China RoHS for solar panels

What is China RoHS?

China RoHS compliance refers - in relation to the RoHS-Directive in the EU - to the legislation on the Restriction of Hazardous Substances in the People's Republic of China. It is officially know as Administrative Measure on the Control of Pollution Caused by Electronic Information Products. Similar to the EU RoHS, electronic products sold and produced in China are restricted in terms of the use of six hazardous substances in their manufacturing process. The substances, whose concentration may not exceed 0.1% in any homogeneous material, are:

Key differences between EU RoHS and China RoHS

A major key difference is the requirement of a label that indicate compliance or non-compliance with the China RoHS (see also: RoHS certification and labeling). The Electronic Information Products (EIP) label including an Environment Friendly Use Period (EFUP) value (in years) has to be placed on electronic products that contain these six substances. Other differences are (see also: chinaRoHS):

• In the current version of the China RoHS as published on 1 Mach 2007 there are no (!) exemptions. Every product imported to and manufactured in China, and as such also medical technologies as well as even thin film PV modules (exempted in the EU RoHS), have to comply
• China RoHS is currently only restricted to the same six hazardous substances as the EU RoHS, but will potentially add more hazardous substances in future versions of the legislations
• Labels, marks, and disclosure are required
• In the China RoHS compliance, products may contain DecaBDE 
• The packaging material for the products as well as transport packing need to carry recycling and re-usability indications
• The concept of "Put on the market" is different
• Different penalties apply
• The legal responsibilities are different
• Material testing down to the homogeneous materials in every single part you use to build your product may be required

China RoHS - phase 2

The second phase of the China RoHS complaince, abbreviated as China RoHS - phase 2, is an amendment of the current China RoHS framework proposed by the Chinese Ministry of Industry and Information Technology (MIIT). It was first published in July 2010 for expert and public comments. Whereas China RoHS - phase 1 was primarily only requiring self-labeling with the Electronic Information Products (EIP) label, phase 2 targets and bans products with RoHS substances from China and stipulates conformity enforcement.

China Compulsory Certificate (CCC)

Via the China Compulsory Certificate (CCC), it also expands the scope of the EIP by expanding the scope of electric and electronic products. Related products are listed in the Catalog for Priority Pollution Control (CPPC) after the various involved and related parties, including businesses, experts, associations and government bodies, agree on such inclusion. However, if there do not exist any economically viable and technically mature substitution materials for such RoHS substances, the product is not listed in the CPPC. The CPPC will be continuously evolving to keep in pace with technical and economic developments.   (Source: Intel)