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Government Affairs >> Environment

China RoHS Finalized || MII Delegation Trip to US || AeA China RoHS Summary || Contact

On February 28, 2006, China's Ministry of Information Industry (MII) promulgated the long-awaited “Management Methods for Controlling Pollution Caused by Electronic Information Products Regulation” (“China RoHS”).  China RoHS” provides a broad regulatory framework for substance restrictions, pre-market certifications, labeling and information disclosure requirements affecting a broad range of products and parts defined as "electronic information products" ("EIP").  The extremely broad scope of products captured under the “EIP” definition underscores the potential that the entire IT industry is directly affected by “China RoHS” compliance obligations.


MII "China RoHS" FAQ Document

Continuing AeA's leadership of the U.S. technology sector on "China RoHS" advocacy and information sharing below please find unofficial English translations of the Ministry of Information Industry (MII) drafted Frequently Asked Questions (FAQ) focusing on "China RoHS" regulation and supporting industry standards. Ministry of Information Industry published the FAQ document in December of 2006 and made additional amendments in February of 2007. The FAQ document on this website reflects these updates.

To review the unofficial English translations, please use the links below:

Information in the above listed documents is for reference purposes only and does not constitute legal advice. For binding Language, refer to the original document in Chinese.


Learn the latest global environment developments on RoHS, WEEE, Energy Efficiency, and more at TechAmerica's annual compliance roadshow. For your convenience, TechAmerica has planned four events across the United States to give you the vital information that you need to remain compliant to international manufacturing standards. These events are scheduled for:

Tuesday, April 28, 2009
Santa Clara, CA
  Friday, May 1, 2009
Andover, MA
     
 
Hosted at Marvell Technology Group Ltd.   Hosted at Philips Electronics North America
     
Tuesday, May 5, 2009
 Austin, TX
  Thursday, May 7, 2009
Schaumburg, IL
     
National Instruments  
Hosted at National Instruments   Hosted at Motorola's Headquarters

AeA, ITAA, GEIA and CSIA have merged to form TechAmerica, the largest and strongest voice and resource for technology in the United States. Together, we are the industry's leading trade association, offering companies a broader array of programs and services.

AeA and USITO Delegation Meetings with CNCA and MIIT

On July 14, 2008 a delegation of AeA and USITO members met with Mr. Huang Jianzhong and his staff Yang Meng from the Ministry of Industry and Information Technology (MIIT). MII is now officially called MIIT (Ministry of Industry and Information Technology.)

July 14, 2008 - View Notes from AeA China RoHS Steering Committee Meetings with CNCA and MIIT.
 

Questions and Answers from October 26, 2006 AeA China RoHS Conference

AeA is pleased to announce that over 80 questions raised at the October 26, 2006 AeA Santa Clara, CA China RoHS program have been addressed in a single document. The information contained in this document includes a summary of "China RoHS" information that is found in industry technical standards and Frequently Asked Questions (FAQ) documents published by the Ministry of Information Industry (MII), and compiled by the AeA- Advancing the Business of Technology. AeA is sharing this document with MII for their comments. This document is a living document that can be changed as updates, clarifications and final regulatory and standards documents are published. None of the information offered in this document should be viewed as legal or compliance advice from AeA, but rather as an informational summary of current "China RoHS" developments and available information from MII. References to Ministry of Information Industry (MII) laws and FAQ Documents are English translations for information purposes only. Binding versions of these laws and documents are the original Chinese versions. Click here to review.

November 2006 the Ministry of Industry Information (MII) finalized and signed three "China RoHS" supporting industry standards

  1. Labeling;

  2. Maximum Concentration Value; and

  3. Test Methods.

In an effort to keep AeA members informed of current "China RoHS" developments below please find AeA UNOFFICIAL English translations of the three standards.

China RoHS is simply the first step in the rulemaking process. Many important details that are critical for compliance with and understanding the affects of China RoHS on our companies, products, and trade with China will be issued in the coming year. AeA is dedicated to leading industry advocacy and education in this area. To join the AeA "China RoHS" Steering Committee contact Michaela Muranova, Director International Environment and Trade Policy, at 202.682.4445.

With expertise gained from leading the U.S. tech industry’s RoHS efforts in Europe for over 10 years, AeA has communicated a message of harmonization, ease of product introduction and technically and economically realistic compliance requirements. 

By prioritizing our efforts in China and holding various forums, meetings and exchanges AeA has successfully forged relationships that have allowed companies the opportunity to directly communicate comments, concerns, and proposals in key issues. AeA intends to continue to lead U.S. tech industry efforts in China on the “RoHS” regulation, we welcome all company participation and efforts.

October 26, 2006 - AeA China RoHS Program Draws 250 Attendees to Hear China MII Delegation on Impending Environment Rules AeA hosted a half-day conference at Sun Microsystems in Santa Clara, CA, on China RoHS (regulations restricting the use of certain substances in the production of electronic information products) that drew over 250 people from across the country.  They came to hear presentations by the primary drafters and implementers of the regulation from the Chinese Ministry of Information Industry (MII).  With the impending effective date of March 1, 2007, companies were eagerly seeking more information and clarification of the requirements they will have to meet for their products to be compliant.

AeA, with the support of 12 sponsoring companies (Agilent, AMD, Apple, Cisco, Dell, GE, HP, Honeywell, Intel, Motorola, Sun, Teradyne), organized a ten-day trip from October 17-27 for the delegation of senior MII officials that included meetings in Washington, DC; Austin, TX; and San Jose, CA.  For over two years the AeA China RoHS Coalition has been providing input to these officials on US company views and concerns related to development and implementation of the China RoHS regulations, including several technical exchanges in Beijing.  This was the first time that the MII group had met with companies in the US on the China RoHS rules and the AeA program was the only public opportunity for non-sponsoring companies to hear first-hand the latest information on the implementing rules.  To learn more about AeA’s work on China RoHS visit our China RoHS webpage.

AeA also hosted the MII delegation for a welcoming lunch in the AeA offices on October 20.  Bill Archey, AeA CEO and President, greeted the group, provided them with an overview of AeA, and discussed the key goals of the meetings that had been arranged for the delegation.

MII Delegation
The Chinese MII Delegation including WANG Bingke, Deputy Director General, Department of Economy and Economic Operations, MII; AeA Executives William T. Archey (President & CEO) & Rob Mulligan (Sr. VP International); and AeA Member Company Representatives at the AeA DC Headquarters.

MII Speaker
HUANG Jianzhong, MII, Speaking at Sun

MII Speaker
Chang Limin, MII, Speaking at Sun

Status of the Regulation

  1. On March 1, 2006, China's Ministry of Information Industry (MII) promulgated the long-awaited “Management Methods for Controlling Pollution Caused by Electronic Information Products Regulation” (“China RoHS”). The text of China RoHS was finalized on February 28, 2006, after a long wait. MII released the document to the MII Standards Working Group on March 1 and the official Chinese News Agency (Xinhua) announced the promulgation of China RoHS on March 3.
     

  2. MII notified "China RoHS" to the World Trade Organization (WTO) on September 28, 2005.


"Effective" Dates

  1. There will be more than one "effective date" for "China RoHS".
     

  2. The effective date indicated in the final "China RoHS" was March 1, 2007. This first effective date was the "in force" date for all provisions, in the draft text of notified "China RoHS", EXCEPT FOR the substance restrictions and pre-market certification requirements (see, eg., articles 18-20).
     

  3. Effective dates for substance restrictions and pre-market certification requirements
    would be dates specified in the first batch of the Catalogue, and could be much later than the first effective date of "China RoHS" (i.e., later than March 1, 2007).


Status of Catalogue

  1. The catalogue drafting process will likely take months with a first draft likely in 2007.
     

  2. Drafting of the catalogue had not commenced as of the promulgation date of "China RoHS"
     

  3. Current key issues involving catalogue development include what "electronic information products" would be included in the first catalogue batch.
     

  4. It is important to note the definition of "electronic information products", which includes final products, components and parts, and materials.
     

  5. Items included in the Catalogue will be subject to pre-market testing and certification. 


Status of Standards:

  1. The Labeling, MCV and Test Method Standards were finalized in November 2006.  As with all priority China RoHS documents AeA will translate and post for Member benefit. 
     

  2. SJ/T 11363-2006 Requirements for Concentration Limits for Certain Hazardous Substances in Electronic Information Products (FINAL standard)
     

  3. SJ/T 11364—2006 Marking for Control of Pollution Caused by Electronic Information Products (FINAL standard)
     

    1. GB 18455-2001 Packaging Recycling Mark is referenced in the "Marking for Control of Pollution Caused by Electronic Information Products"
       

    2. The China RoHS label images are available at the following link. The images are compressed .rar files.  When uncompressed, these are Adobe Illustrator files which you can use to create your own artwork.  AeA has also provided these images below.
       


  4. SJ/T 11365—2006 Testing Methods Testing Methods for Hazardous Substances in Electronic Information Products (FINAL standard)
     

Finalized Regulation

China RoHS Documents in Chinese

Joining the China RoHS Subcommittee

All AeA members are welcome to participate in the AeA China RoHS Subcommittee.  It is one of the many perks of being an AeA member.

For more information or to join the committee contact: 

Mark Plagens
Director, International Environment Policy
601 Pennsylvania Avenue NW
North Building, Suite 600
Washington, DC 20004
202.682.4445 (office)
713.677.3821 (mobile)
202.682.9111(fax)
mark_plagens@aeanet.org

This page was last updated on 04/03/09.  
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