The administrative measures for the restricted use of hazardous substances in electrical and electronic products (the industry is called China RoHS2.0) has 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 new regulation and ensure effective implementation, the Ministry of energy and energy conservation of the Ministry of industry and Commerce has organized the "common questions answering questions on the implementation of the" Regulations on the restricted use of hazardous substances in electrical and electronic products ".
The first part is comprehensive questions.
Q1. what laws and administrative regulations are the upper law of the administrative measures? What is the purpose and significance of our revised management measures?
Answer: "management method" is a departmental rule, and its upper law is "People's Republic of China Cleaner Production Promotion Law", "People's Republic of China solid waste pollution prevention and control law" and "waste electrical and electronic products recycling management regulations".
The purposes of the management measures are mainly reflected in the following aspects:
1. actively implement "China made 2025", implement green manufacturing in an all-round way, develop green products and build green manufacturing system.
2., limiting the work of hazardous substances in electrical and electronic products as the basic work of China's industrial clean production and recycling of waste electrical and electronic products, embodies the principles of environmental protection for pollution prevention and prevention, and implements the work idea of "starting from the source".
3., restrict the use of hazardous substances in electrical and electronic products into the industry management, realize legalization and integrate with the international market.
4. promote the substitution or reduction of hazardous substances in electrical and electronic products, advocate ecological design, and promote environmental protection and resource conservation and comprehensive utilization in the process of production, use and end disposal of electrical and electronic products.
5. accelerate the adjustment and optimization of industrial structure and ensure the sustainable development of related industries.
Q2. "management measures" is a new departmental regulation revised on the basis of the original "electronic information products pollution control management measures" (hereinafter referred to as the "original method"). What major adjustments have been made to the relevant requirements of the "management measures" compared with the original method?
A: compared with the original method, the revised management measures have made the following adjustments in specific requirements:
1. scope of application
After the original method is revised, the name is amended as the "administrative measures for the restricted use of hazardous substances in electrical and electronic products" [in the original method, which is called the catalogue of key management of pollution control of electronic information products]. Compared with the original method, the scope of application of the management measures is extended from the original electronic information products to the electrical and electronic products, but the core contents are all restricted by the use of harmful substances.
2. relevant 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 method", that is, to comply with the standard of identification requirements. The "second step" requires the implementation of the hazardous substances limit requirement for the product catalogue of the use of hazardous substances in the electrical and electronic products (hereinafter referred to as the "catalogue of compliance management").
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.
3. delete the identification requirements for packages.
In the "management measures", the requirements for materials that are harmless, easy to degrade and easy to recycle should be adopted when producers and importers of electrical and electronic products make and use packaging. Considering that China has issued the national standards for labeling requirements of product packages, the "management measures" have deleted the original requirements for the packaging of products.
In the Q3. management method, it is required to restrict the use of harmful substances in electrical and electronic products. In the original method, it is called "toxic, harmful substances or elements". What is the difference between the two statements?
Answer: "management method" standardizes the expression of restricted substances, and does not affect the relevant provisions of the "management measures".
Is the Q4. management method applicable to Hong Kong, Macao and Taiwan?
Answer: "management method" does not apply to China's Hong Kong, Macao and Taiwan regions. However, the production of electrical and electronic products sold in Hong Kong, Macao and Taiwan and in mainland China should meet the relevant requirements of the "management measures".
Q5. is the product within the scope of application of the administrative measures to meet the requirements of the "management regulations", or is it based on the date of production of the product or the time when the market is put on the market?
Answer: for the products within the scope of application of the "management measures", the requirements for the "management measures" are 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". 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.
Q6. should the management measures also be based on the date of production for imported products? Is it related to the time of entry or market?
Answer: import products are the same as those produced in China. The time of implementation is based on the date of production, and it has nothing to do with the time of entering or putting into the market.
Q7. "management measures" mentioned in a number of "should meet the electrical and electronic products harmful substances use of national standards or industry standards", and "no violation of electrical and electronic products harmful substances use of national standards or industry standards", what are the main criteria? Must these standards be implemented?
Answer: according to the provisions of the eleventh, thirteenth, fourteenth, sixteenth and eighteenth provisions of the "management measures", the following criteria (including standard amendments) are used to limit the use of hazardous substances by national standards or industrial standards.
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 (lead, mercury, cadmium, six valent chromium, polybrominated biphenyl and polybrominated two phenyl ether) of electrical and electronic products (GB/T26125-2011, IDTIEC62321:2008);
Atomic fluorescence spectrometry for determination of six valence chromium in electrical and electronic products (GB/T29783-2013).
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.
In the third paragraph (six) of Q8.'s management measures, the concept of the term of environmental protection is put forward. Is the term of environmental protection equivalent to that of safe use?
Answer: according to the definition of "management measures", the term of environmental protection for electrical and electronic products refers to the period when users do not normally leak or change the harmful substances contained in electrical and electronic products according to the normal use of product instructions, do not cause serious pollution to the environment or cause serious damage to their personal and financial assets. The term of safe use is totally different from that of environmental protection. The period of use of environmental protection does not include the time limit due to factors such as electrical performance safety, electromagnetic safety and other factors. However, in many cases, safety problems are often accompanied by the leakage of harmful substances.
Q9. electrical and electronic products are complex in structure. How to determine the environmental protection term of a product?Is the deadline for environmental protection to be approved by the government?
Answer: according to the provisions of the fifteenth provision of the administrative measures, the environmental protection term of electrical and electronic products can be formulated by the enterprise itself, and the various industry associations shall be encouraged to formulate the guidance for the environmental protection use period of the products in this trade. Enterprises can also refer to the method of general term of environmental protection application of electronic information products (SJ/Z11388-2009) to determine the environmental protection term of products.
Generally speaking, the environmental protection term of the whole product should be based on the time limit of the components with the shortest environmental protection period in the product.
The determination of the term of environmental protection does not require government approval.
The second part is about the scope of application of the administrative measures.
I. scope of application of the administrative measures
What is the "matching product" in the definition of electrical and electronic products in the Q10. management measures?
Answer: "supporting products" in the definition of electrical and electronic products in the "management measures" refers to components / components, components and materials used for electrical and electronic equipment within the scope of application of the "management measures".
Note: spare parts or optional accessories for electrical and electronic equipment, as well as spare parts for maintenance, renovation, expansion or upgrading, also belong to the above components / components. Among them, the standard accessories are random accessories. If there is a lack of standard accessories, to a certain extent, it will affect the use and performance of products; optional accessories refer to components that can enhance product functions and improve product performance beyond standard configuration. Unlike standard accessories, the use of optional parts does not affect the use of the basic functions of the product.
As a part of electrical and electronic products, supporting products should meet the requirements of the "management measures".
In the definition of "Q11. electrical and electronic products", "except for electrical energy production, transmission and distribution equipment", which equipment is excluded? Besides, what other products and conditions are excluded?
Answer: the following electrical and electronic equipment and their special or customized supporting products are not within the scope of the "management 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;
(Note: Electrical and electronic equipment for export shall be in conformity with the provisions of the national / regional restricted use of hazardous substances in export destinations.)
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.
Are there any supporting electronic products classified in Q12.? The notes of the product list are listed in the notes.
Answer: the "electronic information product classification notes" of the original method enumerated the ten categories of products that were applicable. However, the scope of application of the "management measures" has been extended to electrical and electronic equipment and supporting products. Taking into account the rapid development of the technology in the electrical and electronic industry and the rapid updating of products, it is still difficult to exhaust all electrical and electronic equipment by enumerating. The method of summarizing and explaining the major equipment categories applicable to the management measures is now being used for reference in the process of classifying and controlling the products in the execution process of the relevant parties.
The scope of application of the management measures includes, but is not limited to, the following types of equipment and their supporting products:
1. communication equipment
Fixed or mobile communication access, transmission, switching equipment, communication terminal equipment, including wired communication equipment and wireless communication equipment. Such as speed radar, wireless remote control and navigation equipment, walkie talkie, cell phone, fax machine, telephone, radio frequency products, etc.
2. radio and television equipment
Radio and television program production and broadcast control equipment, radio and television transmission and transmission equipment, as well as the application of television equipment. Such as professional radio and television receiving equipment, professional audio and video replay and audio equipment, and observation of surveillance TV, educational television, special imaging TV, special function TV and tracking TV and other application TV equipment.
3. computers and other office equipment
Computer equipment includes computer and its peripherals, as well as computer network equipment and computer applications, such as finance, information security, industrial control, information collection and identification, and terminals. Such as workstations, servers, minicomputers, learning machines, electronic dictionaries, electronic albums, routers, printers, human-machine interaction equipment, IC card reading and writing machines, handwriting boards, biometric identification equipment, mobile storage media, UPS, voice and graphic image transmission equipment, etc.
Other office equipment include slide projector and projection equipment, camera, photocopying and offset printing equipment, calculator and currency special equipment. For example, all kinds of photocopying equipment and set of photocopying, printing, scanning, fax as one of the multi-function integrated machine, shredder, typewriter, attendance machine, calculator, banknote counting machine.
4. household electrical appliances
Electrical appliances for household appliances refer to electrical and electronic equipment and devices for household and similar purposes, including audio and video equipment, audio equipment, refrigeration appliances, air conditioner, ventilation appliances, kitchen appliances, sanitary appliances, beauty appliances, health appliances, electrical and thermal appliances, sewing and weaving processing equipment and similar products, as well as electronic watches and clocks. They also include household electrical appliances such as household gas cookers, gas heaters, gas water heaters, solar water heaters, and system terminal equipment such as security, monitoring and so on.
Among them, "household and similar uses" refers to non production machines and devices which are mainly used for families but can also be used in offices, factories, shopping malls, restaurants and other public places.
5. electronic instruments and meters
Electronic instruments and meters are electronic appliances or devices used to detect, measure, observe and calculate various physical quantities, material components and characteristic parameters. For example: Electrical and electronic measuring instruments, electronic analysis instruments, electronic counting / timer, electronic monitoring equipment and instruments.
6. industrial electrical and electronic equipment
Including industrial processing, production and testing of electrical and electronic equipment, industrial control monitoring equipment and so on.
7. electric tools
An electric tool is a mechanized tool driven by a motor or an electromagnet to drive a working head through a transmission mechanism, including hand-held, removable and garden power tools. According to the way of operation and usage, it can be divided into metal cutting, sand grinding, assembling, forestry, agriculture and animal husbandry, horticulture, building road and mining.
8. medical electronic equipment and equipment
Medical electronic equipment and devices refer to electronic instruments, equipment, appliances and other similar or related articles directly or indirectly used in the body for the diagnosis, prevention, monitoring, treatment or alleviation of diseases.
9. lighting products
It includes electric light source and luminaire. For example, electric light sources include incandescent lamps, halogen lamps, fluorescent lamps and high-intensity gas discharge lamps, and LED lamps. Lamps and lanterns include indoor lighting lamps, outdoor lighting lamps and emergency lamps.
10. electronic, educational, industrial, sports and entertainment products include all kinds of electronic musical instruments, toys, sporting goods, entertainment equipment and entertainment products with electronic or electrical components.
How does the Q13. party decide whether the electrical and electronic equipment belongs to the scope of application of the administrative measures?
Answer: the following procedures sum up the provisions of the regulations and the scope of application of the management measures in this document. The parties concerned can determine whether the products belong to the scope of application of the "management method" according to the following process.
If necessary, it is the responsibility of the interested parties to preserve and / or provide evidential materials relating to the type of products whose products are clearly excluded from this document.
Two. Specific cases concerning the scope of application
Are Q14. electric transport equipment and tools applicable to the "management measures"?
Answer: electric transport equipment and tools do not belong to electrical and electronic products, so they do not belong to the scope of application of the administrative measures.
How does Q15. 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".
How does Q16. meet the requirements of the "management regulations" for different applications of wire and cable?
Answer: except for the first items of Q11, which exclude the transmission and distribution cables, other cables used for electrical and electronic equipment within the scope of application of the "management measures" shall meet the requirements of the "management measures". For sale of cables that are not sold in the market and not definitive end use, they should also meet the requirements of the "management measures".
Are Q17. toner cartridges, ink cartridges and other consumables belong to the scope of application of the "management measures"?
Answer: for the electrical and electronic products, consumers can replace their own consumables (such as toner cartridges, ink cartridges, etc.). For consumables that do not belong to electrical and electronic products, such as vacuum bags for vacuum cleaners, when they are sold together with vacuum cleaners, they should meet the requirements of the "management measures". When they are put on the market alone, they are not subject to the "management measures".
Do Q18. products and processed products conform to the "Regulations"?
A: in the broad sense, the processing of incoming materials and the assembly of materials are the behavior of using foreign supplied raw materials and parts to process finished products or assemble the whole machine and then export. Export products and raw materials and components imported for export are not subject to the "Regulations on management".
The processing of incoming materials is to sell products from foreign supplied raw materials, parts and finished products or assemble the whole machine. If the product is exported, it is not subject to the "management measures". If the product is sold in the Chinese territory, it should comply with the requirements of the "management regulations".
The export products shall meet the regulations on the restricted use of hazardous substances in the country / region at the destination of export.
Q19. is the electrical and electronic products in the products outside the scope of the administrative measures applicable to the scope of administration?
Answer: Electrical and electronic products that are only intended to be installed outside the scope of application of the "management measures" do not fall within the scope of application of the "administrative measures". For example, a display screen installed on a car or airplane seat, a common component that is scheduled to be installed on the power generation equipment, etc.However, these products fall within the scope of the "management approach" when they are not explicitly used for final purposes and sold separately in the market.
Is the whole package replacement product in the Q20. after-sales service applicable to the "management measures"?
Answer: the whole package replacement product is regarded as the new product with the same nature as the original product being put on the market. It belongs to the scope of application of the "management method".
Has Q21. been sold or sold as a second-hand electrical and electronic product when it is sold again? Is it under the jurisdiction of the "management method"?
Answer: second-hand products are not within the scope of application of the administrative measures.
How should Q22. leasing products implement the relevant provisions of the "management measures"?
Answer: the sale of products to the market in the form of leasing is the scope of application of the "management measures".
Q23. after the implementation of the "management measures", do overseas parent companies need to meet the requirements of the "management measures" when they sell their electrical and electronic products to their subsidiaries in China?
Answer: if an overseas parent company sells the product to a Chinese subsidiary with different independent legal person qualifications, it shall satisfy the requirements of the "management measures"; if the overseas head office sells the product to a Chinese branch with the same legal person qualification, such a situation is a transfer of the company's internal assets and does not belong to the act of "putting the market", so it is not subject to the "management measures".
The third part of the basic requirements of "management measures"
I. implementation of management measures and implementation process of enterprises
What is the implementation of Q24. management measures and the implementation process of enterprises?
Answer: the following process summarizes the implementation of the "management measures" and the general process of enterprise implementation.
Two. Categories of hazardous substances
How to understand the "7. harmful substances stipulated by the state" in the third paragraph (five) of the Q25. management measures?
A: This is a general way of expression of Chinese legal normative documents.
With the development of technology and environmental requirements, industry and information
The Department will adjust the list of hazardous substances in this article at the right time.
Three. Marking requirements
(1) implementation of standards in transition period
Q26. before the date of implementation of the management measures, how shall the parties concerned implement the provisions of SJ/T11364-2014?
A: SJ/T11364-2014 has been released in July 9, 2014. According to the 2014 Announcement No. eighty-eighth of the Ministry of industry and information technology 4, the date of implementation of SJ/T11364-2014 will be consistent with the date of implementation of the "management measures". Therefore, before the date of implementation of the "management measures", the parties concerned can gradually switch the old and new SJ/T11364 standards. In the meantime, the implementation of the old and new standards is in line with the requirements of the "management measures". For the newly incorporated electrical and electronic products within the scope of application of the "management measures", the relevant parties should gradually complete the identification of hazardous substances information in accordance with the requirements of SJ/T11364-2014 during the transition period.
The relevant parties shall ensure that the electrical and electronic products produced in July 1, 2016 and after meet the relevant provisions of SJ/T11364-2014.
How should Q27. enterprises operate to meet the relevant requirements of SJ/T11364-2014, and which documents should be used to declare harmful substances in products?
Answer: 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/T11364-2014:
A) requires upstream suppliers to provide relevant self declaration information and supporting technical documents.
B) testing the harmful substances in the product according to the real and effective product inspection reports from any party, or by self or commissioned third party.
C) effective third party product certification certificate.
The parties concerned shall be responsible for the authenticity and validity of the statement information.
What date is the starting date of the environmental protection term of Q28. electrical and electronic products?
Answer: the starting date of the environmental protection term of electrical and electronic products is based on the date of production.
After the formal implementation of the Q29.SJ/T11364-2014, can the name and content list of harmful substances not used by enterprises continue to be used, or can the form be used as a corrigendum of the original form?
Answer: usually, after the SJ/T11364-2014 implementation date, the name and content list of harmful substances that the enterprise has not exhausted can not continue to use if it does not meet the standard requirements. If the form is part of the product manual or printed on the product package, the instruction / package can be used continuously, but for saving consideration, the enterprise can use the form of inserts to correct the original form.
(two) the scope of application of the relevant standards
The scope of application of Q30. management method is electrical and electronic products. The products of SJ/T11364-2014 are applicable to electrical and electronic products. How can enterprises carry out SJ/T11364-2014?
Answer: the products within the scope of application of the "management measures" shall be marked according to SJ/T11364-2014. The products that are not within the scope of application of the administrative measures but within the scope of the SJ/T11364-2014 standard shall be recommended to be marked by SJ/T11364-2014.
(three) identification of supporting products for electrical and electronic equipment.
Q31. how should the upstream and downstream enterprises of the supply chain convey and identify harmful substances in the procurement activities for production matching?
Answer: according to the SJ/T11364-2014 regulations, the supplier can not identify the products supplied for the purchase of electrical and electronic products for production matching, but must provide the purchaser with all the information required for identification. This regulation is mainly aimed at reducing the production cost and avoiding duplication marks in the manufacturing process. According to this regulation, the logo can only appear on the final product, but the identification information must cover all the components of the product; while the upstream supplier has the responsibility and obligation to provide the downstream customers with all the information required for identification. Among them, the electrical and electronic products purchased for production matching include electrical and electronic components, components or raw materials purchased from abroad for production matching.
Are the spare parts for Q32. replacement or repair required to be identified?
Answer: because spare parts of electrical and electronic equipment are usually used for maintenance and upgrading of the same type of products on the equipment, there is no need to identify spare parts for electrical and electronic equipment for after-sale service in order to avoid duplication of labels.
Q33. is it necessary to identify parts that do not belong to electrical and electronic equipment when they are sold together with the whole machine? Does the content list contain the harmful substances contained in these accessories?
Answer: for parts that do not belong to electrical and electronic equipment, if they are sold together with the whole machine, if necessary to meet the requirements of the product structure or function, such as the expansion platform of the electric sewing machine, the lens hood of the camera, etc., they need to be identified according to the SJ/T11364-2014. In the name and content table of the harmful substances, the contents of the harmful substances of these accessories need to be specified; otherwise, they can not be identified.
Q34. for removable parts of electrical and electronic equipment, when they are also part of electrical and electronic equipment, will the environmental protection term be individually tagged or tagged together with the whole machine?
Answer: for removable fittings, when it itself belongs to electrical and electronic equipment (such as power adapter, keyboard, etc.), enterprises can choose whether to mark the environmental protection term with the whole machine. If labeled together, the "harmful substances name and content list" should contain information on the harmful substances of these accessories; if it is indicated separately, the name and content list of the harmful substances can be selected separately or marked together, but the parts should be covered in the table and indicate the location of the hazardous substance.
For such components that need to be regularly replaced and contain harmful substances, especially when the environmental protection term of the component is lower than other parts of the equipment, the parts and machines that need to be replaced regularly can be identified separately, so that the environmental protection life of the whole product will not be affected by the replacement parts.
Q35. how should we identify the complete sets of equipment containing multiple electrical and electronic products? For example, do TV sets and random sale remote controls require independent identification?
Answer: if the environmental protection term of these electrical and electronic products is different, it can be identified separately. If the environmental protection term is the same, it can be identified or identified on the main product. The content list should include the harmful substances contained in the whole equipment and indicate the location of the hazardous substances.
(four) specific requirements for logo contents and logos
Q36. when the content of harmful substances in the product has not exceeded the limit requirement stipulated in GB/T26572-2011, should the "e" sign shown in Figure 1 in SJ/T11364-2014 be identified?
Answer: according to the requirements of 6.2.1 of the S / T 1, 13, 6, 4 - 2014, if the content of hazardous substances in the product does not exceed the limit requirement stipulated in GB/T26572-2011, the figure 1 ("e" sign) should be selected for identification, and no hazardous substance content list is required.
Q37.SJ/T11364-2014, Figure 5.1, figure 1, what font is "e" in the logo? What is the ratio?
Answer: in order to mark the beauty of the design, the "e" in the logo is made of fine art, and its proportion can be obtained from the standard grid of Figure 3 of SJ/T11364-2014 5.4.1. The relevant parties can also download the following page to download the electronic version of Figure 1 and Figure 2: http://www.cesi.cn/cesi/wrkz/biaozhunhuayanjiu/2016/0309/12419.html
Does the green label and orange standard specified by Q38.SJ/T11364-2014 need to choose these two colors? How to deal with when the product's color and logo are similar when executing?
Answer: SJ/T11364-2014 did not impose mandatory regulations on the color of the prohibited substances. According to SJ/T11364-2014 5.3, green and orange are the recommended colors for different signs. Producers or importers may choose other colors for marking according to the actual situation according to the standard size, but should meet the requirements of standard 6.1.1.
The minimum specification of Q39.SJ/T11364-2014 5.4.2 is 5mm * 5mm. If a sign of this size is not very conspicuous on the product, what should we do?
Answer: the specifications given by SJ/T11364-2014 are only the minimum requirements. When marking, the logo can be magnified according to the actual situation of the product specifications.
Q40.SJ/T11364-2014 the bottom of Table 1, 6.2.2, "enterprises can be here, according to the actual situation of the table" dozen "technical reasons for further explanation. What do you mean?
Answer: according to the regulation of SJ/T11364-2014, when the content of certain harmful substances in the product exceeds the requirement of GB/T26572-2011, it should be "X". It can be further explained in parentheses when the enterprises are temporarily unable to achieve replacement or reduction due to technical or economic reasons.
Q41.SJ/T11364-2014 requires the identification of the name and content of the harmful substances should be addressed to the components. How should the parts of the products be divided? Do parts without hazardous substances need to be listed in the list of hazardous substances as stated?
Answer: there is a wide variety of electrical and electronic products. It is impossible to list the parts of the products one by one. The method of specific parts division is stipulated by the enterprise itself, but it should contain all the components of the product, and it is suitable to declare the content of harmful substances in a single component or the same type of parts as a unit so as to fully reflect the harmful substances in the product.
Contains the situation.
Parts that do not contain harmful substances are not required to be listed in the table of hazardous substances in Table 1 of table SJ/T11364-2014 6.2.2.
Can Q42. use "other" to represent difficult parts? That is, use "others" as the part names in SJ/T11364-2014 Table 1.
Answer: the purpose of identifying the name and content of harmful substances according to the components is to enable the recycling enterprises to better understand the harmful substances in the products. If the use of "other" instead of "part name" obviously can not play such a role, it is not allowed.
Q43. in the product description, when using SJ/T11364-2014 Table 1 to indicate harmful substances containing information, can the scope of the form be enlarged to provide more information about harmful substances?
Answer: the form provided in SJ/T11364-2014 is the basic requirement. Enterprises can expand the identification scope of the form to inform consumers and recover the more harmful substance information of the enterprises. However, the information provided by the original form can not be deleted or the original information will be clarified. It is permitted to increase the number of harmful substances and to mark the environmental protection period of each component separately.
Q44.SJ/T11364-2014 mentioned in Clause 6.3, "... If the figure 2 is chosen for identification, the number in the logo should be replaced by the actual environmental protection term of the identified product, and the detailed explanation of the conditions for ensuring the use of the product in the period of environmental protection and the special identification of the matching parts should be given in the product description. Please specify the conditions of use and the special logo of the matching parts.
Answer: under different conditions of use, the term of environmental protection for the same product may be different. At the same time, in order to avoid possible harm to the environment and human health due to improper use or disposal, producers or importers need to specify the environmental conditions, usage methods and various kinds of tips or warning messages to prevent misuse, such as "away from high temperature" and "no removable disassembly".
The "special marks for accessory parts" means that producers or importers can use separate harmful substances to restrict the use of special accessories such as printing consumables and batteries.
(five) some specific identification cases
Q45. now many electrical and electronic products are not removable. Is it necessary to label the product and battery with only one label?
Answer: for the electrical and electronic products that are not removable for batteries, only one label can be used to limit the use of hazardous substances. However, the contents of hazardous substances should include all the units of the battery.
Q46. the nameplate of some mobile phones is in the battery compartment. Can the logo be tagged in the same position as the nameplate?
Answer: Yes. For battery dismountable mobile phone products, its battery compartment is the visible part of the consumer when the battery is disassembled. Therefore, it is possible to identify the mobile phone products in the battery compartment, and should satisfy the requirements that SJ/T11364-2014 6.1.1 should be clearly distinguishable and not easy to fade.
Q47. if the product description and packaging are integrated, can the logo and the content list be labeled on the package?
Answer: according to the general provisions of the fourth chapter of SJ/T11364-2014,
The carrier of product description can be a package. If the product satisfies the conditions specified in paragraph second of the 6.1.2, the logo can only be marked on the package.
Four. Limited requirements
Q48. "management measures" stipulates that all products that are included in the catalogue of catalogues should meet the requirement of limitation, can enterprises participate in the formulation of the catalogue of compliance management?
Answer: Yes. The Ministry of industry and information technology will, along with the relevant ministries and commissions, publish the catalogue of compliance management in batches according to the principles of openness and transparency according to the industrial development.
Q49. is there any exception (Exemption) for the application of certain hazardous substances in products?
Answer: the products that are included in the catalogue of compliance management will clarify the relevant application exceptions (Exemption) of hazardous substances, and publish them with the catalogue of compliance management.
Q50. will there be a transitional period in the catalogue of compliance management?
Answer: the "cataloging management directory" will set up a certain transitional period for implementation and be clear when issuing the catalogue of compliance management.
Q51. according to the provisions of article eighteenth of the "management measures", the products in the catalogue of compliance management shall be managed according to the qualification assessment system for hazardous substances in electrical and electronic products. What is the specific form and content of the conformity assessment system?
Answer: Electrical and electronic products hazardous substances restricted use conformity assessment system will be formulated in accordance with the provisions of the eighteenth and second sections of the management measures and will be issued in appropriate form.
The fourth part, other requirements of the administrative measures.
Q52. "management measures" stipulates that the design and production of electrical and electronic products should conform to the corresponding national or industrial standards. If we meet the requirements of technological conditions and adopt environmentally friendly programs, are there any rigid requirements for product design and production?
Answer: ninth and tenth of the "management measures" put forward that when designing and producing electrical and electronic products, relevant parties should meet relevant national standards and industry standards, adopt high resource utilization rate, easy recovery and treatment, environmental protection programs and technical restrictions, or eliminate harmful substances in products. These two articles are recommended at present. They are not mandatory requirements.
Is the packaging of Q53. electrical and electronic products belong to the jurisdiction of the administrative measures?
Answer: Article twelfth of the "management measures" stipulates that the packaging of electrical and electronic products should comply with the relevant standards, and adopt materials that are harmless, easy to degradation and easy to recycle. Therefore, the packaging of electrical and electronic products should belong to the scope of application of the "management measures", but the contents of this clause are recommended at this stage.
As the regulations on packaging have been deleted from the administrative measures, the identification of electrical and electronic products packaging can be seen in relevant regulations and national standards.
Does Q54. "management measures" involve the recovery, disposal and reuse of electrical and electronic products after abandonment?
Answer: one of the legislative purposes of the "management measures" is to facilitate the dismantling and disposal of electrical and electronic products after discarding, and to reduce environmental pollution caused by the disappearance of electrical and electronic products. However, the "management method" emphasizes "starting from the source" and requests for the design, production, sale and import of electrical and electronic products. The recycling, disposal and reuse of electrical and electronic products should comply with the relevant regulations of China's regulations on the recovery and disposal of waste electrical and electronic products (Decree No. 551st of the State Council) and other relevant laws and regulations.
The fifth part is about penalties.
Q55. for violation of the provisions of the "Regulations", the third chapter of the penalty provisions did not propose specific penalty terms, why?
A: because the relevant ministries and commissions have their own penalty provisions for different situations, the management measures should not be specified in this chapter in order to ensure consistency. Therefore, according to the provisions of article nineteenth of the administrative measures, units or individuals who violate the requirements of the administrative measures shall be handed over to / or by the business, customs, quality inspection, industry and commerce departments within the scope of their respective duties and shall be punished according to law.
Q56. 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?
Answer: 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.
(source: Jiayu detection network)
