On January 14, a further explanation notice is issued by the Standard Working Group for Pollution Prevention and Control of Electrical and Electronic Products (hereinafter referred to as “the WG”), who is the drafter of the China RoHS labelling standard SJ/T 11364 Labeling requirements for restricted use of hazardous substances in electrical and electronic products. The purpose is to clarify and emphasize the implementation of China RoHS 2.0 with the frequent standard version change and avoid confusions on implementation.

China RoHS 2.0 is based on the national regulation Administrative Measures for the Restriction of Hazardous Substances in Electrical and Electronic Products (issued in 2016). At present, the supportive pillars (besides corresponding standards on specific testing) for its implementation are mainly two standards: 

-   SJ/T 11364 (labeling requirements): currently effective version is the 2006 version, and it will be replaced by SJ/T 11364-2024 on April 1, 2025.

-   GB/T 26572-2011 Requirements of concentration limits for certain restricted substances in electrical and electronic products: it is still effective, and its amendment list No. 1 will com into effect on January 1, 2026, in which the restricted substances will expand to 10 items (the same as EU RoHS).

Back to the explanation notice of the WG, the key point of the document is to alert the stakeholders on the following points:

-   Be aware and ensure compliance with the revised SJ/T 11364-2024:  new terms added; delete the labelling method for production date; add 4 substances to be aligned with GB/T 26572 no.1 amendment list; add labeling method and requirement for QR code; add requirements on using webpage as the labeling carrier etc.

-   Be prepared for the compliance of newly added 4 substances in GB/T 26572 no.1 amendment list: DEHP, BBP, DBP, DIBP

-   Ensure coordinated implementation of the two standards during the transition period.

For foreign stakeholders, the best compliance practice is to ensure relevant product/component within China RoHS 2.0 scope (if any) are conformed with currently effective standards and regulations, while keep up with the latest updates of the system and standard change in case of any impact.

If you have any questions or need further assistance, please reach us at: info@bestao-consulting.com.

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