RoHS (Restriction of Hazardous Substances)

  • Scope: Electrical and electronic equipment
  • China RoHS 2: Effective since 2016
  • Restricted substances: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, 4 phthalates
  • Mark: “China RoHS 2 compliant” mark required

REACH (EU chemicals regulation)

  • Applies to chemicals manufactured/imported in the EU at >1 tonne/year
  • SVHC (Substances of Very High Concern) list: currently 241 substances
  • Information duty when SVHC concentration in article exceeds 0.1% (w/w)

China-specific regulations

1. China RoHS 2

  • Applies to E&E products on the China market
  • Compliance mark required

2. Air Pollution Prevention Law

  • VOC (volatile organic compounds) emission limits
  • Painting and printing processes need exhaust treatment

3. Solid Waste Pollution Prevention Law

  • Classification, handling, designated disposal sites
  • Manifest system for hazardous waste

4. Environmental Protection Tax Law

  • Tax on pollutant discharge
  • Itemized for air, water, soil, solid waste, noise

OEM factory due diligence checklist

  1. Environmental management certification: ISO 14001 obtained?
  2. Pollutant discharge permit: Legal emissions license
  3. RoHS / REACH test reports: Product-level compliance
  4. Chemical management tables: Across the supply chain
  5. Waste disposal contracts: With licensed vendors