The administrative measures for the restricted use of hazardous substances in electrical and electronic products have been promulgated in January 6, 2016 and will be formally implemented in July 1, 2016. In order to help relevant parties to understand the requirements of the "management measures" and ensure the effective implementation of the "management measures", in May 16, 2016, the Ministry of energy conservation and comprehensive utilization of the Ministry of industry and Commerce issued the answers to common questions about the implementation of the administrative measures for the restricted use of hazardous substances in electrical and electronic products.
AGC Xin Yu Huan test collects the following issues for enterprises to pay attention to:
1. Scope of application
The original provisions of the management measures: second, the production, sale and import of electrical and electronic products in People's Republic of China shall be governed by these measures.
(1) electrical and electronic definition: Electrical and electronic products refer to equipment or supporting products that are operated by electric current or electromagnetic field or generated, transmitted and measured for current and electromagnetic fields. The rated working voltage is no more than 1500 volts and the alternating current does not exceed 1000 volts. Except for electrical energy production, transmission and distribution equipment. The "supporting products" here refers to components / components, components and materials used for electrical and electronic equipment within the scope of application of the "management measures".
(2) the electrical and electronic products mentioned in the management measures are no longer listed by exhaustive method, including, but not limited to, the following 10 types of equipment and their supporting products.
1. communication equipment
2. radio and television equipment
3. computers and other office equipment
4. household electrical appliances
5. electronic instruments and meters
6. industrial electrical and electronic equipment
7. electric tools
8. medical electronic equipment and equipment
9. lighting products
10. electronic culture, education, industry, sports and entertainment products.
(3) application scenario: "management measures" do not apply to Hong Kong, Macao and Taiwan areas, but electrical and electronic products sold in Hong Kong, Macao and Taiwan and in mainland China should meet the relevant requirements of the "management measures". In addition, export products and raw materials and components imported for export are not subject to the "Regulations on management". The export products shall meet the regulations on the restricted use of hazardous substances in the country / region at the destination of export. Second hand products are not within the scope of application of the administrative measures.
(4) clearly exclude the product range: the following electrical and electronic equipment and its special or customized supporting products are not within the scope of application of the administrative measures:
1. the equipment and equipment involved in the production, transmission and distribution of electric energy, such as power plants, transmission and distribution power stations, and power supply and distribution systems for buildings.
2. electrical and electronic equipment for military use;
3. electrical and electronic equipment for special environment or extreme environment;
4. electrical and electronic equipment for export;
5. temporary import or import and export, but not sale of electrical and electronic equipment;
6. prototype for R & D and testing purposes.
7. for exhibition, exhibition and other purposes, but not for sale of samples, exhibits and so on.
2, implementation time
For the products within the scope of application of the "management measures", the requirements for the "management measures" shall be based on the date of production. That is: the parties concerned should ensure that the products produced in July 1, 2016 and after meet the requirements of the "management measures". The import product is the same as the domestic product. The implementation time is based on the date of production, and has nothing to do with the time of entering or putting into the market.
Among them, the date of production refers to the date when the product completes all the processes on the production line and is inspected and packaged as finished products that can be sold on the market.
3. Applicable standards
The regulations on the restricted use of hazardous substances in electrical and electronic products. The national standards or industrial standards for the restricted use of hazardous substances refer to the following standards (including the standard amendment list):
(1) requirements for restricted use of hazardous substances in electrical and electronic products (SJ/T 11364-2014);
(2) limit requirements for restricted substances in electrical and electronic products (GB/T 26572-2011);
(3) standard for detection of hazardous substances: Determination of six restricted substances in electronic and electrical products (lead, mercury, cadmium, six valent chromium, polybrominated biphenyl and polybrominated two phenyl ether) (GB/T 26125-2011, IDT IEC 62321:2008); atomic fluorescence spectrometry for determination of six valence chromium in electrical and electronic products (GB/T 29783-2013).
The above standards are formulated for the implementation of the "management measures". They are the standards that must be enforced in the "management measures". Only when enterprises implement the standards adopted in the management measures can they meet the requirements of the "management measures", so the products within the scope of application must comply with the requirements.
4, SJ/T 11364-2014 compliance issues and information on hazardous substances in products
The parties concerned can collect and integrate hazardous substances in electrical and electronic products through the combination of their own hazardous substances control and risk management measures, but not limited to the following ways, and identify the harmful substances in the products according to the requirements of SJ/T 11364-2014.
(1) require upstream suppliers to provide relevant self declaration information and supporting technical documents.
(2) according to the real and effective product inspection reports from any party, or by self or commissioned third party to detect harmful substances in the product;
(3) effective third party product certification.
5. Conformity assessment system
Regarding the conformity assessment system, the management method still adopts the idea of "two steps", that is, the "first step" requires only declaring the harmful substance information within the scope of application of the management measures, that is, to comply with the standard of labeling requirements; and the second step is to limit the requirements for hazardous substances entering the product catalogue of the management of the use of hazardous substances in electronic products. The difference is: for the conformity assessment mode involved in the "second steps", the eighteenth of the management measures points out that "the state establishes the conformity assessment system for the restricted use of hazardous substances in electrical and electronic products". It is about to formulate a conformity assessment system that is suitable for China's national conditions according to the actual development of the industry.
6. How do we determine whether the battery and battery for different applications belong to the scope of application of the management measures?
A: except for the special batteries and batteries used in exclusive management of this product, the other types of batteries and batteries belong to the scope of application of the "management measures".
7, the main body of responsibility
After the entry into force of the management measures, even if the final product producers have a good green supply chain management system, but if the final product is found to be out of line with the requirements of the regulation due to the supply chain reasons, is it the responsibility of the final product producer or its upstream supplier? According to the answer, in this case, if the final product is found to be out of line with the provisions of the "management regulations", then the problems caused by the upstream suppliers, such as components or components, will also be responsible for the producers of the final products. The responsibility of the upstream suppliers should be traced back by the final product manufacturers themselves.
For more answers, please refer to:
Http://www.miit.gov.cn/n1146295/n1652858/n1653018/c4777618/part/4777622.pdf
(source: Xin Yu ring)
