Design Chain Associates, LLC
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June 3, 2019

Welcome to the June 2019 Design Chain Associates E-mail Newsletter! This is a quick, one-topic newsletter: China RoHS! Check the News and Upcoming Events sections as well.

In addition to DCA's newsletters, keep an eye on DCA's bi-monthly articles in TTI's MarketEYE Resource Center.

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China RoHS 2 Conformity Assessment System Announced and Translated

Late last month, China's Ministry of Industry and Information Technology (MIIT) and the newly formed State Administration for Market Regulation (apparently the AQSIQ and SAC have been absorbed into this new organization) announced the issuance of the "Implementation Arrangement for the Conformity Assessment System for Restricted Use of Hazardous Substances in Electrical and Electronic Products (EEP)".

As a refresher, China RoHS only restricts substances when a product - an EEP - is listed in the Catalog. The Catalog today includes the following EEPs:

The Conformity Assessment System calls out new marks as well as two methods of certification: voluntary 3rd party certification and self-declaration. Evidence of compliance, the extent of which appear to be similar to a complete technical document file for EU RoHS, must be submitted for the self-declaration process, while extensive 3rd party testing and on-site audits are aspects of the voluntary certification process. No rationale for why a manufacturer would choose the voluntary certification over the self-declaration process is provided (it may have to do with preference for government procurement; I expect them to explain further at some point). The new mark, and the "public service platform" to which this evidence of compliance must be uploaded for both certification processes, are part of China's new Green Product Label process. Products must be compliant by November 1, 2019.

We have translated the "Implementation Arrangement for the Conformity Assessment System for Restricted Use of Hazardous Substances in Electrical and Electronic Products (EEP)", including the two annexes that describe the certification processes, as well as the "Measures for Usage and Administration of Green Product Labeling" (GPL). We are offering the GPL measures separately for manufacturers whose products are either not in the above list or are not EEPs and would like information on how and when to use these labels. Please visit our China RoHS website for more info, including links to the original Chinese and the ordering page (where we have finally reimplemented the PayPal cart, per popular demand!) for our translations.

See below for a link to a Chemical Watch article that discusses these new developments. And stay tuned! There's always more to come for China RoHS.

DCA Articles & DCA In The News

Note that you can now catch-up on past DCA newsletters on our DCA In The News web page!

May 22, 2019 Chemical Watch: China issues conformity assessment rules for RoHS2. Two conformity assessment approaches have been defined, along with a new mark, for EEPs in the initial catalog.

May 17, 2019 Last Month's DCA Newsletter: May 2019. More on organohalogen flame retardant restrictions and conferences to attend.

Events to Attend

September 16-17, 2019: Boston, MA. Chemicals Management for Electronics & Electricals USA 2019. After successful conferences in San Francisco and Brussels, we will co-chair this important conference in New England. Attend for a comprehensive view on the forces driving chemical-related product and business model changes in the electronics industry, and to network with your peers, regulators and others. Contact me for a discount!

July 23, 2019: Webinar: The end of plastics in electronics? What could possibly bring about the end of plastics in electronics and what must electronics manufacturers and the chemical industry do about it? Along with Lauren Heine, Director of Safer Materials and Data Integrity, MaterialWise, we will try to address those questions.

June 24-25, 2019: Santa Clara, CA. ANSI June 2019 Company Member Forum. The ANSI Company Member Forum will be at Qualcomm's Silicon Valley headquarters this year. Topics include China standards, trade agreements, internal management of standards, government affairs, 5G, sustainability and the circular economy (chaired by DCA), and more.

June 11-13, 2019: Reston, VA. ACS Green Chemistry & Engineering Conference. Come to fabulous Reston, VA, learn about where green chemistry is in use, where invention is needed, and network with the leaders in the field. We will have a short session focused on battery and photovoltaic technologies, as well as a call-to-arms for invention.

More to come! Stay tuned.

Contact and Feedback

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This newsletter covers only a fraction of how we support our clients. DCA offers expertise and consulting services in all the areas covered above, as well as many others. Please contact us to discuss your needs.

Best Regards,
Michael Kirschner

Design Chain Associates LLC

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