Reducing the STRESS  of Software Implementations Worldwide  


Oracle Applications Users Group



by Sandra Noble, President
Noble & Associates Consulting, Inc.


The Restriction of Hazardous Substances (RoHS) Directive 2002/95/EC of the European Union is a well known document. What is not so well known are details of a somewhat similar document (Legislation in this case), popularly known in industry as the China RoHs. Officially called the Administrative Measure on the Control of Pollution Caused by Electronic Information Products regulation, the China RoHs, was promulgated by the Ministry of Information Industry (MII), People’s Republic of China, on February 28, 2006. The China RoHS came into effect on March 1, 2007.

The EU RoHS and its Chinese counterpart are similar in that both target the domestic market and restrict the use of the same six substances: lead, cadmium, mercury, chromium (VI), PBB (poly-brominated biphenyls) and PBDE (polybrominated diphenyl ethers). The maximum threshold limits are also the same in both the documents, (100 ppm [parts per million] for cadmium and 1000 ppm for the other five) on homogeneous material basis (i.e. any single substance that cannot be separated mechanically). There are, however, significant differences in approach between the two RoHS directives.

Within the full scope of Electronic and electrical products covered by the regulation (stated under ten broad headings), will be a yet-to-be-published list of EIPs (electronic information products) known as the catalogue (Article 18 of the regulation), which will be the included products. This is different from the EU RoHS, where products are included unless specifically excluded. Other notable inclusions in the China RoHS which are different from the EU RoHS are: a standard for marking packaging materials and the concept of an “Environmentally Friendly Use Period” (EFUP) for EIPs and product testing in approved Chinese laboratories for the purpose of labeling hazardous substance disclosure.

Relevant Peoples Republic of China Electronic Industry Standards has been developed for the China RoHS. These are the SJ/T 11363-2006 “Requirements for Concentration Limits for Certain Hazardous Substances in Electric Information Products”; the SJ/T 11364-2006 “Marking for Control of Pollution Caused by Electronic Information Products”; and the SJ/T 11365-2006 “Testing Methods for Hazardous Substances in Electronic Information Products”.

The Environmentally Friendly Use Period (EFUP), also referred to as the Environmental Protection Use Period (EPUP) is the period (years) from the date of manufacture, that hazardous substances contained in an EIP will not leak or change under normal operating conditions, leading to any environmental pollution, damage or bodily injuries. The MII is yet to determine EFUPs in consultation with industry bodies.

The China RoHS is being rolled-out in two phases:

The current phase 1 effective March 1, 2007, involves material content disclosure and labeling. Phase 2, to be implemented at a future date, will involve pre-market testing and certification of products (estimated to be some 1800+) which will be listed in the catalogue. This latter phase is likely to accelerate the collection by suppliers, of ppm level homogeneous material content data in their products. The EU RoHS directive has not been very successful in this respect.

China will likely emerge as the top consumer of electronic and electrical products in the world. While this will be good for the economy, it will come with the associated cost of environmental problems for society. This is justification enough for the promising environmental regulations to be implemented and nurtured.

Go from Zero To Green In Six Months! Click below:
RoHS Hazardous Materials and Compliance Guidelines


Go from Zero To Green In Six Months! Click below:
RoHS Hazardous Materials and Compliance Guidelines

Sandra Noble MBA, CPIM, Six Sigma, DCFS, CDP, is president of Noble & Associates Consulting which specializes in I.T. Needs / Strategy Assessments, unbiased Software Selection assistance, and curing Post Implementation Distress™. We also have full life cycle implementation expertise in SAP, Oracle and other enterprise-wide software solutions. Reducing the STRESS of Software Implementations Worldwide!

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