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Forget AMCPCEIP - Think China RoHS
by Ray Franklin, RoHSwell.com, 11/09/2005
An English translation of the Administrative Measures on the Control of Pollution Caused by Electronic Information Products is now available. This mouthful of a regulation, more popularly known as China RoHS, was released for industry review on 27 September 2005. The review period ends 27 November. Here is a very brief summary of this new regulation.
The acronym, AMCPCEIP, is of no value whatsoever. I predict that China RoHS will stick permanently.
The English translation is unofficial. It was commissioned by Wilson Sonsini Goodrich & Rosati. For additional information you may contact Kimberley McMorrow or Marc Gottschalk at the firm at 650.493.9300.
The law is strongly patterned after RoHS. Virtually every kind of electrical or electronic gear is covered, even including software (presumably packaging and media). The following are key points taken from specific articles in the measure.
- Article 3 - In addition to the RoHS 6 banned substances, China RoHS adds this open-ended restriction:
"Other toxic and harmful substances or elements provided by the State."
This could literally be anything. Furthermore, there are no exemptions, at all.
- Article 11 - A new principle is introduced called the "safety period of electronic information products." This concept defines a period of time during which harmful or toxic materials will not "leak or mutate" and thus cause no harm to the environment or to users. The safety period, as determined by the manufacturer, must be explicitly indicated on the product.
- Articles 14, 15 - Products or packaging must be marked with the names and content of toxic or harmful substances and their recyclability.
- Article 18 - All products must be certified by certification and accreditation authorities of the state.
- Article 19 - An annual catalogue of products, substance restrictions and safety periods will be maintained by the state.
- Article 20 - Catalog not withstanding, products not listed must still comply with China RoHS.
- Chapter 3 promises penalties for failure to comply. Apparently, the penalties are left up to the named regulatory bodies.
- Chapter 4 provides that anyone may report violations, and that the measures are subject to interpretation by any of the seven listed regulatory agencies.
- The measure takes effect 1 July 2006.
(Continued Below ...)
Additional Resources
Design Chain Associates China RoHS page with a link to the translated measure.
Direct link to the English translation.
