Takehome: MIIT officially released the qualification management catalogue (first batch) of China RoHS 2 and its exemption list.
On March 12, 2018, the Ministry of Industry and Information Technology (MIIT) of China officially released the Qualification Management Catalogue (first batch) and the Exemption List of the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products (known as China RoHS 2). The documents are scheduled to go into effect on March 12, 2019.
China RoHS 2 has imposed concentration limits for some hazardous chemicals on the products in the catalogue. The concentration limit is 1000mg/kg for lead, mercury, chromium (6+), poly brominated biphenyls (PBBs) and poly brominated diphenyl ethers (PBDEs); and 100mg/kg for cadmium. And these substances are the same as those restricted by EU Directive 2002/95/EC.
The finalized catalogue contains the same 12 categories of electrical and electronic products listed in the draft version issued in June last year, specifying them in greater detail. For example, the catalogue stipulates the scope of the television category and provides that some types of printers are exempted from the regulation. Meanwhile, it notes that products listed in this catalogue are not subject to the regulation if they are used as parts of products that are not in the catalogue; however, if these products are sold separately in the market without a specified end use, they fall into the scope of this catalogue.
The exemption list contains 39 exemption scenarios under which an exemption could be given. It is mostly the same as the list in the draft version, except for the addition of Item 37.2 for cadmium in low-energy conversion cadmium-based semiconductor nanocrystals quantum dots (QDs) for display and lighting applications (cadmium content < 0.2µg/mm2 of screen display area).
The documents further clarify the requirements of China RoHS 2. Enterprises must carefully assess whether their products are included in the catalogue or the exemption list, in a bid to ensure compliance with the documents.