On December 30, 2022, one of the significant standard in the China RoHS governance system, the labelling standard SJ/T 11364 Labeling requirements for restricted use of hazardous substances in electrical and electronic products to call for public comments (hereinafter referred to as “SJ/T 11364”) has its draft issued draft to call for comment by China Electronics Standardization Institute (CESI). The call for comment period will end on January 16, 2023.
The first version of SJ/T 11364 is issued in 2006 and its first revision took place in 2014. In 2017, Amendment No. 1 is published as a supplementary document. This draft of SJ/T 11364 is developed under the request of Ministry of Industry and Information Technology in 2019 under project number 2019-0969T-SJ.
The main changes of the SJ/T 11364 comparing with previous version include:
- Add four hazardous substances: Bis(2-ethylhexyl) phthalate (DEHP), Butyl benzyl phthalate (BBP), Dibutyl phthalate (DBP) and Diisobutyl phthalate (DIBP)
- Delete certain definition in the previous version under various reasons. For instance, the definition “EEP” is deleted as it is already clearly defined in the Measures for the Administration of the Restricted Use of the Hazardous Substances Contained in Electrical and Electronic Products.
-Delete the requirement stating, “Manufacturers or importers should provide checking service on production date to consumers or administrations when necessary”.
-Delete overlapping contents in the previous SJ/T 11364 with the standard GB/T 26572 Requirements of concentration limits for certain restricted substances in electrical and electronic products.
-Add website as an allowed channel for regular EEP for RoHS information disclosure, but it requires the product should have a clear link or corresponding connection with the information disclosed in website.
-Manufacturer or importer of the EEP is allowed to combine the information into a QR code and put the code on appropriate carrier in accordance with the requirements of other articles in the new version of SJ/T 11364.
China is putting stricter supervision on RoHS, certain actions may need to be taken by EEP manufacturers to update the RoHS markings. Manufacturers with factories within China that may import such EEPs or relevant components are advised to have compliance team confirm with suppliers to keep up with the procedure.
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