China RoHS Translations
Corrections made 4/29/2007:
Notes added to table regarding GB 18455, the China RoHS Measure Q&A and the standards Q&A.
Additional documents added to table.
One of the difficulties with China RoHS compliance is that the original documents were issued only in Mandarin Chinese. For most businesses, this necessitates working from English translations. Since translation is an imprecise art, the situation adds risk to any interpretation. One way to reduce risk is to compare different translations.
Fortunately, there are several translations available for most of the critical documents. AeA and Grasp LLC offer free translations. Design Chain Associates (DCA) sells independently produced translations. DCA has also posted links on their China RoHS web site to all the known translations. The table below shows the document coverage.
| Document | AeA | DCA | Grasp | PRC |
|---|---|---|---|---|
| China RoHS (ACPEIP) | Yes | Yes | Yes | |
| Classification of EIP | Yes | Yes | ||
| Concentration Limits Standard SJ/T 11363-2006 | Yes | Yes | ||
| Marking Standard SJ/T 11364-2006 | Yes | |||
| Product Marking Regulation | Yes | |||
| Testing Methods Standard SJ/T 11365-2006 | Yes | |||
| Package Recycling Mark GB 18455-2001 - Note 1 | Yes | Yes | ||
| China RoHS Measure Q&A (12/1/06) - Note 2 | Yes | |||
| Standards Q&A - Note 3 | Yes | Yes | ||
| EFUP Guidance Draft | Yes | |||
| Draft General Disassembly Requirements | Yes | |||
| AeA China RoHS Conference Q&A | Yes |
As you can see from the table, you can get excellent coverage by using the free translations from AeA and Grasp LLC. With the DCA translations, you can add a second or third view for reduced risk. And in some cases, only DCA has current translations.
It is, of course, natural to be most interested in the legislation, initially. However, I find the Q&A documents to be of equal value for understanding the context of the regulations. The three interviews available at Grasp LLC make for excellent reading.
The general Q&A interview with Jianzhong Huang provides an overview of China RoHS. Mr. Huang lists the similarities and differences between EU RoHS and China RoHS and explains the two-phase approach. He also notes that there will be eight standards defining the specifics of compliance. Three of those standards have already been released.
"China RoHS Q&A - Standards" presents a wide-ranging discussion of the marking standard. It includes such tidbits as the requirement to mark only the outermost layer of packaging with the recycling logo. Marking of all packaging elements is encouraged, but not required.
Reading multiple translations of regulatory documents is admittedly tedious. It remains the best way I know to build first-hand knowledge of the regulations. To avoid MEGO (my eyes glaze over) I find it helpful to choose a particular topic of interest and then skim the documents, reading in detail only those sections that pertain to my selected topic. Each time I do this with another topic, I gain a deeper understanding of the regulations.
Thanks to the dedication of a few translators, there is ample material to expand your education on China RoHS. I encourage you to dig in and become familiar with this important set of documents.
Additional Resources
China RoHS Compliance - overview of the regulations with a step-wise compliance plan and sources for all the resources you will need to complete the job.
AeA Translations
Grasp LLC Translations
DCA Translations
"China RoHS scope clarified" - explains scope of legislation and the 2-phase implementation.
