China RoHS: It's Here ... Ready or Not!

Bookmark and Share

China RoHS: It’s Here … Ready or Not!

SEMI offered a webcast on China RoHS in direct response to member needs. The February 27 webcast featured Tad Ferris, a leading expert on China RoHS, and a case study by Steve Brody from Brooks Automation. The session was moderated by Aimee Bordeaux of SEMI (EHS Division).

Ferris began with a brief overview of China RoHS. In February 2006, the Chinese government issued tough new environmental labeling regulations for electronic information products (EIP) that are imported into, or manufactured in China for domestic use. These regulations went into effect March 1, 2007, and comprise the first phase of China’s overall mandate “Management Methods for Controlling Pollution by Electronic Information Products,” which is commonly called “China RoHS.” In the second phase, starting at an undetermined future date, a subset of EIP will be compiled in a “Catalogue” and subject to restrictions of six toxic substances—the same substances covered in the European Union’s RoHS Directive—as well as pre-market testing and certification. The regulations address China’s growing concerns about the environmental and health effects of toxic substances in EIP. A significant amount of semiconductor equipment, components, and even semiconductor materials are included as EIP, and subject to the new labeling standards.

Ferris answered a few basic, but still complex, questions about compliance. For example, if you provide China RoHS “covered products” to other businesses (i.e., a B2B situation), are you subject to China RoHS requirements? Then he launched into the fundamentals by reviewing guidelines provided by China’s Ministry of Information Industry (MII)—the lead agency in developing and interpreting China RoHS. The presentation covered the latest interpretations of the requirements to help semiconductor equipment manufacturers answer key questions about the first phase of China RoHS, such as:

  • If your product was manufactured before March 1, is it covered under China RoHS?
  • How do you determine if your company is subject to the labeling and information disclosure requirements?
  • Is it possible that your company is entitled to one of the many “exclusions” to the legislation (some parts for maintenance, prototypes, etc.)?
  • How should you determine my company’s “environmental protection use period (EPUP)”? Do spare parts and second-hand equipment need to be labeled?
  • Which labels go on what kinds of products?
  • What about the “irregular shape” exception?
  • Can your company avoid having clean packaging opened for a “China RoHS” inspection?
  • What steps can your company take to avoid delay by port authorities when importing products into China?

Next, Steve Brody from Brooks Automation explained how his company prepared for China RoHS compliance. He explained how they chose an EPUP number and decided which products get labeled and the location of the labels. He discussed decisions about “spares, replacements, and upgrades,” hazardous substance location tables, and next steps. If you are looking for an example of how one company methodically approached the process, review the Brooks Automation slides.

Finally, the webcast offered participants the opportunity to ask questions. Over 50 questions were submitted. Due to time constraints, only five questions were answered, including questions on: printed circuit board “spares,” spot checks on “clean room environment” boxes, and intellectual property (IP) concerns if China RoHS requires laboratory examination of the product.

The webcast did not delve into the next phase of the China RoHS legislation. China’s Ministry of Information Industry (MII), the lead agency in developing China RoHS, may play a key role in forcing changes in our industry as it delineates the next phase of the mandate—which involves EIP material restrictions and pre-market testing and certification requirements. SEMI will keep you updated on the “Catalogue” portion of the China RoHS legislation.

If you would like to listen to the webcast, please register at this website:

For access to the presentation slides, please visit and click on China RoHS presentation slides. You must be a SEMI member to access these slides.

The SEMI EHS Division tracks numerous topics and regulations of interest to SEMI members. For more information about EHS issues, programs, and committees, go to

This article is intended for general guidance and background information only, not for decision making. Seek a qualified advisor for specific advice.

Additional resources on China RoHS:

For information, please contact:

Sanjay Baliga
Senior Project Manager
Environmental, Health, and Safety (EHS)