Leverage EU RoHS data to meet China RoHS requirements

Most companies have spent many years collecting data to meet the European Union's Restriction of Hazardous Substances (RoHS) compliance requirements. Most importantly, these companies have incurred significant costs collecting EU RoHS compliance, material declaration and composition data from their suppliers with the idea that it should be possible to use the same data to address similar regulatory requirements.

The ratification of China RoHS has forced many companies to address data and process requirements and has put to test the hypothesis of collecting compliance data once to address multiple regulations. This article examines the applicability and validity of EU RoHS data for addressing China RoHS.

Management Methods for Controlling Pollution by Electronic Information Products, a.k.a. China RoHS, is a regulation passed by the Chinese government to regulate the presence of hazardous chemicals in Electronic Information Products (EIP). Currently about 1,800 products are considered to be EIPs. The official list can be obtained from the ministry's web site. Although China RoHS is fairly similar to EU RoHS in theme the implementation has significant differences. The differences stem mainly from the proactive monitoring requirement of China RoHS as opposed to the self-policing nature of EU RoHS.

From a data management perspective the key feature of the China RoHS specification is the classification of Electronic Information Product (EIP) A/B/C categories for parts and homogeneous materials.

• EIP-A is the same as a homogeneous material described by EU RoHS
• EIP-B is defined for metallic coating
• EIP-C is defined for parts that have total volume of less than 4 mm3

These categories have specific maximum concentration value (MCV) limits for hazardous substances as shown below.

For EIP-A, the MCV limits are as follows:

• Lead and lead compounds: 1000 PPM
• Mercury and mercury compounds: 1000 PPM
• Cadmium and cadmium compounds: 100 PPM
• Hexavalent chromium and compounds: 1000 PPM
• PBB: 1000 PPM
• PBDE: 1000 PPM

For EIP-B, heavy metals including lead, mercury, cadmium and hexavalent chromium cannot be intentionally added.

For EIP-C, further decomposition into homogeneous materials is not necessary. The MCV limits specified for EIP-A are applicable for the whole part in the case of EIP-C. The content of the six substances (and groups) with respect to the overall part can be taken into consideration.

In addition, information about environmentally friendly use period of the end product is also required as part of the information disclosure.

At the current time, China RoHS legislation does not have any penalties for exceeding maximum concentration value (MCV) thresholds. However, all EIPs need to be properly marked and labeled. Sales bans and penalties will be enforced in the second phase of the implementation.

Leveraging EU RoHS data

Most, if not all companies will look to leverage data that they collected for EU RoHS compliance to address the China RoHS information disclosure and labeling requirements. In order to successfully do this the data collected for EU RoHS would have to meet the regulatory data requirements of China RoHS either by valid inference or logic.

Companies have collected various levels of compliance data depending upon the level of sophistication of their data collection and management processes. So here's a look at what types of information can be leveraged to meet China RoHS requirements.

Part level EU RoHS Yes/No
The part level Yes/No declaration consists only of a Yes/No value for EU RoHS compliance status for a given regulation and any applicable exemptions. The IPC 1752 declaration uses class 1 and 2 forms to support part level Yes/No declaration.

Part level EU RoHS Yes/No with JIG reporting and declarable substances
This type of declaration includes part level Yes/No RoHS declaration as well as the information and content of the presence of regulated substances from the RoHS or Joint Industry Guide list.

Homogeneous material declaration
This type of declaration includes composition of substances at the homogeneous material level per EU RoHS specification. However, there is no requirement to account for 100% of composition at the homogeneous material composition and at the part level.

Full Disclosure
This type of declaration is based on composition of substances at the homogeneous material level and full 100% of composition is accounted for at the homogeneous material and at the part level.

The above four types of data can be used as the initial starting point for supporting China RoHS analysis and information disclosure processes. Companies can make the following inferences or use the data as it is when evaluating for the presence of regulated hazardous substances above maximum concentration values.

When the data is at Part level EU RoHS Yes/No (IPC 1752 Class 1-2):

• If the part is EU RoHS compliant you can assume that the part is also China RoHS compliant (provided there is no possibility of metallic plating)
• If the part is EU RoHS compliant with exemptions, request more data for either a JIG substance declaration or homogeneous material declaration
• If part is EU RoHS non-compliant, request more data for either a JIG substance declaration or homogeneous material declaration

When the data is at Part level EU RoHS Yes/No and JIG substance (IPC 1752 Class 3-4) declaration:

• Use the JIG substance declaration data to evaluate if the regulated substances exceed MCV thresholds

Homogeneous materials (IPC 1752 Class 5-6, AIAG) substance composition or full disclosure:

• Use homogeneous material level substance declaration to evaluate if the regulated substance exceed thresholds

In addition, companies should understand where metallic plating occurs in their parts. Because the thresholds for MCV are different for metallic plating they need to be identified and marked so that evaluation routines apply to the appropriate set of MCV thresholds. Companies that have implemented compliance data management systems should add the EIP classification as an attribute so that the classification value can be maintained and used for evaluation. Conversely, data collection formats should also accommodate declaration and capture of classification attributes, typically at the homogeneous material level.

It is clear that adopting a substance level declaration or homogeneous material level composition for data collection would have eliminated the need for data collection for China RoHS. However, companies that have invested significant resources to collect EU RoHS can take comfort in the fact that additional data requirements for China RoHS are minimal as they can leverage existing EU RoHS data. This is more of a lucky coincidence as thresholds for regulated substances for China RoHS are the same as those of EU RoHS.

From a long-term perspective companies are better off adopting a higher level of data collection, which is typically at the substance level or homogeneous material composition level, as it reduces or eliminates the need for data re-collection when existing regulations change or new regulations are introduced.

You can reach Krishna Gorrepati at kgorrepati@tdaamerica.com.

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