| The EU has developed the Restriction of Hazardous | | | | not apply to industrial machinery, replacement parts |
| Substances (RoHS) Directive 2002/95/EC. This is only | | | | for equipment sold prior to July 1, 2006, military |
| a directive (effective July 1, 2006) and member | | | | equipment or aerospace applications. The China RoHS, |
| nations are to enact their own legislations based on | | | | on the other hand, proposes to include (in a |
| its guidelines. The Chinese Administrative Measure on | | | | catalogue to be issued), a list of electronic |
| the Control of Pollution Caused by Electronic | | | | information products (EIPs) to which the regulation |
| Information Products (popularly known as China | | | | will apply. This will be a limited list (understood as |
| RoHS) effective from March 1, 2007, is however a | | | | 1800+) out of the universe of electrical and electronic |
| legislation. Both nations' regulations are targeted at | | | | equipment covered under ten broad headings in the |
| their respective domestic markets. | | | | document. Another difference is that the EU RoHS |
| The EU RoHS and the China RoHS both restrict the | | | | does not specify any labeling requirements whereas |
| use of the same six chemicals used in electrical and | | | | the Chinese document does so. Further, the Chinese |
| electronic equipment. These are lead (Pb), cadmium | | | | RoHS will be implemented in two phases. Phase 1 |
| (Cd), mercury (Hg), hexavalent chromium (Cr VI), | | | | effective March 1, 2007 requires specific labeling and |
| and fire retardant PBBs (poly-brominated biphenyls) | | | | content disclosure. Phase 2 will enforce the actual |
| and PBDEs (polybrominated diphenyl ethers). Both the | | | | restrictions and require mandatory testing in local |
| RoHS limit Cd to 100 parts per million (ppm) and the | | | | laboratories. |
| other five to 1000 ppm on homogeneous material | | | | The differences between the two regulations mean |
| basis. This means that the restrictions apply to any | | | | that EU RoHS compliant products may not |
| single substance that could (theoretically) be | | | | automatically be China RoHS compliant. Suppliers will |
| separated mechanically. There are significant | | | | have to work hard for compliance, particularly to |
| differences in the two regulations. | | | | document the content of the hazardous materials at |
| Firstly, the RoHS applies to ten categories of waste | | | | ppm level in the products in the disclosures that will |
| electrical and electronic equipment (referred to as | | | | be required in Phase 2. |
| WEEE) and includes a number of exemptions. It does | | | | |