February 8th, 2007
Folks,
Guest blogger Krista Botsford of 5-Trees joins us today to discuss China RoHS. Her comments follow:
China RoHS is confusing. With no official translation available, and no official direction form the Chinese Government, industry is reliant on interpretation and unofficial translations. AeA has been instrumental in assisting with information on the evolvement of the China RoHS legislation. China RoHS has a phased approach; the most immediate being Phase 1: Labeling. The labeling requirement begins 01 March 2007 (i.e. in 21 days!) for Electronics Information Products (EIP's). The products are not exactly the same products as the EU's RoHS. Some products outside the scope of in the EU are in-scope with China; others in-scope in the EU are out of scope in China.
Definition of EIP: from AeA Translation of "China RoHS"
Electronic information products refer to the products and accessories manufactured with electronic information technology including electronic radar products, electronic communication products, broadcasting and television products, computer products, household electronic appliances, electronic surveying instruments, specialized electronic products, electronic components, electronic application products, and electronic material products.
The labels required for 01 March 2007 are in the image above. If there are no toxic or hazardous substances or elements contained in the products, logo 1 is applicable. If products contain any toxic or hazardous substances or elements, logo 2 is applied to the product. In addition, names and contents of toxic or hazardous substances shall be specified in the user manual. The suggested color for the marking in logo 1 is green; and logo 2 is orange. If the color matches or the color does not contrast with existing color of the product, a suitable replacement is acceptable. The number inside logo 2 is the environmentally-friendly use period. This is the number of years the product can be used without releasing any of the hazardous substances into the environment.
In the user manual, the table above (Source: AeA Unofficial translation of "China RoHS") is to be published with the materials information. The table must be published in Chinese.
Krista Botsford, 5-Trees LLC
kbots@5-trees.com
781.552.9585
Jim Hall:
Dear Dr Ron,
We have received reports that XRF instruments have identified Lead on unpopulated PCB's with Lead-Free surface coatings which had been processed in a cleaner which was also used for lead bearing PCB's. Is this a violation of RoHS, I agree no. But it emphasises the need for careful calibration and interpretation of results from instruments used to validate RoHS compliance.