You may just be catching your breath after having implemented plans to deal with European RoHS and then Californian RoHS, but did you know that in March 2007, the first part of China's RoHS law comes into effect, and this is a very different creature. Although at the heart of the legislation is a ban on the six same substances (lead, mercury, cadmium, hexavalent chromium, PBB's, and PBDE's), complying with European RoHS won't ensure you are compliant to the Chinese version.
The scope of the law is limited to Electronic Information Products ("EIP"), which are imported into China or manufactured in China, for use in China; products manufactured in China for export are not regulated. China's definition of EIP is wider in scope then the European definition. A detailed list of all of the product types governed can be found here: http://www.aeanet.org/governmentaffairs/gabl_HK_Art3_EIPTranslation.asp.
The first part of China's RoHS law is a labeling and disclosure requirement. If a product manufactured after March 1, 2007 contains any of the six regulated substances, that must be noted on the product label. The quantity and location of the substance within the product must be identified within a table in the product literature. Additionally, packaging materials must be identified on the outer package, and the date of manufacture must be marked on the product.
The next part of the law has yet to be published, but it will be a catalogue, listing the acceptable levels of the six controlled substances for each category of regulated electronic information products. There are currently no exemptions, but there may be when the catalogue is published.
Testing and marking responsibilities exceed the requirements of European RoHS in many ways. Marking and disclosure requirements are rigorous, more then simple self-declaration. Detailed testing of every homogeneous component may be required, and testing may only be acceptable if done by a Chinese lab.
As for MG Chemicals' products, it does not appear that any of our products fall into any of the categories of EIP's listed.
China's RoHS law is a very wide ranging detailed law. It included responsibilities for China's government, and other aspects such as the product design process and product packaging. This article should not be used as legal advice; it is only intended to give an brief overview of a few of the many pieces of this law. Those wishing more information can read a translation of the law here. Those wishing to contact the Chinese government about RoHS can use chinarohs@mii.gov.cn as a point of contact.
Stay tuned, apparently both Korea and Taiwan are coming up with their own versions of RoHS, due out in 2008.
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You may just be catching your breath after having implemented plans to deal with European RoHS and then Californian RoHS, but did you know that in March 2007, the first part of China's RoHS law comes into effect, and this is a very different creature. Although at the heart of the legislation is a ban on the six same substances (lead, mercury, cadmium, hexavalent chromium, PBB's, and PBDE's), complying with European RoHS won't ensure you are compliant to the Chinese version.