China RoHS 2: Regulation Revamp Increases Scope

China RoHS 2: Regulation Revamp Increases Scope

China’s Management Methods for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products Regulation, or China RoHS 2, was published on January 21st.

While China RoHS 2 continues to deal with the original hazardous substances found in the regulation’s first iteration, the primary change between the two is an expansion of its scope. The original scope was a specific list known as the Electronic Information Product (EIP) list. Now, the regulation covers anything that falls under the definition of an electrical product. This aligns China RoHS 2 with the European Union’s (EU) Restriction of Hazardous Substances Directive.

However, unlike EU RoHS, China RoHS 2 does not identify any out-of-scope products. This is significant for a number of newly in-scope companies who will have to label their products with their environmentally-friendly use periods (EFUPs) and update product documents with a table of toxic and hazardous substances.

All of this must be implemented by July 1st, 2016.

Historically, consumer appliances have been out of scope. Dishwashers, for example, will now require EFUPs and tables of toxic and hazardous substances to be ready by the deadline. This is not a long transition period. Manufacturers must adjust quickly to the new rules in order to meet this deadline.

Additional analysis will be provided once further guidance on this matter is received.


For more information on RoHS 2, contact our regulatory experts at

For the latest news and information on the EU RoHS Directive, read our blog here.