Hi Ian,
 
Here is my interpretation based on a phone conversation with a Chinese
engineer from one of the CCC certification centers.
 
China will formulate a RoHS Catalogue (list of regulated products).  This
Catalogue expects to list products item by item (such as using HS codes).  A
good example is the AQSIQ/CNCA Notice No. 60 (promulgated July 1, 2002) which
lists CCC regulated products by HS codes. 
 
Take electric toasters as an example.  Electric toasters (HS code: 85167200)
are CCC regulated products.  This doesn't mean all electric toasters are
required to be CCC certified.  An electric toaster with voltage less than 36V
(applies to both AC and DC), OR its capacity is over 10L, this toaster is
"exempted". 
 
There is a high possibility that those current CCC regulated products will
have a higher possibility to be included in the RoHS Catalogue.
 
You may encounter a situation that your product is between "yes" (need
certification) and "no".  Which way to go?  The answer depends on the
importance between time and money.  If time is important (you have to have
products delivered before... and you cannot afford to have produsts sit in the
Customs), go ahead to have the product certified.  If your products are stuck
at the Customs, you have to provide a "certificate of exemption" or "exemption
certificate" (same document, different translation).  Someone must submit this
application in person.  It is not too difficult to obtain it if you have
someone near the entry port and/or the CNCA in Beijing.  If not, you may not
be able to sleep well until the product is released from the Customs (you have
to find someone to do this for you and you have to rush it). 
 
I hope this helps.
 
Best regards,
Grace

 
On 3/7/06, Gordon,Ian < ian.gor...@bocedwards.com> wrote: 

Grace
Do you know if the Chinese RoHS law applies to ALL products indicated in
Article 3 section 1 or is does this law only apply to products covered by 
the CCC certification process?

Thanks

Ian Gordon

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