How does BOMcheck manage compliance with RoHS restrictions in China, Korea and Japan?

Other RoHS legislation around the world focuses on the same list of RoHS substances, but has different requirements.  BOMcheck analyses the substance declarations provided by suppliers to identify any restrictions on using these parts in other parts of the world.

China RoHS

China RoHS2 – the final Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products – came into force in July 2016 and requires a broad scope of products to comply with product labelling and substance disclosure requirements. All electrical and electronic products in scope must be labelled with an environmental protection symbol. This is exactly the same labelling requirements as China RoHS1 but now applied to a much wider scope of products in China RoHS2 from 1 July 2016.

In addition to a label on the product, if any part in the product exceeds the RoHS maximum concentration values in any homogenous material the product instructions must include a table in Chinese which identifies the part names which contain the RoHS substances. This is the same substance disclosure requirements as China RoHS1 but now applied to a much larger scope of products. The China RoHS2 table follows same format as China RoHS1 but has updated references to the updated standards for product marking (SJ/T 11364) and the RoHS maximum concentration values (GB/T 26572).

On 15 March 2018 China issued the first "Compliance Management Catalogue" detailing 12 types of electrical and electronic products which also need to comply with hazardous substance restriction limits set out in national standard GB/T 26572 2011 from 15 March 2019. Similar to EU RoHS2, some applications are exempt from the substance restrictions, including 39 uses of lead, cadmium, mercury and hexavalent chromium which are detailed in a list of China RoHS2 exemptions. The numbering of the exemptions in the China RoHS2 product catalogue is different compared to numbering of the exemptions listed in Annex III of EU RoHS2. However, the re-numbered list of China RoHS2 exemptions includes all the exemptions listed in EU RoHS2 Annex III as at July 2016, as direct translations without any expiry dates.

Korea RoHS

The Act for Resource Recycling of Electrical/Electric Products and Automobiles was published on 2 April 2007 and came into force on 1 January 2008.  The Act applies the same EC RoHS materials restrictions and maximum concentration values to 10 categories of electrical and electronic equipment which are listed in Article 6, Enforcement Ordinance of the Act.

Japan RoHS

Under an amendment to the Law for the Promotion of the Effective Utilisation of Resources, Japan introduced a mandatory labelling standard for certain types of household electrical equipment and IT equipment from 1 July 2006.  If any single homogenous material in these types of equipment contains > 0.01% by weight of cadmium or > 0.1% by weight of lead, mercury, hexavalent chromium, PBB or PBDE, the J-MOSS labeling standard requires that the equipment is marked with an orange “R” mark.   If the equipment does not contain these materials it should be marked with a green “G” mark.


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