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WEEE/RoHS - China and EU Comparison
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RoHS: Restriction of the use of certain Hazardous Substances in Electrical and Electronic Equipment Directive
A European Community directive that was passed on February 13, 2003 along with the Waste Electrical and Electronic Equipment Directive. This Directive bans the placing on the EU market of new electrical and electronic equipment containing more than agreed levels of lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE) flame retardants. China RoHs was implemented in March of 2007; it is very similar to EU RoHS but has different qualifications for labeling, concentration, and other requirements.
| EU RoHS |
China RoHS |
| Products must be fully compliant by July 1, 2006 |
Products compliant after March 1, 2007 |
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| 6 RoHS substances must not be present in homogenous materials, unless covered by exemption. |
1. All EIPs (Electronic Information Products) must be marked to indicate what, if any, substances are present.
2. Substances will be listed in a catalog, restrictions will be specified (Spring 2008). |
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Restricted Substances:
Lead
Cadmium
Mercury
Hexavalent Chromium
Polybrominated Biphenyl (PBB)
Polybrominated Diphenyl Ether (PBDE) |
Restricted Substances:
Lead
Cadmium
Mercury
Hexavalent Chromium
Polybrominated Biphenyl (PBB)
Polybrominated Diphenyl Ether (PBDE)
*Possibility of others being added |
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| No marking requirements |
Marking requirements include:
Pollution control and recyclability mark. |
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If no RoHS present:
If RoHS substance is present in at least one material. The Environment Friendly Use Period is the number within the label:
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Compliance is self declared. Third party testing is not required.
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Compliance is self declared, for marking of all EIPs. Testing of substances listed in catalog will be performed by authorized laboratories in China. |
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Source: National Weights & Measures Laboratory; China RoHS Solutions; RoHS International - Ltd.
WEEE and RoHS Frequently Asked Questions
I build systems, as opposed to selling discrete products. Am I affected by WEEE?
WEEE applies to any EEE put onto the EU market and collected as waste at end of life, as long as it fits into one of the ten categories listed in the Directive. It makes little distinction between products put on a retailer’s shelf and something custom-made for an end customer. Many systems fall under Category 3 (IT and telecommunications equipment).
I make equipment that is sold to the military and/or the government. Am I covered by WEEE? RoHS?
The WEEE Directive excludes EEE which is connected with the protection of the essential interests of the security of Member States, arms, munitions, and war material. The exclusion does not, however, apply to the products which are not intended for specifically military purposes.
RoHS does not cover military equipment that is the common view in Europe, however different countries have different views. If you are selling to a government, the best advice is to check with that government regarding their policy.
Are medical devices and monitoring and control instruments covered by WEEE? RoHS?
These types of EEE are covered by WEEE, but are currently excluded from EU RoHS. Revision of medical devices to be included in RoHS is underway by the European Commission. It is unlikely that any inclusion would enter into force before 2010 at the very earliest.
What are the criteria for determining whether a product falls under the WEEE Directive?
Equipment must be "dependant on electric current or electromagnetic fields in order to work properly, and equipment for the generation, transfer, and measurement of such currents and fields". The equipment needs electricity as its primary energy to fulfill its basic function, when electric current is off it cannot fulfill its primary function.
Can I register for my Europe-wide WEEE obligations in one EU country, or do I have to register in all 27?
Producers must register in all EU countries where EEE is being put on the market, in every country where you are responsible for the products coming into Europe. If your distributors/re-sellers sell your products elsewhere in the EU, someone will have to register in those countries, usually the distributor/re-seller.
Does the substance ban under RoHS Directive apply to the production process?
It is understood that the substance ban refers to the final product and not the production process.
Which products are in the scope of China-RoHS?
China-RoHS is much broader than EU-RoHS and includes all "Electronic Information Products" (EIPs). These include radar equipment, IT, telecom, production equipment used for making EIPs, some types of test instruments, medical devices, electronic components such as resistors and ICs, batteries, PCBs, materials, and certain household appliances. The Chinese government has published guidance which lists well over 1800 EIPs.
Source: U.S. Department of Commerce; U.S. Commercial Service
(Last Modified: March 25, 2008; Next Update Date: Available Upon Request)
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Tags/Labels:
Electronics,
China,
Standards & Regulations
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