• RoHS Compliance When Importing Electronics from China

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    RoHS compliance

    CE Marking Course For Importers: Click Here

    RoHS restricts heavy metals, such as lead and mercury, in electronic products imported and sold in the European Union. RoHS compliance is mandatory, not optional, for importers.

    In this article, you will learn how to ensure RoHS compliance when importing from China and selling to the EU:

    • What is RoHS?
    • Restricted RoHS heavy metals
    • Product categories
    • CE marking requirements
    • RoHS marking
    • How to find RoHS compliant components
    • RoHS compliance testing
    • Accredited testing companies
    • RoHS testing costs

    RoHS and RoHS 2

    RoHS (Restriction of Hazardous Substances Directive) is a European Union product certification standard that limits the usage of certain substances (mainly heavy metals) in electronics. The restricted substances are listed below:

    • Lead (Pb)
    • Mercury (Hg)
    • Cadmium (Cd)
    • Hexavalent chromium (Cr6+)
    • Polybrominated biphenyls (PBB)
    • Polybrominated diphenyl ether (PBDE)

    These restricted substances are found in a variety of materials and products such as solder, paint, batteries and metallic parts. Brussels have good reasons for doing so. Heavy metals such as Lead and Mercury are toxic and have a negative impact on both humans and the environment.

    For once the EU has made things a bit easier for us. Starting in 2013, RoHS is now a ‘CE marking directive’.

    Note that RoHS doesn’t cover electrical safety or communication standards, which is covered by other EU directives. These include the Low Voltage Directive (LVD) and the Radio Equipment Directive  (RED).

    Products required to be RoHS compliant

    Most electronic products are required to be compliant with the RoHS directive. This includes, but is not limited to, the following products:

    • Large household appliances (i.e. refrigerators and air conditioners)
    • Small household appliances (i.e. microwave ovens and coffee machines)
    • Computing and communications equipment (i.e. laptops and tablet computers)
    • Cameras
    • Headphones
    • Lighting (i.e. LED lamps and light bulbs)
    • Power tools (i.e. drills and blowers)
    • Electric toys and sports equipment (i.e. fitness bikes)
    • Automatic dispensers (i.e. vending machines)
    • Power Banks
    • Solar Chargers
    • Batteries
    • Solder
    • Cables and wires
    • Medical Devices (i.e. pulse rate monitors)
    • Smart Watches & Wearables
    • Semiconductor devices (i.e. breathalyzers)
    • Quartz Watches (Electronic Movements)

    That’s pretty much anything that can be plugged into a power socket. Always assume that an electrical product is required to be RoHS compliant with importing to the European Union. As a matter of fact, the EU intends to introduce RoHS compliance as a certification requirement for all electronics by 2019.

    RoHS and CE Marking

    All products that fall inside the scope of the RoHS directive must be CE marked. This doesn’t change much, as all electronics are regulated by other ‘CE directives’ such as the Low Voltage Directive or the EMC Directive.

    That said, RoHS compliance involves more than lab testing or selecting the right components. CE marked products must also come with the following documentation:

    • Declaration of Conformity
    • Technical File
    • User Manual
    • Label files

    RoHS Mark / Symbol

    Notice that there is no ‘RoHS mark’. Some suppliers do label their products as ‘RoHS compliant’, but the CE mark is the official and mandatory compliance mark for electronics imported to the European Union.

    Sometimes, the WEEE mark is assumed be a ‘RoHS symbol’, but that is not the case.

    Are all electronic components RoHS compliant?

    No, not all electronic components are RoHS compliant. Many component suppliers, in China and elsewhere, tend to offer the same components as both RoHS and non-RoHS. The former is  slightly more expensive than the latter.

    As such, you must request your manufacturer to specifically procure RoHS compliant components, or contact a component supplier directly.

    How to ensure RoHS compliance when importing from China

    Ensuring RoHS compliance when importing from China is not necessarily that complicated. That said, you must select one of the following two strategies:

    Option 1: Select a RoHS compliant components

    The easiest, and cheapest way, to ensure RoHS compliance is by procuring components that are already RoHS tested. For example, Chinese watch manufacturers can procure RoHS movements from major brands such as Miyota, Seiko or Ronda – or they can procure non-RoHS movements from a local supplier.

    A RoHS tested brand name movement may be a bit more expensive than a non-RoHS movement. Ultimately, you’ll save money by selecting a RoHS tested movement, as you don’t need to pay for testing yourself.

    Option 2: Submit components for RoHS testing

    The other option is to send a product or individual components to a testing company to verify whether its RoHS compliant. If you intend to purchase a private label product, this may in fact be your only option.

    Keep in mind that RoHS compliance testing is always paid for by the customer, not the manufacturer. RoHS testing can be expensive, and cost up to $700 per product, depending on the number of electronic components that must be tested.

    Further, this cost must be carried even if the product fails compliance testing, which is rather likely – if the supplier didn’t specifically procure RoHS compliant components before assembly.

    Can I use my suppliers existing RoHS test reports?

    No, you cannot use an old test report as ‘proof of compliance’ for your own products. A test report is only valid for a specific batch of products.

    You cannot prove that the product covered by the test report was made using the exact same components as your widget.

    That said, an existing RoHS test report can help you assess if the supplier is qualified to make RoHS compliant items, but that’s a very different thing.

    Further, a supplier cannot be “RoHS certified”, as RoHS only applies to specific components. When a supplier states that they are “RoHS certified” on their Alibaba or Globalsources page, they refer to their ability to procure and assemble RoHS compliant components.

    How to book RoHS testing

    All major compliance testing companies offer RoHS compliance testing. This includes Asiainspection, Intertek, SGS and Bureau Veritas. These companies are also accredited in the European Union, meaning that their test reports are accepted by the authorities in EU member states.

    You can request a free quotation online, and submit components directly to their testing facilities in Mainland China or Hong Kong. Note that testing is not required to take place within the EU. What matters is that the testing company is accredited in the European Union.

    There are also hundreds of smaller non-accredited testing companies offering RoHS testing services. Avoid them, as their test reports are not legally recognized in the EU.

    Do I need to ensure RoHS compliance if I imported to the United States?

    No, RoHS is a European Union directive, and is not applicable to products imported or sold in the United States. As of today, there is no equivalent to RoHS in the United States.

    Do I need to ensure RoHS compliance if I sell online to consumers in the EU?

    In theory, you cross-border sellers should ensure compliance with RoHS. However, the reality is that a large number of electronic products, shipped via platforms such as Wish, are not RoHS compliant.

    Further, the EU authorities seem to be far more strict when it comes to enforcing that EU based companies ensure RoHS compliance, while they are very lax when it comes to electronics shipped directly from Chinese online sellers.

    Do you need help to ensure compliance with all mandatory safety standards?

    We know how hard it can be to get a grip on product safety standards, labeling, documents and lab testing. To help startups get a grip on the process, and avoid crippling fines and forced product recalls – we created the Starter Package:

    a. An overview of product safety standards in the United States, Europe, Australia & more

    b. Mandatory document sample files

    c. Product labeling template files

    d. Checklists that guide you step-by-step through the entire compliance process

    In addition, you can also book quality inspections, lab testing and shipping directly from the platform. Click here to learn more.

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  • 4 Responses to “RoHS Compliance When Importing Electronics from China

    1. aggelos at 9:34 pm

      hi! i am from greece and i recently purchased o voltage regulator by vmark a chinese company! on their webside down below are markings like ce iso9001 and rohs compliant. however when i received the product the rohs marking was not on the packaging neither on the product.i found only the ce and the iso9001 markings.how is that possible?i sent them an email but they never answered. i don’t know what to do. i am concerned about my health and the enviroment. please respond to me because they will not answer me.

    2. Edward at 6:04 am

      What about the definition of control and monitoring under category 9 and Industrial control and monitoring category 11? It appears that RoHS authority has stated “Industrial” refers to very large piece of test equipment that is permanently fixed; is intended use with another equipment and must be installed by professional.
      Do those digital multimeters, clamp meters, oscilloscopes come into scope in July 2014 or July 2017?

      Thanks,
      Edward

    3. Faith at 12:28 pm

      Great Advise and Info. I wish I knew all about these before I imported my test batch of tablets. Would have taken longer to purchase but I would have been saved a lot of headache. Will definitely read more on your site. Thanks a lot.

      1. Fredrik Grönkvist at 4:41 pm

        Hello Faith,

        I’m happy to hear that. We’ll publish more related to US and EU compliance in September and October.

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