1. Management Methods for Controlling Pollution by Electronic Information Products Chris Cleet, Manager of Environmental Affairs Electronic Industries Alliance (EIA) ECA Fall Engineering Summit September 26, 2006

2. China Rulemaking Principles  Guilty until proven innocent  China laws generally speak of “precaution”  Laws generally require “proof of innocence”  Pre-market testing  Certification

3. China Rulemaking Principles  Looking internationally for inspiration  Looking to other countries for models  Use of “models” does not mean they are “copying”  Tend to review models for inspiration  Fit to meet China’s needs

4. China Rulemaking Principles  Resource Conservation  China increasingly concerned with resources conservation  Energy  Water  Materials

5. “Management Methods for Controlling Pollution by Electronic Information Products”

6. RoHS Pronunciation

7. China RoHS ≠ There is a misperception that because it’s often called “China-RoHS” that it is just like the European Union RoHS Directive

8. Agencies  Lead agency:  Several other agencies are involved in developing the implementing measures for China RoHS  State Environmental Protection Agency (SEPA)  Administration for Quality Supervision, Inspection and Quarantine (AQSIQ)  State Administration for Industry and Commerce (SAIC)

9. Important Dates 20062007 February 28, 2006 China RoHS promulgation. China RoHS released to the public a few days later March 1, 2007 Effective date for labeling provisions and measures other than materials restrictions September 2007 – March 2008 Projected, possible effective dates for first batch of catalogues/ materials restrictions September 2006 – June 2007 Possible promulgation period for RoHS standards (will not be released all at once; labeling, MCV and testing standards likely released first)

10. Scope  “Electronic Information Products”  Defined in categories; there are many…partial list is:  Communications equipment, electronic components, audio equipment, surveying equipment  MII issued an illustrative note listing products in these categories, on March 16, 2006  Covers finished products, parts and components and materials

11. China RoHS  Three key components: Thou shalt not use… Substance Restrictions Pre-market certification Labeling

12. China RoHS  To ease understanding…think of China RoHS as two separate laws: 1)Labeling and information disclosure 2)Substance restrictions and pre-market certification

13. Labeling and Information Disclosure  Must comply if “you import or manufacture EIP”  Goal of labeling:  Protect environment  Provide end-of-life information for users and recyclers

14. Labeling and Information Disclosure  Three key elements:  Environmental protection period (articles 3, 11, 12)  Material content, toxic-substance content and recyclability marking (article 13)  Packaging material content marking (article 14)

15. Labeling and Information Disclosure  Materials content and environmental protection period accomplished through product labeling Label 1Label 2

16. Labeling and Information Disclosure  Label 1:  Any EIP that does not contain toxic or hazardous subtances  Must be on product or in product literature  Label 2:  Any EIP that contains toxic or hazardous substances  Must be marked on product (except where product literature marking is authorized, per the labeling standards)

17. Labeling and Information Disclosure  If EIP is subject to label 2, a table must be in the product literature: Name of Part* PbHgCdCr6+PBBPBDE resistorXOOOOO *Definition of “part” is subject to MII interpretation

18. Substance Restrictions  Catalogue approach  No “exemptions” as per EU RoHS  If not in catalogue, not covered  MII is working on criteria for listing EIP in the catalogue

19. Substance Restrictions  Current substance restrictions (article 3)  Lead  Mercury  Cadmium  Hexavalent chromium  PBBs  PBDEs  Maximum concentration limit standards (MCVs) are being finalized and will be set forth in an implementing standard

20. Substance Restrictions  Pre-market testing and certification  Apply only to those EIP listed in the Catalogue  Will require testing by Chinese labs  AQSIQ certification based on lab results  Testing methods are being finalized  Dates for implementation to be included on catalogue

21. Q&A

22. Contact Information Chris Cleet Manager of Environmental Affairs Electronic Industries Alliance 703-907-7573 ccleet@eia.org