EFS Consulting
07/23/2024

New mandatory standards for the China RoHS finalized

In May 2024, the Standardisation Administration of China (SAC) Subcommittee TC297/SC3 on Testing Methods for Hazardous Substances completed a draft standard for hazardous substances in electrical and electronic products.

This new standard will replace both “GB/T 26572-2011 Requirements on the Restriction of Hazardous Substances in Electrical and Electronic Products” and “SJ/T 11364-2014 Marking for the Restriction of Use of Hazardous Substances in Electrical and Electronic Products.” It is set to serve as the foundational regulation for China’s RoHS (Restriction of Hazardous Substances) guidelines.

Products in scope

The new standard applies to devices and related products that utilize or interact with current and electromagnetic fields, with a rated operating voltage up to 1500V DC or 1000V AC, excluding those involved in electricity production, transmission, or distribution. It categorizes electrical and electronic products into two types: Type I products listed in the “Compliance Management Catalogue for the Restricted Use of Hazardous Substances in Electrical and Electronic Products” must meet marking, assessment, and limit criteria, while Type II products not listed need only adhere to marking specifications.

Requirements: Limits

The standard specifies that for each homogeneous material in an electrical or electronic product, the mass fraction of lead, mercury, hexavalent chromium, polybrominated biphenyls (PBBs), polybrominated diphenyl ethers (PBDEs), di-n-butyl phthalate (DBP), diisobutyl phthalate (DIBP), butyl benzyl phthalate (BBP), and di(2-ethylhexyl) phthalate (DEHP) must not exceed 0.1%. For cadmium, the limit is 0.01% by mass fraction. The hazardous material content in each unit must be determined following the procedures outlined in GB/T 39560.

Requirements: Marking

For marking, the new standard follows the guidelines of SJ/T 11364. It specifies that internal components, such as resistors, circuit boards, and display elements, which are themselves electrical and electronic products but are used as parts of other products, do not need to bear the hazardous substance restriction symbol directly on their surface when sold separately. Instead, this symbol should be included in the product’s documentation or digitally embedded in the software.

Requirements: Conformity Assessment

The standard requires that products listed in the “Compliance Management Catalogue for Electrical and Electronic Products” must have more than 70% of their components covered by test reports in the technical support documents for the “Supplier Declaration of Conformity for the Restricted Use of Hazardous Substances in Electrical and Electronic Products.” This requirement will have a broad impact on the majority of electrical and electronic equipment sold in China.

More about this Business Area
Compliance and Legal

Insights

What is regulatory compliance?
What is automotive compliance?
What is product compliance?