China RoHS II v. EU RoHS II – What’s the Difference?

by Brittany Tofinchio Palmer

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China’s new Restriction of the Use of Hazardous Substances in Electrical and Electronic Products (RoHS II) regulation was issued on January 21, 2016 and is set to enter force on July 1, 2016.  One of the main changes from China’s RoHS I regulation is the expansion of products from electronic information products to all listed electrical and electronic products with voltages not exceeding 1500 volts (V) direct current and 1000V alternating current.  However, power generation, transmission, and distribution equipment is excluded from the definition.  The same hazardous substances as in RoHS I will be subject to the regulation: cadmium and its compounds, mercury and its compounds, hexavalent chromium and its compounds, lead and its compounds, polybrominated diphenyl ethers, and polychlorinated biphenyls (PCBs).  In addition, all electrical and electronic products will require one of two logos to accompany it depending on whether it contains any of the hazardous substances listed above.  If no hazardous substances are present, a green symbol with arrows and an “e” in the middle of it will be used.  If hazardous substances are present, the same style symbol but in orange will be used.  The symbol will have a number in it as opposed to an “e”, indicating the number of years it can be safely used before needing to be recycled.

So what’s the difference between China’s new regulation and the European Union’s (EU) RoHS II regulation? There are several that are significant. The first is the scope of electrical and electronic products covered. China will eventually publish a list of specific products subject to regulation in a Compliance Management Catalogue, while in the EU, all electrical and electronic products are applicable and regulated unless specifically exempted.  The second is markings whereby each regulation has specific logos or marks that must be used, but China has an additional provision that requires the names of the hazardous substances used in a product to be published in the product’s instructions.  As far as compliance, in China, testing by a third party is required where the EU relies on self-declarations.  The last main difference is the regulated restricted substances. The EU regulates the same six substances that China does, but the EU added four additional phthalates in 2015.