Notes for Electronic Information Products” based on the national statistical classification directory after the Measures were issued. This document provides detailed definitions and explanations of electronic information products. With this reference, manufacturers can easily determine whether their products fall within the scope of “electronic information products.” The document is available on the Ministry’s website.

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The FAQ provides criteria for determining whether products fall within the scope of WEEE and RoHS, but it is not a product classification standard. It is intended to assist manufacturers in evaluation. However, responsibility for determining applicability lies with manufacturers who are best able to assess their own products. If there are questions, manufacturers may consult the relevant national authorities. Under the legal basis of the RoHS Directive, Member States may not add additional product categories without prior notification to the European Commission.

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Catalogue management is a regulatory approach defined in the Measures, differing from the EU RoHS Directive. It targets electronic information products known to contain six hazardous substances. When substitution or compliance is technically and economically feasible, the products are included in the catalogue. The catalogue is developed gradually through procedures such as consultation with enterprises and expert evaluation. A draft procedure document has been prepared to standardize the process.

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After establishing procedural regulations for catalogue development, the Ministry of Information Industry will carry out preparatory work. The process will be institutionalized, standardized, and transparent. Opinions from enterprises, industry associations, experts, and government authorities will be widely collected to ensure scientific and accurate decision-making.

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The control of hazardous substances in electronic information products under the “Measures” indeed follows a “two-step approach.” The “first step,” upon the implementation (effective date) of the Measures, requires that all electronic information products containing hazardous substances entering the market only need to provide “disclosure” (self-declaration). This means labeling or providing information in product manuals to inform users or consumers of the names and contents of hazardous substances or elements in the product, environmental usage period, recyclability at end-of-life, and packaging material information. At this stage, there are no requirements for substitution or concentration limits. The “second step” applies when certain products are included in the Catalogue. These products must either have substituted hazardous substances or meet limit standards, and must pass CCC certification before entering the market.

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The Measures clearly adopt a “catalogue management” approach for restricting and prohibiting hazardous substances. Only products included in the Catalogue are required to undergo CCC certification. Therefore, when the Measures first take effect, products not included in the Catalogue do not require CCC certification. The inclusion of products in the Catalogue is a gradual process, allowing enterprises sufficient preparation time. CCC certification for listed products will inevitably increase costs, which is an unavoidable cost of environmental protection, but this applies equally to all enterprises, whether domestic or foreign, manufacturers or importers.

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The issuance date refers to the official publication date of the Measures, after which no further revisions or consultations will be made. The implementation date is when the legal effect begins; from that date, all provisions take effect except those related to the Catalogue. The timeline for restricting hazardous substances in Catalogue-listed products has not yet been determined. Article 21 states that the implementation timeline will be jointly issued by relevant authorities based on industrial development conditions. Therefore, the enforcement timing for Catalogue products has not been finalized in the Measures.

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The Ministry of Information Industry began developing pollution control standards for electronic information products in 2004. The approach includes actively tracking and participating in international standard development, completing national standards for hazardous substance testing procedures, and developing industry standards. China has participated in IEC/TC111 activities and established corresponding technical working groups. Eight industry standards have been initiated, including limit requirements, labeling requirements, testing methods, and lead-free soldering standards. Three standards (SJ/T 11363-2006, SJ/T 11364-2006, SJ/T 11365-2006) have already been issued, while others are still under development. The standardization process is open, transparent, and aligned with international standards.

Standard development follows strict procedures and is open to enterprises and institutions. The working group has expanded from over 20 members to more than 100. The goal is to align with international standards and ensure future compatibility with global requirements.

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The Measures are a ministerial regulation jointly issued by seven government authorities. They include requirements for environmental labeling and restrictions on hazardous substances. The Labeling Requirements and Limit Requirements are supporting standards developed based on the Measures, further refining and specifying implementation details. Although these standards are recommended in nature, they become mandatory due to their incorporation into the Measures.

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The industry standards developed by the working group support the implementation of the Measures. Standards issued by the General Administration of Quality Supervision are industry standards used mainly to support export testing for EU RoHS compliance. National standards developed by the Standardization Administration aim to meet domestic industry needs and include technical guidance documents. These efforts are coordinated to avoid duplication and ensure consistency.

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The Measures introduce the concept of environmentally friendly product design and production. They require compliance with relevant standards and encourage the use of non-toxic or low-toxicity materials and recyclable solutions where technically feasible. However, these provisions are advisory in nature and do not impose mandatory enforcement measures.

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“White goods” generally refer to household appliances such as refrigerators, washing machines, and air conditioners. “Black goods” refer to consumer electronics such as televisions, radios, audio/video equipment, and speakers. So far, white goods are not officially classified as electronic information products by the national statistics authority and are therefore not included in the scope of the Measures. “Home electronic products” refer to traditional black goods only. Although complete white goods are excluded, some electronic components within them are considered electronic information products. If these components are supplied directly for assembly purposes, they are not subject to the Measures; however, if sold separately, they must comply with the Measures.

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The RoHS Directive applies only to products placed on the market. Therefore, products manufactured for internal use are not covered. However, once placed on the market, compliance is required.

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Electronic products specifically supplied directly to automobile manufacturers for assembly are not subject to the Measures. However, electronic information products sold separately that can be used in automotive applications are within the scope of the Measures.

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Spare parts used for maintenance or upgrades in after-sales service are not subject to the Administrative Measures. However, if they are sold as standalone products, they fall within the scope of the Measures.

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Radar is an electronic information product. Therefore, radar products fall under the scope of the Administrative Measures, except for military radar.

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Although batteries are not included under the EU RoHS Directive, the EU has a separate Battery Directive. In Mainland China, battery products listed in the Classification Notes must comply with the Administrative Measures; those not listed are not subject to the Measures.

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The “electronic application products” in the Classification Notes include “household electronics” and “medical electronic devices and equipment.” Therefore, medical electronic devices and equipment listed in the Classification Notes are considered electronic information products and must comply with the Administrative Measures.

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Electronic industrial equipment explicitly listed in the Classification Notes falls under the scope of the Administrative Measures and must comply with its requirements. Such products placed on the market after March 1, 2007 must also be labeled.

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Currently, photocopiers are not listed in the Classification Notes and therefore are not considered electronic information products and are not subject to the Administrative Measures. The Ministry of Information Industry is revising the relevant statistical classification, and photocopiers may be included in the future.

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According to the Classification Notes, consumables such as toner and ink cartridges fall under “computer peripheral products and consumables” and must comply with the Administrative Measures. Whether used in printers, photocopiers, or other similar devices, they are essentially covered. However, since photocopiers themselves are not currently within scope, consumables specifically supplied directly to photocopier manufacturers for their own use are not regulated. If sold independently, they must comply with the Measures.

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Electronic measuring instruments are explicitly included in the definition of the Administrative Measures. Products listed in the Classification Notes fall under its scope and must comply with the requirements.

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Blank optical discs, CDs, VCDs, DVDs, and magnetic tapes sold separately must be labeled in accordance with the Administrative Measures and the Labeling Requirements. Media that already contain recorded content and are considered software products are temporarily exempt.

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Plastic, paper, or other material labels attached to electronic information products, as well as instruction manuals, may temporarily be exempt from the requirements of the Administrative Measures.

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Second-hand products are not within the scope of the “Administrative Measures”.

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At the current stage, products not explicitly listed in the “Classification Notes” are not considered.

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The current “Administrative Measures on Pollution Control of Electronic Information Products” restricts six substances: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), and polybrominated diphenyl ethers (PBDE, except decabromodiphenyl ether), which are consistent with the EU RoHS Directive.

The phrase “other toxic and hazardous substances or elements as stipulated by the state” is a general legal expression used in mainland China’s regulatory system and is consistent in meaning with Article 5 of the EU RoHS Directive regarding “adaptation to scientific and technical progress”.

With technological development and increasing environmental requirements, it is possible that substances other than the six listed above may later be found to pose significant risks to human health and the environment, and thus require restriction. This clause is intended to allow for future additions of such substances or elements through appropriate revisions.

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The environmental usage period refers specifically to the period during which hazardous substances or elements in electronic information products will not leak or mutate in a way that causes environmental pollution or serious harm to people or property.

It is not the same as the safety usage period and does not include limitations related to electrical safety or electromagnetic safety. The environmental usage period may be shorter or longer than the product’s safety usage period.

It refers to the environmental performance period under normal usage conditions, not under extreme conditions.

Manufacturers or importers independently determine the environmental usage period of their products, as they have the most knowledge of their products and can define it more scientifically.

If a company sets a longer period, it bears longer responsibility; if shorter, it may lose some market competitiveness. Therefore, the determination must be objective and scientific.

Industry associations may provide guidance for their sectors and are encouraged to develop relevant recommendations, which should be filed with the Ministry for regulatory reference.

The environmental usage period does not require government approval.

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Generally, according to the “barrel principle,” the environmental usage period of a product should be determined by its weakest component.

If the product contains components that require periodic replacement and contain hazardous substances, such replaceable parts (e.g., batteries and consumables) may be labeled separately.

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One of the legislative purposes of the “Administrative Measures” is to facilitate dismantling and treatment of discarded electronic information products and reduce environmental pollution.

However, the Measures regulate design, production, sales, and import activities, and do not cover post-disposal recycling, treatment, or reuse. Relevant standards supporting the Measures also do not regulate post-disposal activities.

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The “market placement” time can be understood as the product’s “production date,” i.e., the date it leaves the production line.

Electronic information products produced on or after March 1, 2007 (the effective date of the Measures) must comply with the relevant requirements.

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This clause is an encouraging provision and does not impose specific limit requirements on hazardous substances in packaging materials.

At present, there are no applicable national or industry standards for hazardous substance control in electronic information product packaging.

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In general, processing with supplied materials or assembly refers to manufacturing finished products using imported raw materials or components for export.

Exported products and imported materials for export processing are not subject to the “Administrative Measures”.

For incoming materials processing where products are sold domestically, the products must comply with the Measures.

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Since these items are not sold or placed on the market, they do not require environmental information labeling.

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The “Classification Notes” explain what constitutes electronic information products.

Products in the “Catalogue” are only a subset of those listed in the Classification Notes. They are products known to contain lead, mercury, cadmium, hexavalent chromium, PBB, and PBDE. Not all products in the Classification Notes are included in the Catalogue.

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Generally, there is no difference in strictness between national standards and industry standards.

If an industry standard is issued before a national standard, enterprises should follow the industry standard. Once the national standard is issued, the industry standard becomes invalid.

If an industry standard is issued after a national standard, it usually serves as a supplement, and both may be applied together.

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In the initial stage of implementation, the Measures only require voluntary self-declaration of hazardous substance information, so testing and certification are not mandatory and do not involve mutual recognition issues.

In the later stage, when compulsory CCC certification is introduced, mutual recognition may become relevant and depends on bilateral agreements between governments.

If such agreements exist between governments, certification from recognized foreign bodies will be accepted; otherwise, it will not be recognized.

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Chapter 3 provides general penalty provisions for violations related to electronic information product pollution control but does not specify exact penalty amounts.

Enforcement is carried out by relevant authorities such as customs, industry and commerce, quality supervision, and environmental protection departments, each imposing penalties according to their respective regulations.

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If a finished product is found non-compliant with the “Administrative Measures,” the manufacturer of the finished product is responsible, even if the issue originates from components.

The OEM manufacturer may trace responsibility back to suppliers.

If a component is sold as a standalone product and is found non-compliant, the component manufacturer is responsible.

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If a complete product is found to be non-compliant with the provisions of the "Administrative Measures," the manufacturer of the complete product shall bear responsibility, even if the issue is caused by components. The responsibility of component suppliers should be traced by the complete product manufacturer. If components sold separately are found to be non-compliant, the component manufacturer shall bear responsibility.

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After March 1, 2007, all electronic information products must disclose information such as hazardous substances, environmentally friendly use period, and recyclability in accordance with the "Administrative Measures" and relevant standards. Whether labeling is required and how complete products and components coordinate in marking are specified in the "Marking Requirements."

If a product is included in the "Catalog," its main components must comply with the "Administrative Measures" and relevant standards. However, whether both the complete product and its components must bear the CCC mark depends on which is included in the Catalog. If the complete product is included, only the complete product needs the CCC mark.

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The "Administrative Measures" is a legal regulatory document of mainland China. According to common practice, no official English version is provided. Many English translations are available online and can be used for reference. However, in case of discrepancies, the Chinese version shall prevail.

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The "Administrative Measures" can be implemented with the support of relevant standards and the "Catalog." There are currently no plans to formulate detailed implementation rules, nor is there any information indicating that local authorities will issue their own rules.

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According to the "Administrative Measures," after March 1, 2007, it is not permitted to lease electronic information products manufactured after the effective date that have not disclosed required information or, if listed in the "Catalog," have not obtained CCC certification.

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Consideration has already been given to referencing customs codes when formulating the "Catalog" in the future.

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If an overseas parent company sells products to a subsidiary in mainland China that has a separate legal entity, the requirements of the "Administrative Measures" must be met. If the products are transferred to a branch with the same legal entity, this is considered an internal asset transfer rather than "placing on the market," and compliance is not required.

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According to the Basic Laws of the Hong Kong and Macau Special Administrative Regions, the "Administrative Measures" do not apply to these regions. However, electronic information products manufactured in Hong Kong or Macau and sold in mainland China must comply with the relevant requirements.

Source: Ministry of Information Industry of Mainland China website, "FAQs on the Administrative Measures for the Control of Pollution Caused by Electronic Information Products"

(Updated Edition) China RoHS FAQ

The "Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products" (hereinafter referred to as the "Administrative Measures") were promulgated on January 6, 2016, and officially came into effect on July 1, 2016. In order to help relevant stakeholders understand the various requirements of the Administrative Measures and ensure their effective implementation, the Department of Energy Conservation and Comprehensive Utilization of the Ministry of Industry and Information Technology organized the China Electronics Standardization Institute, the China Academy of Information and Communications Technology, the Fifth Electronics Research Institute of the Ministry of Industry and Information Technology, as well as the China Electrical Equipment Industry Association, the China Household Electrical Appliances Association, the China Electronic Energy-Saving Technology Association, the China Household Electric Appliance Research Institute, and the China Video Industry Association to jointly compile the "FAQs on the Implementation of the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products" (hereinafter referred to as the "FAQs").

During the preparation of the FAQs, opinions were solicited from the Environment Working Group of the Working Committee of the Investment Companies (ECFIC) under the China Association of Enterprises with Foreign Investment, as well as from international industry organizations such as European electrical and electronic industry bodies, the United States Information Technology Office (USITO), and the Japan Electronics and Information Technology Industries Association (JEITA), along with domestic and international industry experts. With the consent of the National Development and Reform Commission, the Ministry of Science and Technology, the Ministry of Finance, the Ministry of Environmental Protection, the Ministry of Commerce, the General Administration of Customs, and the General Administration of Quality Supervision, Inspection and Quarantine, the FAQs were finalized and officially released to the public. (The following content is presented in the original Simplified Chinese text.)

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The "Administrative Measures" is a departmental regulation. Its superior laws include the "Law of the People's Republic of China on Promoting Cleaner Production," the "Law of the People's Republic of China on the Prevention and Control of Environmental Pollution by Solid Waste," and the "Regulation on the Administration of the Recovery and Disposal of Waste Electrical and Electronic Products."

The main purposes of formulating the "Administrative Measures" are as follows:
  • Actively implement "Made in China 2025," comprehensively promote green manufacturing, develop green products, and build a green manufacturing system;
  • Establish the restriction of hazardous substances in electrical and electronic products as a fundamental task for cleaner industrial production and recycling of waste electrical and electronic products, reflecting the environmental protection principle of "prevention first" and the approach of "addressing issues at the source";
  • Incorporate the restriction of hazardous substances into industry management, achieve legalization, and align with international practices;
  • Promote substitution or reduction of hazardous substances, advocate eco-design, and enhance environmental protection, resource conservation, and comprehensive utilization throughout production, use, and end-of-life stages;
  • Accelerate industrial restructuring and optimization to ensure sustainable development.
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Compared with the original version, the revised "Administrative Measures" mainly includes the following adjustments:

  1. Scope of application

    The name has been revised to "Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products." The scope has been expanded from electronic information products to electrical and electronic products, while the core focus remains on restricting hazardous substances.

  2. Conformity assessment system

    The "Administrative Measures" adopts a "two-step" approach: in the first step, products are only required to declare hazardous substance information (in accordance with marking requirements); in the second step, products included in the "Compliance Management Catalog" must meet substance restriction limits.

    Additionally, Article 18 introduces a conformity assessment system to be established based on national conditions, with detailed measures to be issued separately.

  3. Removal of packaging labeling requirements

    The requirement to use non-hazardous, degradable, and recyclable packaging materials remains. However, labeling requirements for packaging were removed because relevant national standards have already been issued.

A.

The "Administrative Measures" standardizes the terminology for restricted substances. This does not affect the substantive requirements. The original version referred to the "Key Management Catalog for Pollution Control of Electronic Information Products."

A.

The "Administrative Measures" do not apply to Hong Kong, Macao, and Taiwan. However, products manufactured in these regions and sold in mainland China must comply with the relevant requirements.

A.

Compliance is determined by the production date. Products manufactured on or after July 1, 2016 must meet the requirements. The production date refers to the date when the product has completed all processes, passed inspection, and is packaged as a finished product ready for sale.

A.

Imported products follow the same requirement as domestically produced products. Compliance is based on the production date and is not related to customs clearance or market entry time.

A.
According to relevant provisions, the applicable standards include:
  • "Marking Requirements for the Restriction of Hazardous Substances in Electrical and Electronic Products" (SJ/T11364-2014);
  • "Requirements for Concentration Limits of Certain Hazardous Substances in Electrical and Electronic Products" (GB/T26572-2011);
  • Test methods:
    • "Determination of Six Restricted Substances..." (GB/T26125-2011);
    • "Determination of Hexavalent Chromium..." (GB/T29783-2013).

These standards are mandatory for compliance with the "Administrative Measures."

A.

No. The environmentally friendly use period refers to the time during which hazardous substances will not leak or cause harm under normal use. It is different from the safe use period, which relates to safety factors such as electrical or electromagnetic safety.

A.

The environmentally friendly use period is determined by the enterprise. Industry associations may provide guidance, and reference can be made to SJ/Z11388-2009. Typically, the shortest lifespan among components determines the overall product period. No government approval is required.

I. Explanation of the Scope of Application of the "Administrative Measures"

A.

The term "supporting products" refers to components/parts, elements, and materials used in electrical and electronic equipment within the scope of the "Administrative Measures." Note: Standard accessories, optional accessories, and spare parts used for repair, refurbishment, expansion, or upgrades are also included.

Standard accessories are auxiliary parts supplied with the product and are necessary for proper use and performance. Optional accessories enhance functionality or performance but are not required for basic operation. As part of electrical and electronic products, supporting products must comply with the "Administrative Measures."

A.
The following equipment and their dedicated/supporting products are not within the scope:
  • Equipment related to power generation, transmission, and distribution (e.g., power plants, substations, building power systems);
  • Equipment used for military purposes;
  • Equipment used in special or extreme environments;
  • Products intended for export (must comply with destination country regulations);
  • Temporarily imported products or products for repair not intended for sale;
  • Prototypes used for R&D or testing;
  • Exhibition or display samples not intended for sale.
A.

The original regulation listed ten product categories. However, due to rapid technological changes, the current "Administrative Measures" adopts a generalized classification approach rather than an exhaustive list.

The scope includes, but is not limited to:
  1. Communication equipment

    Includes wired and wireless devices such as mobile phones, fax machines, radios, navigation equipment, etc.

  2. Broadcast and television equipment

    Includes broadcasting systems, transmission equipment, and TV-related devices.

  3. Computers and office equipment

    Includes servers, PCs, printers, routers, storage devices, biometric devices, UPS, etc.

  4. Household electrical and electronic equipment

    Includes appliances such as audio/video devices, kitchen appliances, air conditioners, and security systems used in homes or similar environments.

  5. Electronic instruments

    Includes measuring, monitoring, and analytical instruments.

  6. Industrial electrical equipment

    Includes industrial production, processing, and control equipment.

  7. Power tools

    Includes handheld, portable, and garden electric tools.

  8. Medical electronic equipment

    Includes devices used for diagnosis, treatment, or monitoring.

  9. Lighting products

    Includes lamps and light sources such as LED, fluorescent, etc.

  10. Entertainment and sports electronic products

    Includes electronic toys, instruments, and recreational devices.

A.

Stakeholders can determine applicability based on the regulatory criteria and should retain evidence if claiming exclusion.

II. Specific Cases Related to Scope

A.

No. Electric transportation tools are not considered electrical and electronic products under this regulation.

A.

All batteries are included except those specifically used in excluded products.

A.

Except for power transmission and distribution cables excluded in Q11 Item 1, all other cables used in electrical and electronic equipment within the scope of the "Administrative Measures" must comply with its requirements. Cables sold on the market without a clearly defined end use must also comply.

A.

Consumables that are themselves electrical and electronic products and can be replaced and installed by consumers (such as toner cartridges and ink cartridges) fall within the scope of the "Administrative Measures." Consumables that are not electrical and electronic products (such as vacuum cleaner dust bags) must comply when sold together with the equipment, but are not regulated when sold separately.

A.

Processing with supplied materials refers to using foreign-provided materials or components to manufacture products for export. These products and related imported materials are not subject to the "Administrative Measures." For processing with imported materials, if the finished products are exported, they are not subject to the regulation; if they are sold within mainland China, they must comply. Exported products must comply with the regulations of the destination country or region.

A.

Products intended exclusively for installation in equipment outside the scope (e.g., displays for vehicles or aircraft seats) are not included. However, if such products are sold separately without a defined end use, they fall within the scope.

A.

Replacement products are considered newly placed products on the market and therefore fall within the scope of the "Administrative Measures."

A.

Second-hand products are not within the scope of the "Administrative Measures."

A.

Products placed on the market through leasing are treated the same as sales and fall within the scope of the "Administrative Measures."

A.

If products are sold to a subsidiary with a separate legal entity, compliance is required. If transferred within the same legal entity (e.g., to a branch), it is considered an internal transfer and not "placing on the market," and therefore not subject to the regulation.

I. Implementation of the "Administrative Measures" and Enterprise Execution Process

A.

II. Categories of Restricted Hazardous Substances

A.

This is a common expression used in Chinese legal and regulatory documents.

III. Marking Requirements

(1) Implementation of Standards During the Transition Period
A.

SJ/T 11364-2014 was issued on July 9, 2014. According to MIIT Announcement No. 88 (2014), its implementation date aligns with the "Administrative Measures," i.e., both took effect on the same date.

Before the effective date, stakeholders may gradually transition between old and new standards. During this transition period, both are acceptable. Products newly included must complete hazardous substance marking in accordance with SJ/T 11364-2014, and all products manufactured on or after July 1, 2016 must comply.

A.

Enterprises may collect and declare hazardous substance information using methods such as:

  • Supplier declarations and supporting technical documentation;
  • Valid test reports or conducting/testing through third parties;
  • Valid third-party certification certificates.

Enterprises are responsible for the accuracy and validity of declared information.

A.

The starting date is based on the product’s production date.

A.

Generally, forms that do not comply with the new standard cannot be used. However, if included in manuals or packaging, they may still be used with correction inserts for efficiency.

(2) Issues Related to Scope of Standard Application
A.

Products within the scope of the "Administrative Measures" must follow SJ/T 11364-2014. For products outside the scope but within the standard’s scope, compliance is recommended.

(3) Issues Related to Hazardous Substance Information Marking
A.

According to SJ/T 11364-2014, for electrical and electronic products procured for production support, suppliers are not required to label the products they provide, but must supply all information necessary for labeling to the purchaser. This provision aims to reduce production costs and avoid duplicate labeling during manufacturing. Under this rule, labeling may appear only on the final product, but must cover all components of the product. Upstream suppliers are responsible for providing all necessary labeling information to downstream customers. This includes components, parts, and raw materials of electrical and electronic products procured domestically or from abroad for production support.

A.

Since spare parts for electrical and electronic equipment are typically used to repair or upgrade similar products, labeling is not required for spare parts used in after-sales service in order to avoid duplicate labeling.

A.

For accessories that are not electrical or electronic equipment, if they are sold together with the main product and are necessary for the product’s structure or functionality (such as an extension table for an electric sewing machine or a lens hood for a camera), they must be labeled according to SJ/T 11364-2014, and their hazardous substance content must be included in the table. Otherwise, labeling is not required.

A.

For detachable accessories that are themselves electrical and electronic products (such as power adapters or keyboards), companies may choose whether to label the EFUP together with the main unit. If labeled together, the hazardous substance table must include information for these accessories. If labeled separately, the table may be presented either separately or together, but must still cover these accessories and indicate where hazardous substances are located.

For components that require periodic replacement and contain hazardous substances—especially when their EFUP is shorter than other parts—they may be labeled separately so that the EFUP of the main product is not affected.

A.

If the EFUP differs among the products, they may be labeled separately. If the EFUP is the same, they may be labeled individually or on the main product. The hazardous substance table must include information for the entire set and indicate where hazardous substances are located.

(IV) Specific Requirements for Labeling Content and Marks
A.

According to Section 6.2.1 of SJ/T 11364-2014, if hazardous substances do not exceed the specified limits, the “e” mark should be used, and the hazardous substance table is not required.

A.

The “e” uses an artistic font for aesthetic purposes. Its proportions can be derived from the standard grid in Figure 3 of Section 5.4.1 of SJ/T 11364-2014. Electronic versions of the figures are also available online.

A.

The colors are not mandatory. Green and orange are recommended. Manufacturers or importers may use other colors as long as they meet size and visibility requirements.

A.

Labels on molded surfaces, paper labels, or manuals may temporarily not need to meet the full requirements.

A.

It indicates that the content of a hazardous substance exceeds the specified limit. Additional explanations may be provided if substitution is not yet feasible.

A.

Component definitions are determined by the company but should cover all parts of the product. Components without hazardous substances are not required to be listed.

A.

No, because it would not clearly convey hazardous substance information to recyclers.

A.

Yes, additional information may be included, but required information must not be omitted or altered.

A.

Instructions should include environmental conditions, usage methods, and warnings to prevent misuse (e.g., “Keep away from high temperatures”). Special labeling applies to items like batteries or printer consumables.

(V) Selected Specific Labeling Examples
A.

Yes, only one label is required, but the hazardous substance table must include the battery.

A.

Yes. For mobile phones with removable batteries, the battery compartment is a visible area when consumers remove the battery. Therefore, it is acceptable to place the marking inside the battery compartment. It must also comply with the requirements of SJ/T 11364-2014 Section 6.1.1, ensuring that the marking is clear, legible, not easy to fade, and not easily removable.

A.

According to Chapter 4 “General Provisions” of SJ/T 11364-2014, the carrier of the product manual can be the packaging. If the product meets the conditions described in the second paragraph of Section 6.1.2, the marking may be provided only on the packaging.

IV. Limit Requirements

A.

Yes. The Ministry of Industry and Information Technology, together with relevant departments, will release the “Compliance Management Catalog” in batches based on industry development, following the principles of openness and transparency.

A.

Yes. Relevant exemptions for hazardous substances will be specified for products included in the “Compliance Management Catalog” and will be published together with the catalog.

A.

A transition period will be established for the implementation of the “Compliance Management Catalog,” and it will be specified when the catalog is issued.

A.

The conformity assessment system for the restricted use of hazardous substances in electrical and electronic products will be formulated in accordance with Article 18, Paragraph 2 of the “Management Measures” and will be issued in an appropriate form.

A.

Since the implementation of China’s “Management Measures” for pollution control of electronic information products is carried out in a “two-step approach,” after the Measures take effect, the “first step” only requires enterprises to make a “self-declaration” of information such as the names and content of toxic and hazardous substances or elements contained in products, environmental protection use periods, and recyclability. At this stage, many enterprises may engage testing or certification bodies to assist in making such “self-declarations.” This voluntary and non-mandatory testing and certification does not involve issues of mutual recognition between countries.

However, in the “second step,” when CCC mandatory certification is required due to government regulation, the issue of mutual recognition between countries does arise. Mutual recognition of testing and certification between countries cannot be achieved unilaterally and must be based on bilateral agreements. In practice, if a foreign government has signed an agreement on mutual recognition of certification bodies with the government of mainland China, China will recognize the certification issued by that country’s certification bodies; otherwise, it will not be recognized.

A.

Article 12 of the “Management Measures” stipulates that packaging materials for electrical and electronic products shall comply with relevant standards and use non-toxic, easily degradable, and recyclable materials. Therefore, packaging materials for electrical and electronic products fall within the scope of the “Management Measures,” but this requirement is currently of a recommended nature. Since the “Management Measures” remove provisions related to packaging labeling, labeling requirements for packaging materials should be implemented in accordance with relevant regulations and national standards.

A.

One of the legislative purposes of the “Management Measures” is to facilitate the dismantling and treatment of waste electrical and electronic products and to reduce environmental pollution caused by such waste. However, the Measures emphasize a “source control” approach and set requirements for product design, production, sales, and import processes. Issues related to recycling, treatment, and reuse after disposal shall comply with China’s “Regulations on the Administration of the Recovery and Disposal of Waste Electrical and Electronic Products” (State Council Decree No. 551) and other relevant laws and regulations.

A.

Because different relevant authorities have their own penalty provisions for different situations, and to ensure coordination and consistency, it is not appropriate for the “Management Measures” to provide detailed provisions in this chapter. Therefore, in accordance with Article 19 of the “Management Measures,” entities or individuals who violate the requirements will be referred to and/or penalized by competent departments such as commerce, customs, quality supervision, and industry and commerce within their respective scope of responsibilities in accordance with the law.

A.

If the final product is found to be non-compliant with the “Management Measures,” then the responsibility shall lie with the final product manufacturer, even if the issue is caused by upstream suppliers of components or parts. The manufacturer of the final product shall be responsible, and any liability of upstream suppliers shall be traced and handled by the final product manufacturer itself.

Source: “Frequently Asked Questions on the Implementation of the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products”

Korea RoHS FAQ

FREQUENTLY ASKED QUESTIONS ON KOREA RoHS / WEEE / ELV

Scope

A.

“Electrical and electronic equipment” refers to equipment and devices (including components and accessories) that operate using electric current or electromagnetic fields. In terms of product scope, Korea RoHS aligns with the existing Extended Producer Responsibility (EPR) system. Article 6 of the Enforcement Ordinance lists applicable products. Therefore, companies can refer to this list to determine whether their products fall under “electrical and electronic equipment.”

A.

“Vehicles” refer to those described in Article 2(1) of the Automobile Management Act (including components and accessories). This includes passenger cars, vans, and trucks under 3.5 tons.

A.

Annex 2 of the Enforcement Ordinance lists materials and components exempt from hazardous substance concentration limits, and these exemption applications are expected to be similar to those under EU RoHS.

A.

Article 6 of the Enforcement Ordinance states that semiconductors used as components of electrical and electronic equipment are included in the scope. However, exemptions may apply due to economic and technical considerations. Companies should therefore verify whether their products fall within scope when complying with Korea RoHS.

A.

Medical products are not currently covered under Korea RoHS. They may be included in the future if the EPR scope expands, so continuous monitoring is required.

A.

No. However, it should continue to be monitored because medical devices may be included in the future due to expansion of the EPR scope.

A.

Industrial equipment or products are not included. Consumer products and some office equipment are currently covered under Korea RoHS. However, the regulatory scope is expected to expand, so continued monitoring is required.

A.

If the product can also be used for purposes other than its main function, it is not included in the scope. If the product is only used for a designated function within a vehicle, then it is included in the scope.

A.

The Act does not clearly specify this. However, discussions are ongoing regarding a legally permitted grace period, under which products placed on the market before a certain date may not be subject to obligations. Details of the grace period have not yet been announced. The approval of second-hand product usage is also under discussion, and a positive outcome is expected.

A.

Regulations concerning batteries are governed by the “Quality Management and Safety Control of Industrial Products Act.”

A.

In principle, EU RoHS covers finished products. The supply chain must comply with specific requirements for supplied parts, and the same principle applies under Korea RoHS.

A.

Yes. Korea RoHS takes effect based on the application scope of the EPR system. However, the scope of electrical and electronic products is expected to expand.

‧Restriction on Use of Hazardous Substances

A.

Korea RoHS prohibits new electrical and electronic equipment placed on the Korean market from containing lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyls (PBBs), and polybrominated diphenyl ethers (PBDEs) above the specified limits. For vehicles, the four heavy metals—lead, mercury, hexavalent chromium, and cadmium—are restricted. The regulated concentrations specified in Annex 1 of the Enforcement Ordinance are the same as those under EU RoHS and ELV.

A.

No. Therefore, until standards are issued, analysis may follow internationally recognized methods. The standards are expected to align with EU RoHS.

A.

Korea RoHS does not cover packaging materials. There is a separate law in Korea regulating packaging materials.

‧Recycling Methods

A.

The “recycling performance rate” refers to the target rate considered during product design, while the “recycling rate” refers to the target rate that must be met during actual recycling processes. Both terms are defined in the Enforcement Ordinance and Enforcement Regulations for each product.

A.

The target recycling (performance) rate is determined based on industrial technical considerations. It is calculated according to the methodology in Annex 3 of the Enforcement Regulations, reviewed by a committee, and published before the relevant year begins. The target rate varies by year and product, and must be checked in the Enforcement Ordinance and Enforcement Regulations for each case.

A.

The guidance explains in detail how to achieve recycling targets through improved materials and structural design. It includes the use of recyclable materials, simplification of materials, material identification markings, and ease of disassembly.

A.

Manufacturers and/or importers may either directly recycle collected waste or join a recycling cooperative organization to fulfill their obligations.

A.

A designated fee is calculated based on recycling costs. The calculation standards and payment procedures are defined by the organization’s regulations.

A.

Manufacturers, importers of electrical and electronic equipment, or recycling cooperative organizations must submit a “Recycling Requirement Implementation Plan” to the environmental authority for approval. After the plan is approved, manufacturers or importers must submit a “Recycling Requirement Implementation Report” to the environmental authority. The submission process for the “Recycling Requirement Implementation Plan” is specified in Article 14 of the Enforcement Ordinance, and the submission process for the “Recycling Requirement Implementation Report” is specified in Article 16.

‧Declaration of Conformity

A.

Manufacturers and importers of electrical and electronic equipment and vehicles must issue a self-declaration stating compliance with hazardous substance concentration limits or product recycling rates. The declaration procedure requires disclosure of operating and management systems and company website information. Details are specified in Annex 1 of the Enforcement Ordinance. There is no mandatory certification process; however, non-compliant manufacturers and importers may be subject to penalties such as imprisonment or fines.

A.

In principle, each product requires a declaration. However, products with similar specifications or versions may be combined into a single declaration. In such cases, all product model numbers must be listed in the declaration.

A.

There is no mandatory requirement for labeling. Manufacturers and importers follow voluntary verification and declaration practices.

A.

Recycling performance records must be retained for five years from the most recent record. They should be archived by year.

A.

Supervisory management is implemented by the Korea Environment & Resources Corporation, and detailed procedures are still under discussion.

‧Timeline

A.

Korea RoHS took effect on January 1, 2008.

A.

Korea RoHS applies to products placed on the market or imported after January 1, 2008. However, considering industry requests, it is still under discussion whether the regulation should be based on the manufacturing date.

A.

The Act passed parliamentary review in April 2007. Public consultation on the Enforcement Ordinance and Enforcement Regulations was ongoing in September 2007. The publication was scheduled for October or November 2007 depending on discussions among ministries and government agencies.

A.

As these are official Korean legal documents, the Korean government does not publish official English versions. Eco Frontier publishes a free English version of the Act and paid English versions of the Enforcement Ordinance and Enforcement Regulations.

— This translation is for reference only. In case of any discrepancy, please refer to the original source website. —

UK RoHS FAQ

A.

Before 1 January 2021, you may use the CE marking or other appropriate markings (e.g., wheel mark or Pi mark). Most CE-marked products could continue to be sold until 31 December 2021. However, if EU regulations change during this period, CE marking may no longer be accepted in the UK before 31 December 2021 (products must comply with UKCA marking requirements).

A.

UKCA marking may be used from 1 January 2021. However, to allow businesses time to adapt, CE marking is still generally permitted until 1 January 2022 in most cases.

A.
If your product meets the following conditions, UKCA marking must be used from 1 January 2021:
  • The product is placed on the UK market
  • It is covered by legislation requiring UKCA marking
  • The product is subject to mandatory conformity assessment by a third-party Notified Body
  • The conformity assessment is conducted by a UK conformity assessment body, and the documentation has not been transferred to an EU-recognised body before 1 January 2021

Note: Existing stock is exempt. For example, products fully manufactured and ready to be placed on the market before 1 January 2021.

A.

No. From 1 January 2021, if a manufacturer wants to place products on the UK market, they must appoint (or choose to appoint) an authorised representative or responsible person based in the UK.

A.

UKCA marking applies to England, Wales, and Scotland, but not Northern Ireland. Products in Northern Ireland require CE marking or the UK (NI) marking.

A.
  • If resizing the UKCA mark, it must be scaled proportionally
  • The UKCA mark must be at least 5mm in height, unless otherwise specified by regulations
  • The UKCA mark must be clearly visible (from 1 January 2023, it must be permanently affixed to the product)
A.

Before 1 January 2023, for most goods (except those subject to special rules), the UKCA mark may be affixed as a label on the product or accompanying documentation. From 1 January 2023, in most cases, the UKCA mark must be permanently applied directly to the product.

A.

The content required for the UK Declaration of Conformity (DoC) is the same as the CE DoC. However, it is important to note that applicable regulations and referenced standards are UK-based rather than EU-based.

EU legislation UK legislation
Restriction of the use of certain hazardous substances in electrical and electronic equipment 2011/65/EU and amendment (EU) 2015/863 The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 (as amended)
IEC 62321 BS IEC 62321
EU legislation UK legislation
Restriction of the use of certain hazardous substances in electrical and electronic equipment 2011/65/EU and amendment (EU) 2015/863 The Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012 (as amended)
IEC 62321 BS IEC 62321
A.

According to current UK government guidance, you may continue to use the CE marking for products placed on the UK market until 1 January 2022.

References:

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