China RoHS Overview. inemi Life after EU RoHS Forum Chicago, IL Sept. 28, Tom Valliere, Sr. Vice President Design Chain Associates, LLC

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1 China RoHS Overview inemi Life after EU RoHS Forum Chicago, IL Sept. 28, 2006 Tom Valliere, Sr. Vice President Design Chain Associates, DCA.7676 Marvel Entertainment, Inc. 0

2 China RoHS Update 1

3 China RoHS: What s the Title? Administration on the Control of Pollution Caused by Electronic Information Products (Official Chinese Translation) Or Measures for Administration of the Pollution Control of Electronic Information Products (Ministry of Commerce of PRC Translation) Or Administrative Measures on the Control of Pollution Caused by Electronic Information Products (WSGR Translation) Or Management Methods for Controlling Pollution by Electronic Information Products (AeA Translation) Everyone just calls it CHINA RoHS 2

4 EU-China Comparison Issue EU China Material Restrictions Common Date Law Passed 23-Feb Feb-06 Effective Date 1-Jul-06 1-Mar-07 Three Marking Requirements: Restricted Marking None Materials, Environment-Friendly Use Period, Packaging Materials Scope 10 Categories, Very Broad MII's Scope - "Electronic Information Products": EU RoHS Scope + ELV, Medical, Radar, Components, Materials - Household Appliances, Toys, Tools... Exemptions N/A - Catalog defines Included Products; Material Application may also define material application Exemptions Defined; Can be "exemptions" (removed from draft mark petitioned standard); no formal petition process yet Packaging Materials Out of Scope Non-toxic/Recycleable, Disclosed in mark Production Materials Out of Scope Restricted per material restrictions Put On The Market Testing/Certification Confused and inconsistent definition across member states. Basically allows limited channel stuffing Not a prerequisite No Channel Stuffing. Each step in the chain from dock to retail shelf must be compliant on the effective date Is a prerequisite (Chinese Lab test results only) for Catalog items 3

5 Material Restrictions (Article 3) Lead Mercury Cadmium Hexavalent chromium Polybrominated biphenyl (PBB) Polybrominated diphenyl ether (PBDE) and 4

6 Material Restrictions (Article 3) Other toxic and harmful substances or elements provided by the State commonly used terminology in Chinese laws will follow WTO rules for notification Don t expect any additions in the near-term Restriction limits defined in Requirements for Concentration Limits for Certain Hazardous Substances in Electronic Information Products standard Consistent with EU except components smaller than 4mm 3 considered homogeneous Testing methods defined in draft of Testing Methods for Regulated Substances in Electronic Information Products English translation available for purchase at 5

7 The Scope Article 3 (Definitions) Describes Scope: Compared to EU RoHS it s very different: IN: Radar systems, Medical devices and products, Automotive electronics, Electronic test equipment, Semiconductor (and other electronic component) manufacturing equipment, and all manner of electronic components including Batteries, Sensors,Optical fiber, and the materials that comprise many of these components OUT: Categories 1 & 2 (home appliances); Category 6 (tools); Category 7 (toys); Category 10 (Dispensers) Otherwise fairly common But Be Careful! Parts used in products that are out of scope are in-scope: Components Electronic Toy circuits Washing machine motors ONLY when sold separately (i.e. for repair) they must comply 6

8 Example: Semiconductor Equipment Semiconductor Device and Integrated Circuit Dedicated Equipment is in scope: Semiconductor Preparation, Epitaxy and Chemico- Mechanical Polishing Exposure, Corrosion, Gel Homogeneity and Developing Equipment Diffusion, Ion Implantation and Quick Heat Treatment Equipment Chemical, Physical, Vapor Disposition and Copper Plating Equipment Subsequent Assembling and Package Producing Equipment Online Process Testing Equipment Intermediate and End Product Testing Equipment Electronic Components Assembling Equipment 7

9 So are Semiconductor Materials Wafers Bond wires Encapsulants Packaging material Photomasks Photoresist And so on Detailed Scope Document at DCA s website, courtesy of AeA 8

10 China Takes A Two-Phase Approach Phase 1: In Force March 1, 2007 All Electronic Information Products (EIPs) within the scope must meet the marking and disclosure regimens for Hazardous material content Packaging material content The Environment-Friendly Use Period must be indicated Phase 2: In Force TBD The Catalog (Article 18) will define Which EIPs are subject to material restrictions The extent of the material restrictions (including exemptions) The in-force date for the restrictions To be reviewed/amended annually The first Catalog is expected later this year no official timetable 9

11 Exemptions: Comparisons With The EU are Absurd EU includes nearly everything then describes exemptions you figure out if they apply China describes only what is included; only appropriate exemptions will be included EU: Yang? China: Yin? Expect the Catalog to document scope and exemption inquiry processes 10

12 Certification Requirements (Art. 18) All Covered Products listed in the catalog: subject to compulsory certification by the State certification and accreditation authorities Will be added to existing CCC (China Compulsory Certification) mark system Imports In To China: subject to examination and inspection at the entry port by inspection and quarantine authorities Certification issued at that point; product then is released from Customs No EU RoHS analog Testing required to homogeneous material level Certified Chinese labs only!!! Testing of Components is acceptable you do not need to submit the final product to destructive testing! 11

13 Three Marking Requirements 1 - Environment-Friendly Use Period (Article 11) 2 - Packaging Materials (Article 14) 3 - Hazardous Material & Contents (Article 13) Mark below plus next page Any eye-catching color can be used if orange does not contrast enough EU RoHS has no marking requirements No Toxic Subs Contains Hazards 12

14 Material Disclosure Materials described in Article 3 must be disclosed by component: X substance is present O substance not present They are looking for PRESENCE, not CONCENTRATION values! Disclosed in brochure/manual for final EIP Marking is ONLY necessary for sales to end customer of end product Website OK but not adequate In Chinese (example shown in English, below) Component Name Hazardous Substances or Elements Lead (Pb) Mercury (Hg) Cadmium (Cd) Chromium VI Compounds (Cr 6+ ) Polybrominated Biphenyls (PBB) Polybrominated Diphenyl Ethers (PBDE) 2N2222A X O O O O O Enclosure, Top X O O O O X Main Chassis O O O X O O 13

15 Environment-Friendly Use Period? What the heck is that? Article 3(5) says: the term during which toxic and hazardous substances or elements contained in electronic information products will not leak out or mutate Lead-acid batteries? PBDE outgassing? Clearly not even MII knows what it really means Article 11: relevant industry organizations may provide guidance on what it means Article 12: MII encourages relevant industry organizations to submit their guidance EIP Environment and Pollution Guidance Committee is defining guidance Recommendation: Get in touch with the relevant industry association for your product in China. They may be able to help 14

16 Standards Status Industrial/ Sectoral Standards that define marking and MCV requirements are now out in final draft form as of 4/18/06 Requirements for Concentration Limits for Certain Hazardous Substances in Electronic Information Products Marking for the Control of Pollution Caused by Electronic Information Products MII plans to issue them September 10, 2006 National Standards after final standards are issued Following are out in draft form: General Disassembly Requirements for Testing Hazardous Substances in Electrical and Electronic Products Testing Methods for Regulated Substances in Electronic Information Products Test Method for lead-free Solder 15

17 Penalties (Articles 22, 23, 24) Penalties addressing violations of certain articles by designers, producers, importers, and sellers are to be developed by various authorities Article 15 requires Strict procurement channels i.e., no more AQS or order by description parts EU RoHS does not directly legislate this, but in effect it does Penalties will also be developed covering government workers [who] abuse their power, practice graft for personal gain,connive and shield their actions or assist parties in violation of the provisions BUT Article 8 provides for recognition and incentives for organizations and individuals that have made outstanding achievements in the work of the control of pollution by electronic information products and related activities. 16

18 Production Equipment (Article 10) Potential Impact to PCB and PCA Manufacturing Requires use of materials, technologies and processes which are energy efficient, easily recyclable and environmentally friendly No Restricted Substances EU RoHS Has No Such Requirement E.g., Lead or Hex Chrome used for PCB Sacrificial layers are OK for EU. May not be for China 17

19 China Next Steps Read it Yourself AeA and PRC MoC English Translations of the law and the scope DCA English Translations of Marking & MCV final draft standards as well as DRAFT standards for Testing Methods for Regulated Substances and General Disassembly Requirements Understand Your Liabilities Technical Review Business Review Legal Review Stay Abreast! Final Standards not out yet Start collecting COMPLETE material composition on the components used to build your products IMMEDIATELY 18