'China RoHS', REACH & other EHS Topics of Current Interest
Links to Information on EHS Topics of Current Interest
COMPARISONS of SIMILAR LAWS in DIFFERENT JURISDICTIONS
A growing issue for industry is the ongoing implementation of EHS laws in different jurisdictions that have similar goals but different requirements. Lack of global harmonization may cause unnecessary cost and effort and create unintended barriers to compliance through the resulting complexity. An example of this is the proliferation of RoHS-like legislation.
RoHS-like Laws in Different Jurisdications
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David Ling, Manufacturers’ View on RoHS-like Regulations, presented at 6th Conference on Standards and Conformance, Da Nang, Vietnam, 5-6 September 2006.
Mr. Ling is the Regulatory Policy and Strategy Manager, Worldwide Technical Regulations for HP. To download this presentation, go to the APEC site (http://www.apec.org/) and search on “David Ling” - Northwest Product Stewardship Council’s summary of RoHS-like laws in different jurisdictions
- Charles Barker, Xing Weibing, Comparative Study of European and Chinese Environmental Measures Restricting Hazardous Substances in Electrical and Electronic Equipment, undated, EU-China Trade Project (produced with assistance of European Union). Mr. Barker is affiliated with the British Standards Institution, and Mr. Weibing with the China Electronic Standardization Institute.
CALIFORNIA
- Sections 57018, 57019, and 57020 of the Health and Safety Code, (formerly Environmental Health Bill, AB 289) Enacted in September, 2006, it authorizes state agencies to request from chemical manufacturers the test methods for detecting their chemicals in air, water, soil, and the human body. It shifts the cost of developing the methods to locate these chemicals from taxpayers to the manufacturers profiting from the product. California is the first state in the country with such a law.
- Division 25.5 of the Health and Safety Code, California Global Warming Solutions Act of 2006 (formerly AB 32and SB 1368). Enacted in September 2006.
- “Green Chemistry in California: A Framework for Leadership in Chemicals Policy and Innovation,”California Policy Research Center at University of California Berkeley (and read herefor a statement of its relevance to State of California)
- Electronic Waste Recycling Act of 2003(SB 20/SB 50); and AB 48(by Saldana), which would extend the scope of the existing legislation, which was introduced on December 4, 2006.
- Chapter 8 to Part 5 of Division 103 of the Health and Safety Code(formerly the Biomonitoring BillSB 1379) Enacted in September 2006. Requires establishment of a California Environmental Contaminant Biomonitoring Program to monitor the presence and concentration of designated chemicals in Californians.
- Adoption of NFPA 1 and 5000 by California (see this May 2004 presentation by Reinhard Hanselkaand other presentations from seminar on A Paradigm Shift in California Building and Fire Codesand Evaluation of 2003 Model Codesby Office of Statewide Health Planning and Development)
CHINA
China Compulsory Product Certification (CCC) Mark
- Certification and Accreditation Administrationof People's Republic of China (CNCA)
- China's CCC Mark: A Guide for U.S. ExportersFrom the Office of the Chinese Economic Area, U.S. Dept. of Commerce
- China's CCC MarkProvide overview information, and information on CCC exemption process from the U.S. Dept. of Commerce
- Export.gov, U.S. Government Export Portal’s China’s Laws and Regulationsrelated to exporting to China, including links to information on China Compulsory Certification (CCC) System
- China Compulsory CertificateInformation from the U.K. government (Dept. of Trade's Trade Partners UK)
- CB Schemeby Worldwide System for Conformity Testing and Certification of Electrical Equipment (IECEE)
“China RoHS”
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Key Documents to Guide Implementation of “China RoHS” |
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Note: English translations are all unofficial. The Chinese government only publishes these legal documents in Chinese. If a discrepancy occurs between an English translation and the original Chinese document, the Chinese version takes precedence. |
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“Management Methods for Controlling Pollution by Electronic Information Products”(Ministry of Information Industry Order #39), February 28, 2006 |
This is the framework law commonly called “China RoHS”.
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Electronic Information Products Classification and Explanations, March 16, 2006 |
This document provides a basic list of items currently regarded as “electronic information products” within China RoHS.
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Standard, “Marking for the Control of Pollution Caused by Electronic Information Products,” SJ/T 11364-2006 |
Details for implementing those provisions of “China RoHS” that must be implemented are contained in eight standards, three of which have been published as of January 2007.
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Standard, “Requirements for Concentration Limits for Certain Hazardous Substances in Electronic Information Products,” SJ/T 11363-2006 |
English translation provided by AeA. |
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Standard, Testing Methods for Regulated Substances in Electronic Information Products, SJ/T 11365-2006 |
English translation provided by AeA. |
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Draft standard, “General Rule of Environmentally Friendly Use Period of Electronic Information Products,”
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This document is expected to be finalized before March 1, 2007.
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Standard, Packaging Recycling Marks, GB 18455-2001, implemented 1/1/2002, and referenced by SJ/T 11363-2006 |
English translation provided by AeA. |
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Supersedes early versions of this FAQ.
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Frequently Asked Questions for “China RoHS” standards, published by Ministry of Information Industry, December 2006 |
Please advise Sanjay Baligaif you are aware of a publicly available English translation of this document. |
- SEMI Regulatory Alert on “China RoHS,” October 3, 2006
- SEMI members are invited to email Sanjay Baligato be put on the SEMI mailing list for updated information on this topic, and for access to a SEMI-members only private web site with additional information on “China RoHS”.
- AeA’s overview of China “RoHS”
- AeA’s China RoHS Q&A, January 5, 2007
- Richard “Tad” Ferris, Hongjun Zhang, China’s Evolving RoHS Legal Regime, Circuits Assembly, May 2006
- “China RoHS Solutions” by Design Chain Associates; and two recent articles on China RoHS (click here for article in Compliance magazine, October 2006, on page 12, and article in EuroAsia Semiconductor magainze, October 2006)
- China National Export Commodities Packaging Research InstituteSource of GB 18455-2001, Packaging recycle mark standard that defines requirement for labeling the packaging material of EIP under China RoHS. This standard can be purchased in Chinese from ANSI. See below for unofficial English translation from AeA.
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Other documents related to “China RoHS” translated into English and publicly available. NOTE: these translations are unofficial.
* “China RoHS” or “Administrative Measure on the Control of Pollution Caused by Electronic Information Products”(translated by Grace Compliance Specialist)
* Classifications of Electronic Information Products(translated by Grace Compliance Specialist)
* June 5, 2006 responses to common questions on “China RoHS” by China’s Ministry of Information Industry(an expansion of the March 3 responses; translated by Grace Compliance Specialist; note this is dated 28 Nov 2006, but still only has 36 questions listed, as does the June 5, 2006 translation by WilmerHale below)
* June 5, 2006 responses by China’s Ministry of Information Industry to 36 frequently asked questions on “China RoHS”(translated by WilmerHale)
* Art work (in Adobe Illustrator) for China RoHS labels, December 2006
* Standard, “Lead-free Solders: Chemical Compositions and Forms,”issue date 13 March 2006 (AeA translation) -
Commercial sources of “China RoHS” Guidance Notes/FAQs. CAUTION: Inclusion of a vendor on this list is not in any way an endorsement by SEMI.
* China RoHS Guidance Notes, RoHS-International, January 2006 -
Commercial sources of translated key documents. CAUTION: Inclusion of a vendor on this list is not in any way an endorsement by SEMI, nor does SEMI have any opinion on the quality of the translations:
* From Design Chain Associates
* From SIEMIC, Inc.
* From SIMCON, a complete bundle of China RoHS key documents -
Key documents in original Chinese.
* “Management Methods for Controlling Pollution by Electronic Information Products,”MII web site
* An addendum to the management methods, MII web site
* Electronic Information Products Classification and Explanation, MII web site
* China RoHS Standards Working Group, MII
* Information about MII China RoHS Q&As, 26 February 2007
* Updated MII China RoHS Q&A, 1 December 2006 (total 48 Q&As)
* Updated Q&A for first three published “China RoHS” standards, December 2006
* MII Q&A, 9 November 2006 (superseded)
* Official email for companies to ask questions about China RoHS is ChinaRoHS@mii.gov.cn, December 2006; and related information from MII
* For additional information about China RoHS from the MII, go to this link
* China Electronic News is the official media of the MII, and has published a Q&A on the three standards signed and approved by the minister of the MII on November 7, 2006(i.e., concentration limits standard, SJ/T 11363-2006; marking standard, SJ/T11364-2006; testing methods standard, SJ/T11365-2006) -
NOTE: Final versions of three “China RoHS” standards have been approved by the minister of the MII (“Marking for the Control of Pollution Caused by Electronic Information Products”, SJ/T11364-2006; “Requirements for Concentration Limits for Certain Hazardous Substances in Electronic Information Products”, SJ/T11363-2006; and “Testing Methods for Regulated Substances in Electrical and Electronic Products”, SJ/T11365-2006) and were published on December 1. They are available in hardcopy in Chinese. For purchase details, go to:
http://www.mii.gov.cn/art/2006/11/14/art_1221_26861.html
http://www.sj.cesi.cn/stan-cd/fxdg/dgms.htm
or contact the China Electronics Standardization Institute(CESI) directly at:
+86-10-84029065, or +86-10-84029217.
EUROPE
CE Marking
Corporate Social Responsibility
- New Approach Directives and StandardsThe European Union has adopted a New Approach to technical harmonization and standards to ensure free movement of goods throughout member countries. This site provides detailed information on these directives and standards, including update dates.
EU EMC Directive
- The new EU EMC Directive 2004/108/ECbecomes effective on July 20, 2007
EU Energy Using Products (EuP) Directive
- Directive 2005/32/ECestablishing a framework for the setting of ecodesign requirements for energy-using products and amending Council Directive 92/42/EEC and Directives 96/57/EC and 200/55/EC
- EUROPA page on energy-using products
- U.K. Defra’s Consultation on new regulations on ecodesign requirements for energy-using products, September 2006.
- Market Transformation Program, a program supporting the U.K. government’s policy on sustainable products
EU Optical Radiation Directive (proposed fourth directive on physical agents)
EU REACH Regulation
- EU REACH Site
- European Chemicals Bureau, responsible for developing methodologies, tools and technical guidance needed for REACH through a number of REACH implementation projects (RIPs)
- European Chemicals Bureau, “REACH in Brief”
- European Chemical Industry Council (CEFIC) REACH Web page
- REACH Implementation Projects (RIPs), European Commission
- Lowell Center Chemicals Policy Initiativetracks chemical policy in jurisdictions around the world, not just in the EU
- U.S. Commercial Service’s “Latest on REACH”
- RoHS Enforcement Guidance Document, developed by “EU RoHS Enforcement Authorities Informal Network.” Informative and advisory, but no legal authority.
- European Commission’s summary of legislation, secondary legislation, and eventsrelated to WEEE and RoHS
- White Paper on WEEE and RoHS Directives of the European Union, prepared by the SEMI International Compliance and Regulatory Committee(dated September 1, 2004)
- RoHS: Working with EEE Producers to Deliver Compliance with RoHS in the UK, from the National Weights & Measure Laboratory (NWML)
- Background informationcollected by the U.K. Department of Trade and Industry
- Actions to Take on WEEE and RoHS, advice offered by ElectronicsWeekly.com (10 Dec. 2004)
- Associations with initiatives related to WEEE and RoHS:
- American Electronics Association
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Electronic Industry Alliance(EIA)
Jointly published the final Joint Industry Guide: Material Composition Declaration Guidewith EICTA (European Industry Association), and JGPSSI(Japan Green Procurement Survey Standardization Initiative) -
High Density Packaging User Group
Post somelead-free paperson their site. - IPC’s Lead-free Website, covers not only the EU directives but related ones from around the globe from the viewpoint of the electronic interconnect industry
- National Electronic Distributors Association(NEDA)
- International Electronic Manufacturing Initiative (iNEMI)formerly NEMI
- Orgalime RoHS Guide, updated October 2006. Orgalime also has other information about WEEE and RoHS
JAPAN
Basic Law for Establishing the Recycling-based Society
- English translation of the lawby the Ministry of the Environment, Japan
“Green Procurement Law” or Law Concerning the Promotion of Procurement of Eco-friendly Goods and Services by the State and Other Entities
- English translation of the lawby the Ministry of the Environment, Japan
High Pressure Gas Safety Law
- Summary of the Lawfrom Cabinet Office, Government of Japan
Law for the Promotion of Effective Utilization of Resources
- Overview of the Law, from Ministry of Economy, Trade & Industry (METI)
South Korea
Act for Resource Recycling of Electrical and Electronic Equipment and Vehicles (“Korea RoHS”)
- English translation of the Act passed April 2, 2007, by Jun-sik Yun and In-sung Park, Eco-Frontier
United Kingdom
- Consultation on proposed national action to restrict the use of perfluorooctane sulphonate (PFOS) and substances that degrade to PFOS, by the U.K. Department for Environment, Food and Rural Affairs (DEFRA). Now closed.
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