On May 16, 2016, China State Administration for Market Regulation (SAMR) and Ministry of Industry and Information Technology (MIIT) released China RoHS 2: Implementation Arrangements for Conformity Assessment System. The Implementation Arrangements were formulated to strengthen the management of the Qualification Management Catalogue (First Batch) for China RoHS 2 (Administrative Measures on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Products [EEP]).

Two methods of conformity assessment are recognized in the Implementation Arrangements.

1) The supplier (this includes producers, authorized representatives, etc.) can select the voluntary certification promoted by the state, or

2) the supplier can prepare a self-declaration of compliance.

For voluntary certification, the company must submit an application for conformity assessment to an official certification body established according to law. The process is implemented and standardized by the state.

For the self-declaration option, suppliers can autonomously adopt a reasonable way to complete the conformity assessment and then provide the government with corresponding technical support documents for review.

Voluntary Certification

The certification scheme is applicable to assembled equipment, subassemblies, component parts, and materials - though the certification models differ. The conformity assessment mark for products that undergo voluntary certification is:

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Concentration limits for certain restricted substances and requirements for the dismantling of EEP are found in GB/T 26572. Tests must be implemented in accordance with GB/T 26125-2011. The supplier's declaration of conformity must comply with GB/T 27050.1 (Conformity assessment―Supplier's declaration of conformity―part 1: General requirements).

Self-declaration

Self-declaration is another method of conformity assessment that is applicable to products listed in the Qualification Management Catalogue (First Batch) for China RoHS 2. The conformity assessment mark for products undergo self-declaration is:

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The self-declaration must include a certification that the product meets the hazardous substance limits and related technical support documents. At a minimum, the the self-declaration must include:

  • The name and contact information of the supplier;

  • EEP name, specification and model, technical support document number, and technical support file type;

  • Commitment to the truthfulness, completeness and consistency of the contents of the statement and related declaration materials;

  • Additional information, including signature of the authorized person, company seal, etc.

Suppliers of EEP must upload conformity reports as technical support documents through the public service platform. The report must prove the product conforms with the hazardous substance limits. The following two options may be employed:

  • The supplier can commission an inspection and testing agency to test for hazardous substances in the product according to relevant standards, and produce a test report.

  • The supplier can prepare a conformity report based on the determination of hazardous substances in all components, parts and raw materials.

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