China RoHS

Overview

The Ministry of Information Industry (MII) of the People’s Republic of China has begun issuing standards for their equivalent of the RoHS Directive. The official title of their overall legislation is “Management Methods for the Control of Pollution from Electronic Information Products”, but it is more commonly referred to as China RoHS. This standard covers the same six substances as the EU RoHS Directive, namely lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyl (PBB), and polybrominated diphenyl ether (PBDE), and also uses the same maximum concentration values (MCV) of these substances. China RoHS officially went into effect on March 1, 2007.

Product Marking

Electronic end products (see below for definition) sold in China after March 1, 2007 must have either of the following two logos.


Logo 1
             
Logo 2

Logo 1 signifies a product with none of the six substances above the MCV. Because the vast majority of electronic products today use one or more of the EU RoHS Directive exemptions such as lead in ceramics, high temperature solder, or component glass and contain levels of some of the substances in excess of China RoHS MCV’s, very few electronic products will use this logo.

Logo 2 is used on a product with one or more of the six substances above the MCV. The number in the circle is the Environmental Protection Use Period (EPUP) as defined in Paragraph 3.5 of the Marking Standard SJ/T11364-2006. The EPUP is time in years for which hazardous/toxic substances will not, under normal operating conditions, leak out the product, or the product will not change in such a way as to result in severe environmental pollution, injury to health, or great damage to property. After long and careful consideration, Power-One has decided to use 25 years for the EPUP for all of our products based on the Technical Life Method as described in the draft General Rule of Environment-Friendly Use Period Electronic Information Products. Although our customers may request other EPUP’s, because of the legal issues involved, determining the EPUP used on our products remains the sole responsibility of Power-One. In order to avoid costly color printing or extra labels, the EPUP logo will be printed using black ink on a white or silver background on our existing labels, instead of using the suggested red-orange color, which is not mandatory.

What Is Marked and What Is Not

There is a general belief that all electronic products sold in China must have one or the other of these logos, but this is not correct. The following is from an English translation on the AeA (American Electronics Association) website of the China Marking Standard SJ/T11364--2006, Paragraph 4:

”With respect to the electronic information products that are purchased for manufacturing. Suppliers need not provide the aforementioned marking, but shall supply to the purchaser all necessary information required for marking. Correspondingly, the purchasers [in this case] shall mark the electronic information products they manufacture and the scope of marking shall include that for the electronic information products purchased for manufacturing.”

The vast majority of our DC-DC converters and AC-DC power supplies are embedded in our customer’s product and fit the description of a “product purchased for manufacturing”. Thus, Power-One will not mark these products with a China RoHS logo.

Our power systems and power system components such as rectifiers and controllers, field replaceable units (FRU’s) which includes all of our hot-swap front ends as well as our Compact PCI, Cassettes, and DIN-Rail products, can be sold as standalone items. As such, we mark all of these products with the China RoHS Logo 2 as described above. These products are listed in the appendix below.

Hazardous Substance Table (HST)

There is also a requirement for a Hazardous Substance Table to be provided with products having an EPUP label. This table lists a few major parts and subassemblies making up our power supplies and converters where these contain any of the six substances over the MCV. To comply with China RoHS, this table must be in Chinese, but the Power-One tables will be in English as well for clarity. A copy of the applicable table will be included in the shipping documents for these products.

For customers who use our products which do not require EPUP marking, Power-One supports these customers by providing the information they need which allows them to correctly fill out an HST for their own products. Our individual RoHS Certificates of Compliance which are found on the Power-One website already list each of the RoHS substances which may be contained in our power supplies and where these substances may be found. Tables for custom power supplies are provided to the specific customer upon request.

Packaging Markings

Aside from the product marking and documentation, all packaging material must be marked with the applicable Packing Recycling Marks as specified in China National Standard GB 18455-2001. Power-One complies with these marking requirements.

China RoHS: The Future

The product and packaging marking and related disclosure tables are the only China RoHS requirements which went into effect on March 1, 2007. For the future, China is setting up laboratories throughout China where actual testing of products for RoHS substances will take place. MII has also developed a uniform testing standard (currently in draft phase) for these laboratories to use. Once MII starts to publish lists of specific products which must meet the RoHS MCV requirements, known as the Catalogue for Pollution Control in Key Electronic Information Products, these products will have to be tested and certified by the Chinese labs. The first batch of products to be listed in this catalog has not yet been decided and it is expected that this will begin no earlier than October 2007. Power-One will stay on top of developments for China RoHS, so that we can respond in a timely manner for our customers.

Issued: December 15, 2006; Updated: April 23, 2007
Bob White
Director of Safety and Environmental Compliance
Phone: +1 805 384-5391
robert.white@power-one.com

Appendix- Power-One Products having China RoHS EPUP Marking

Cassette Series
H, K, KP, M, Q, P, S

DIN-Rail Series
LOK, LOR, LOS, W, X

CompactPCI Series
CPA, CPD

PALS Series
PALS400, 600

Front End Series
FCP, FE, FNP, FXP, HP6, SFP

Front End Shelves
FNR, FXR, FRH, FRV, RACK-HP600

Power Systems and Components
Rectifiers, Controllers, Cabinets, Racks

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