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GPC prepares for China RoHS - and other variants

Sydney - March 2007

It had to come. The European Union (EU) is now not alone in enacting RoHS legislation. An increasing number of other countries are rolling out their own variants – and they are different from each other.

The EU directive became effective on the 1st July 2006, along with Japan. However the following countries are adopting similar legislation on the following dates:

California RoHS                  1st January 2007
China RoHS                       1st March 2007
South Korea RoHS             1st July 2007

The EU directive identified six substances as toxic and has set Maximum Concentration Values (MCV) allowable:

  • Lead
  • Mercury
  • Cadmium
  • Hexavalent chromium
  • Polybrominated biphenyl (PBB)
  • Polybrominated diphenyl ether (PBDE)

Whilst the EU directive may not have impacted many companies, it appears that as the net widens, companies are going to be affected by environmental compliance initiatives like RoHS, WEEE, REACH & ELV, regardless of where they ship their products.

Increasingly, other countries and states (Nova Scotia and even Wal-Mart for example) are embracing some form of RoHS or recycling laws. However with no common standard, designers will need to “green” their designs as much as possible to counter future implementations.

China is the first to implement a variant of the EU’s direction.

Material restrictions don’t take effect on the 1st March 2007, only mark & disclosure requirements. The in-force date, extent of the restrictions and scope will be defined in a “catalogue”. Drafting may take many months however, it is expected the first draft will be available sometime in 2007.

How is China RoHS different to the EU directive?

The main differences are:

  1. Scope. Where the EU directive lists a myriad of exclusions, China RoHS includes most of these. There are no exemptions…yet. It is expected these may be defined in the catalogue.
  2. Lower thresholds of hazardous substances. For example, although China RoHS allows any components that are <4mm3 to be treated as homogenous materials and permits 1000ppm to be applied at the component level, most EU RoHS compliant resistors contain well in excess of this level of lead by weight. Some suppliers are reluctant to release MCV information due to IP concerns.
  3. More than one effective date. Substance restrictions and pre-market certification dates will be addressed in the first publication of the catalogue.
  4. Labelling. The initial requirement relating to the 1st March 2007 effective date is for marking and disclosure of any banned substances using labelling that defines whether or not the products contain any of the six hazardous substances. If they are present, the "Environment-Friendly Use Period" (EFUP) must also be determined and indicated including packaging. Date of manufacture must also be marked.
  5. Declarations in Chinese. Detailed marking and material disclosure is required for all products shipped into China. All declaration tables are to be written in Chinese.
  6. Certification by Chinese labs. Items included in the catalogue will be subject to pre-market testing and certification. Only test results from Chinese lab will be accepted.

Chinese law does not cover Hong Kong until 2047 so products supplied from here will be treated as “imports”. It is also not clear how this law will affect the current China Compulsory Certification (CCC) system.

Despite China being well known for not rigorously enforcing Intellectual Property laws, they are serious about the environmental laws and there should be no assumption that China will not enforce RoHS.

How can GPC Electronics help with compliance?
GPC Electronics helps customers to prepare for RoHS issues by providing:

  • BOM scrubbing & documentation.
  • Management of the phasing out of non-compliant components and phasing in of new components.
  • Totally RoHS compliant processes.

About GPC Electronics
GPC Electronics is an electronics contract manufacturer based in Penrith (Sydney) Australia. Additional manufacturing sites are in Christchurch (New Zealand) and Shenzhen (China). The company produces complex electronics equipment for leading global corporations. Rather than simply following customer instructions to build products, GPC Electronics helps its customers to achieve their strategic goals through greater responsiveness, overall lower cost and improved flexibility.

(Additional information at:

Bradley Ayres
Customer Support Manager
GPC Electronics
61 2 4737-6625