The European Union RoHS directive issued in 2003 and the Chinese ROHS directive issued in 2006 have the same goal - both of which are to reduce the use of harmful elements in electronic products. These two directives strictly restrict the use of some specific chemical substances [including lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE)]. The framework structure of the directives is also similar (for example, the scope of application of the directives), and there are many differences in the specific contents of the directives. For example, the authentication methods required by the two instructions are different; The identification methods are also different. The identification requirements of China's ROHS directive include the packaging part, while the EU's ROHS directive does not require packaging.

An important part of China's ROHS directive is the issuance of the key catalogue in the plan. This key catalogue will define in detail the catalogue of products controlled by the directive and the implementation schedule. The current planned release date of the catalogue is the autumn of 2008, but it is still unknown whether it will be released as scheduled. The specific contents of this directory are unknown at present. For a simple example, according to the information we have so far, we are not sure whether the products included in the key catalogue will be finished products, raw materials or electronic components. In addition, another important part of the catalogue is a list of exempted products. The majority of electronic manufacturers hope that this exemption list can be consistent with the exemption content in the EU ROHS directive, so that they can continue to sell products that have met the EU ROHS requirements in China without changing the product design and process again.

Main differences between the two directives at present

One of the main differences between the two directives is the party responsible for the product. The EU directive stipulates that manufacturers of products must ensure that products comply with the provisions of the directive. In China's ROHS directive, manufacturers and sellers of products may be punished for producing or selling products that do not meet the requirements of the directive.

Before the promulgation of the key catalogue of China's ROHS directive, the directive did not specifically restrict the use of harmful substances. Its main function was to require manufacturers to correctly mark whether their products contained harmful elements according to the requirements of the directive. China's RoHS marking directive, which was officially implemented on March 1, 2007, is a new attempt in the world. At the same time, some of the products it covers are also exempted from the EU ROHS directive. For example, medical equipment and measurement and control instruments are exempted from EU directives, but they are also required to be identified in China's RoHS directives. The marking Directive requires all manufacturers to complete the implementation within one year after the promulgation of the directive, and then many detailed provisions on the implementation of the directive will be gradually followed at the end of the one-year time limit. Because the time of implementation is too tight, the whole supply chain of electronic products has also been confused.

As a part of China's RoHS marking requirements, all products must be accompanied by a form (or provided from the manufacturer's website) when they leave the factory to indicate whether the products contain harmful substances. This table (see Figure 1) contains the main parts and components constituting the product, and it must indicate whether the harmful substances contained in the product are below the limit content (marked with O) or above (marked with x). The form must be in Chinese.

In addition to the above table, the product must also be attached with a label (if the product size is too small, the label can be attached to the accompanying document) to display the environmentally friendly use time (EFUP). The label is displayed in two forms as shown in the figure below.