I understand, but strictly testing is stated as being a pre-requisite
for items in "the catalogue" but until you know that your product is in
"the catalogue" you don't know for sure if it applies to you and what
you have to do. I suppose you just have to plan for the worst case for
now.
As I understood it (and I'm very willing to be corrected) the first
phase of implementation as of March 1 2007 requires only a marking on
the product and a written declaration in Chinese, such as a product
information sheet shipped with the product. Testing and enforcement will
follow later when more details are published.
Are we really supposed to give a product sample and full BOM and
component sourcing details to a Chinese lab to qualify each and every
product type imported into China before customs will allow it in? What
guarantees do we have concerning intellectual property considerations?
The next year is going to be very busy for the Chinese certification
labs and everyone beating down the doors of all the component suppliers
to supply full materials declarations for every part they use.
Nigel
-----Original Message-----
From: Reuven Rokah [mailto:[log in to unmask]]
Sent: 08 January 2007 11:57
To: (Leadfree Electronics Assembly Forum); Burtt, Nigel
Subject: RE: [LF] China RoHS Clarification
- China RoHS is without exemption so EU RoHS is not enough.
- The estimation for catalogue publishing is Q1 07 and one year
implementation.
- EFUP for some products have the Chinese inputs such Telecom 50
years.
- All the products / components should have CCC by Chinese Lab.
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Reuven ROKAH
e mail: [log in to unmask]
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of N Burtt
Sent: Monday, January 08, 2007 12:18 PM
To: [log in to unmask]
Subject: Re: [LF] China RoHS Clarification
Its seems safe to assume that if your products already fall under RoHS,
then
they will be within scope of China's version. However, until "The
Catalogue" is
published (we have been told Sept 2007) the scope is not fully defined
and
there are no exemptions yet.
Almost all RoHS product utilises one or more the exemptions already (eg
high
melting point SPb for CBGAs and for IC internal die attach, lead in
ceramic for
SMT resistors, network infrastructure, servers) - so you may be EU-RoHS
compliant but not China-RoHS compliant. Will anyone feel brave enough to
put
on the China "green E" products and thus provide a false 0% declaration
for all
6 substances on these by March 1 2007?
If I'm right then everyone needs to use the qualified "EFUP" marking (at
least
until the catalogue clarifies scope and any exemptions) and the number
to put
in the circle is important - how about we all agree to use the
"inifinity" symbol
until further notice?!
However, for products which are assemblies of many different components
and
hundreds of homogenous materials that appears to fall within scope,
getting
the required information from suppliers to accurately complete the
required "Hazardous Material and contents" declaration... and do so in
Chinese... will be no mean feat given how difficult it was to even get
just a
documented yes/no answer from many suppliers about RoHS.
Nigel Burtt
Dolby Labs Inc
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