Presented by:Bruce CalderVP Consulting Services

China RoHS 2 FAQExplanation of new FAQ - June 10 2016

Overview - Agenda• Introduction

• New China RoHS Law

• Overview

• Structure

• FAQ

• China RoHS FAQ

• Key clarifications from the new China RoHS FAQ

• Further questions submitted to Claigan

• Table location options

• EFUP

• Product level versus product line level tables

• Summary

• Q&A

Claigan Overview

• Principal Services- Consulting

- Laboratory testing

- Data gathering

• Experience- Wide range of professional, medical, industrial,

and consumer companies

RoHS, REACH SVHC, REACH Registration, Conflict Minerals, Batteries, Packaging, Persistent Organic Pollutants, Proposition 65, California Transparency in Supply Chains, UK Modern Slavery, and more….

Claigan - Update Services• Monthly or Quarterly

Updates - Custom webinar

- On the changes in requirements

- Impacts to your specific products

- Monthly or Quarterly

- Interactive

- Translated version of the China RoHS 2 FAQ to be provided to Claigan’s quarterly update clients.

Claigan - China RoHS• Claigan services

- Hazardous material table generation

- From current data, or from

- Testing / screening of your products

- Offsite at Claigan, or

- Onsite at your site

New China RoHS Law• On January 6, the New China RoHS law was published

- “Management Methods for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products”

- Goes into effect 1 July 2016

• Highlights- New definition of EEE (same as EU RoHS)

- EU RoHS scope of products

- Table and labelling- To the new China RoHS standard (SJ/T 11364-2014)

- No restrictions yet

New China RoHS FAQ• New China RoHS FAQ Released

- FAQ for China RoHS 2- Only available in Chinese

- Claigan working on a translation

- Will be available to Claigan’s monthly/quarterly update clients next week.

• FAQ- http://www.miit.gov.cn/n1146290/n4388791/c4777797/part/

4777801.pdf

China RoHS

China RoHS Law(Management Methods for the Restriction

of the Use of Hazardous Substances in Electrical and Electronic Products)

SJ/T 11364-2014Product Labelling Standard(Marking for the restriction of hazardous

substances in electrical and electronic products)

Mandatorylabelling of content and recyclability

Packaging marking if mandatory standard exists

GB/T 18455-2010Package recycling marking

Standard only ‘recommended’

Restriction of substances if catalog exists

No catalogs at this time

Restriction CatalogsProducts and Exemptions

China RoHS Standard• Key China RoHS Standards

- SJ/T 11364-2014 (hazardous materials table)

- SJ/Z 11388-2009 (EFUP number calculation)

- GB/T 26572-2011 (restricted substance concentration limits)

- GB/T 18455-2010 (packaging recycling marks)

China RoHS FAQ• Overview

- “Management Methods for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products”

- 8 pages

- China RoHS FAQ

- 34 pages

• Key details- Explain key definitional issues that were not clear in the initial law

or related standards

China RoHS FAQ - Webinar Format• China RoHS 2 FAQ

- Fifty-six (56) questions and answers (in Chinese)

- Many cover the same topics

• This webinar- Will focus on the principal concepts that have impact on product

compliance

- But we will not go question by question … for 56 questions

China RoHS FAQ - Fundamentals - Dates• EU RoHS

- Placed on the market

- Date of import or release to distribution in the EU

• China RoHS- Date of manufacture

- As labelled on the product

- Applies to

- July 1 2016 entry into force of China RoHS law

- EFUP number

Mandatory Requirement - July 1 2016• Deadline for implementation of SJ/T 11364-2014

- July 1 2016

• Impact- Products with a date of manufacture after July 1 2016 need to be

compliant with SJ/T 11364-2014 or they cannot be sold in China.

- and

- expect a decent number of panicked / confused inquiries from customers

Fundamentals - Finished Products• EU RoHS

- Scope

- EU RoHS applies only to finished electrical and electronic products

- Components have the compliance requirements of the products they are incorporated into

- Repairs and upgrades to products have the compliance requirements of the products they are repairing or upgrading.

Fundamentals - Finished Products• China RoHS

- Scope

- China RoHS also applies only to finished electrical and electronic products

- Components no longer have separate requirements under China RoHS

- Components have the compliance requirements of the products they are incorporated into

- And are to be under scope of the table of the finished product they are integrated into

- Repairs and upgrades to products have the compliance requirements of the products they are repairing or upgrading

- And have no table requirement of their own

Recap - Components• Components

- Table and EFUP label

- Components no longer have a requirement for their own China RoHS table or EFUP label

- Repairs and upgrades are to be assumed to be included in the table of the product they are repairing or upgrading, but there is no specific requirement their neither have any requirement for a table or label.

Components - Continued• Cables

- Sold with or intended for a product

• Included under that product’s table and label

- Sold separately without an intended end product

• Need their own table and label

- Very similar to EU RoHS (cause for inclusion)

Replacement and Accessories• Ancillary Parts

- Accessories that are necessary to a product’s function are under the scope of that product China RoHS table and label

- Accessory products that have stand alone function and are not necessary to the function of that product need their own table and label

• ie. mouse, keyboard

• Full product replacement- A full product replacement is considered to be a new product

and have the compliance requirement of that date

Scope• Scope / Territory

- Does not apply to Hong Kong, Macau, and Taiwan

• Sale vs. lease vs. gift- All constitute ‘sales’ for the purposes of placing a product under

scope

• ‘Other’ Category- Can an ‘other’ line item be used in the hazardous materials table

for hard to define parts?

• No. Specifically not allowed.

• Hazardous Material Table - Component Listing- There are no specific rules regarding how to list components or

assemblies in table, as long as it is comprehensive

- Each row can be a different component or a group of similar components

• Expanded information- The manufacturer can provide expanded information on the

restricted materials and recommendations for proper handling, but cannot replace the mandatory elements of the restricted materials table

Hazardous Materials Table

EFUP Number• EFUP Date

- From date of manufacture of the product

- Irrespective of importation date

• Multiple EFUP numbers- If a product contains multiple components using multiple EFUP

numbers,

• each component is allowed its own EFUP number

• but the product can also be governed by an EFUP number for the whole product

• EFUP in Battery Compartment- The EFUP number / nameplate of the product can go into the

battery compartment if the battery is removable by the end user

Miscellaneous Information• Future substances

- Confirms that China RoHS 2 is written in a manner to add restricted substances (such as phthalates) in the future

• Non-Removal Batteries- Non-removable batteries should be listed as a row in the

hazardous materials table.

• Product packaging - Marking of material content of product packaging (plastic and

paper type) is only recommended, not mandatory

Non-Compliance• Q56. After the "Rules" enter into effect, even if the end

producer has a good green supply chain management system, if due to reasons within the supply chain the final producer is found to be out of compliance with statutory requirements, who is responsible for this expensive issue, the final producer or the upstream supplier?

• A: If the final producer is found to be out of compliance with the "Rules", then even if the problem was caused by the upstream supplier of parts or components, liability is borne by the final producer. Upstream supplier liability must be pursued independently by the final producer of the product.

• Submitted to Claigan by a webinar registrant

• Does China RoHS 2 allow the manufacturer (outside China) to make the material declaration via a website or does it have to be shipped with the product?

• The hazardous materials table needs to be either- On a label on the product,

- In the instruction manual,

- By a link in the manual referring, in simple Chinese, to a web page,

- As a print delivered with the product documentation,

- In a CD/DVD provided with the product, or

- Accessible in the software of the system as long as instructions to find the table in the system software is included in simple Chinese in the manual.

Industry Questions - Question 1

• Submitted to Claigan by a webinar registrant• I would be particularly interested to learn how one comes up

with a number for the EFUP. Are there any official Chinese government guidelines? If not, are there industry practices, guidelines or at least suggestions? Are there acceptable min-max numbers and do they vary by product type/category?

• Officially- Standard: SJ/Z 11388-2009

- EFUP =

- Technical life of the product + the time between manufacturing date and put into service date

- In practice, life expectancy of the product

Industry Questions - Question 2

• Submitted to Claigan by a webinar registrant• Do I need a hazardous materials table for every product or can I

have a single table that covers a group or family of products?

• Hazardous materials table- Every product under scope of China RoHS needs a hazardous materials

table

- However, the same table could be used for family, groups, or product lines

- The key requirement

- The table can be used by the end user or recycler to identify the locations with hazardous materials

Industry Questions - Question 3

Summary• Scope

- Same categories as EU RoHS

- Finished products only

- Components no longer directly under scope

- Based on the date of manufacture

• EFUP- Significant clarifications on EFUP numbers

• Table- Needs to be in place to SJ/T 11364-2014 by July 1 2016

• Non-compliance- Is the responsibility of the final product manufacturer even if

caused by a supplier

Claigan - Update Services• Monthly or Quarterly

Updates - Custom webinar

- On the changes in requirements

- Impacts to your specific products

- Monthly or Quarterly

- Interactive

- Translated version of the China RoHS 2 FAQ to be provided to Claigan’s quarterly update clients.

• Claigan services - Hazardous material table generation

- From current data, or from

- Testing / screening of your products

- Offsite at Claigan, or

- Onsite at your site

Q/A time

Claigan - China RoHS