RoHS | January 23, 2007

What You Need to Know About ACPEIP (China RoHS)

On February 28, 2006, China publishes its new law entitled »Administration on the Control of Pollution Caused by Electronic Information Products« (ACPEIP), often referred to as the »China RoHS« because, as far as the prohibition of substances is concerned, it does have similarities to the EU RoHS-directive.
The ACPEIP regulates the dissemination on the Chinese market of »electronic information products« (EIPs) that contain lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBBs) or polybrominated diphenyl ether (PBDE) up to thresholds defined in accordance with »Industry Standard SJ/T 11363-2006«. In principle, the maximum permitted thresholds line up with those published in the EU's RoHS Commission Decision (2005/618/EC). However, the ACPEIP legislation also includes a number of requirements that go beyond the RoHS Directive. The Chinese law, for example, requires that special labels and supplementary information be attached to EIPs. By the end of 2007/early 2008, it will also make tests and certification compulsory for certain EIPs.

All EIPs that are manufactured in or imported to China fall under the jurisdiction of the ACPEIP. The labeling and supplementary information requirements concern every EIP. A list of EIPs published by the authorities also indicates those parts, components and materials that are affected by the new law. On the other hand, the prohibitions on certain substances and the need for certification prior to marketing concern only those EIPs that will be defined in a special »Key Product Catalogue«. The finalized rules and standards for the creation of this catalogue – and the implementation of certification – have not yet been published.

Time frame
Binding aspects effective March 31, 2007:

1. Labeling and supplementary information: Affects – with exceptions – every product defined as an EIP. Important note: EIPs that are intended for further processing do not have to be labeled. The relevant information must be made available by the supplier, however (see below: China RoHS information for EPCOS products).

2. Prohibition of substances

3. Compulsory pre-marketing certification

The latter two EIP listed in the »Key Product Catalogue«. However, this catalogue is not yet available.

Marking/ Labeling scope EIP
The labeling is mandatory from March 1, 2007 on.

According to the Q&A published on MII website (, and the most recent Standard on Marking SJ/T11363 , section 4 General Rules, for electronic information products (EIP) that are purchased for manufacturing, e.g. passive components, suppliers need not provide the aforementioned marking, but shall supply to the purchaser all necessary information required for marking. However, information on hazardous material content has to be provided to customer. This information can hereby be provided via Internet or any other appropriate electronic or paper based version, if there is no internet access at the purchaser's location.

Marking/ Labeling for packaging
Packages of EIP do not have to be labeled according to GB 18455-2001, if the package is not used for separate sale to an end-customer

Marking formalities

For those EIP with mandatory labeling (see comment Marking / Labeling Scope EIP) the green label (Fig. 1) applies when the EIP does not contain any of the restricted substances above their thresholds. The green "e" label is mandatory if it applies.

For those EIP that contain these substances, or one of these, above their thresholds, the orange label applies (Fig. 2). The number inside is the so-called EFUP (Environmentally friendly use period) indicating the period in years from date of manufacturing in which no hazardous substance is released to the environment. The EU RoHS exemptions are not considered, thus the respective EIP would have to be labeled in orange incl. EFUP according to the regulation.

The labels do not necessarily have to be colored and can also be black/white or of the same color as the product, e.g. when printed on the housing.


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