Dear Peter,
 
Thank you very much for your questions.  Following is my personal comments to
your questions
 
1) The limit for toxic and hazardous substances will be included in the test
standards to be formulated.
To be conservative, Chinese rules would like to have "other..." added to cover
any unexpected issues if any.  An advantage for this addition will eliminate
revision for the law.  For example, in the future if any toxic substance to be
added, an appendix referring to this "other..." rule works. 
 
2) The answers to this question are included in the China RoHS Q&A which I
sent out this morning.  The answers can be found from Item 3 and 4 of the
defferences between the Administrative Measure and the EU RoHS Directive. 
 
3) Please find the answers from the China RoHS Q&A regarding "two steps' walk".
 
4) Under currect China compulsory certification rules, in country testing is a
requirement.  This means during application process, you are required to send
product samples to a designated lab to obtain a test report. 
 
Ms. Bo and Ms. Lu, please correct me if this is not true any more.
 
5) I have no answers for these questions at this time.  
 
By the way, thank you for pointing out my web site error.  I had it corrected
this morning.
 
Best regards,
Grace Lin
Grace Compliance Specialist
New Jersey, USA
grace...@graspllc.com
www.graspllc.com


 
On 3/9/06, Peter Weichel < p...@pbi-dansensor.com> wrote: 

Hi experts,

Having read the translated version of China RoHS regulations courtesy
Grace Lin, i seem to spot several 
questions which needs answering.

1)
I see in that doc. no specification of limits for the materials, are
they same as in EU ?
And as a show stopper they add "Other toxic or hazard substances set
bys state" i.e. no end to this ?
Where are thees other substances listed ?

2)
In the EU RoHS there are currently exempted products which will have a
transistion period of at least until EU
includes product catergory 8 & 9 into RoHS (most likely not before 
2009/2010).
However the China RoHS does not use the term exemptions but lists
incuded products, and the list is quite wide
ranging also including some EU exempted products.
Now does that mean that we have to comply in China with products that 
are OK in EU (for now) ?

3)
The China RoHS seems to be valid from march 1st 2007.
Is that realy true ?

4)
Does the requirement for documentation of hazardous contents require us
to make analysis of exact contents ? 
I.e. do we have to send a product for chemical analysis ?

5)
As i read the doc. we also have to add CCC mark if covered by China
RoHS is that true ?
If so products not previsuosly under CCC regulation now have to add CCC 
anyway!
Does this mean that such a product will have to comply to other CCC
aspects as well or only RoHS aspects ?

Thats it for now, i hope to have some of the above points commented
;o)

Have a nice day all, 

Best regards
PBI-Dansensor

Peter Weichel
Test and Approval Engineer


PBI-Dansensor A/S
Roennedevej 18
DK-4100 Ringsted
Tel.:  (+45) 57 66 00 88

Fax:  (+45) 57 66 00 99

e-mail:   p...@pbi-dansensor.com

Website:  www.pbi-dansensorcom

PBI-Dansensor

Peter Weichel
Test and Approval Engineer

PBI-Dansensor A/S
Roennedevej 18 
DK-4100 Ringsted
Tel.: (+45) 57 66 00 88
Fax: (+45) 57 66 00 99
e-mail: p...@pbi-dansensor.com
Website: www.pbi-dansensor.com 




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