Environmental Directives - China
The People’s Republic of China, through their Ministry of Information Industry (MII), has begun issuing documentation and legislation for the “Management Methods for the Control of Pollution from Electrical and Electronic Products,” more commonly called China RoHS. Vicor Corporation is committed to fully comply with all Environmental Legislation adopted in the locations where we do business.
China RoHS is structured as a 2 Phase Program, with Phase 1 having become effective on March 1, 2007. Vicor is currently on track to comply with all applicable China RoHS directive requirements, specified for Phase 1.
China RoHS Program Requirements
China RoHS covers the same six substances as the EU RoHS Directive – Lead (Pb), Mercury (Hg), Cadmium (Cd), Hexavalent Chromium (Cr6+), Polybrominated Biphenyl (PBB) and Polybrominated Diphenyl Ether (PBDE). The Maximum Concentration Values of these substances also follows EU RoHS, and is detailed in SJ/T 11363-2006 – China RoHS Concentration Levels. The China RoHS Scope Document lists the types of Electrical and Electronic Equipment covered by China RoHS as of March 1, 2007. Per China RoHS, all Vicor Products are within the scope of China RoHS and are classified as EIP-A. Vicor is currently on track to comply with all applicable China RoHS requirements, as specified in the following paragraphs.
Date of Manufacture
China RoHS requires that all Electrical and Electronic Products in scope are marked with a Date of Manufacture. This is the starting point for the Environmental Friendly Use Period, described below. Currently all Vicor Product, Brick Division, VI Chip Division and Westcor Product, is so marked and these markings comply with China RoHS.
Environmental Friendly Use Period (EFUP)
Per SJ/T 11364-2006 – Product Marking, the EFUP is defined as the time in years in which hazardous/toxic substances within Electrical and Electronic Products will not, under normal operating conditions, leak out of the Product, or the Product will not change in such a way as to cause severe environmental pollution, injury to health, or great damage to property. In accordance with the Technical Life Method of the China RoHS EFUP Guidance Draft Document, Vicor has determined the Environmental Friendly Use Period of all Vicor Products shall be Twenty-Five (25) years.
Electronic End Products sold in China after March 1, 2007 must be properly marked in accordance with SJ/T 11364-2006. China RoHS Compliant Product must be marked with the following marking (Logo 1):
Product judged to be Non-Compliant will have a similar marking, except the “e” will be replaced with Vicor EFUP (25) and the color will be orange (Logo 2). Coloration of the labels is not mandatory.
China RoHS, as formulated for Phase 1, does not currently recognize any Product Exemptions. All Vicor Product which is EU RoHS Compliant, is Compliant by authorized Exemption. This means that all Vicor Product will be China RoHS Non-Compliant, and will be identified by Logo 2. This marking shall be affixed by Vicor’s Hong Kong Distributors, as required by Customers. Per the China RoHS Directive, Product shipped to Hong Kong does not come under the purview of China RoHS. Vicor currently has labels to mark Logo 2, if required, and has shipped these labels to our Hong Kong Distributors.
Material Disclosure Tables
All China RoHS Non-Compliant Product must be provided with a Material Disclosure Table. This Table lists the six hazardous substances of interest to China RoHS, and uses x and o to indicate which substances are present above the Maximum Concentration Value (MCV) in an Electrical or Electronic Product, and which are not.Material Disclosure Tables are required to be in Mandarin. These Tables shall be used by our Hong Kong Distributors, and by our other Customers World Wide, to properly mark end items they ship into China containing Vicor Products.
The Tables are prepared by Vicor and Westcor Family groups, and appear at the following links:
Material Disclosure Tables English Versions
Material Disclosure Tables Mandarin Versions
Aside from Product Markings and documentation, all packaging material must be marked with the applicable Packing Recycling Marks in accordance with China National Standard GB 18455-2001. This document follows international marking requirements, and Vicor fully complies with this standard.
China RoHS Future Developments
During Phase 1 of China RoHS, no material prohibitions will become effective. All product will be accepted into China, providing it is properly marked and accompanied by Material disclosure Tables. Vicor will continue to ship EU RoHS Compliant and Non-Compliant Product to China, as required by Vicor Customers.
Material Prohibitions will become effective with the commencement of Phase 2. Phase 2 will become effective as specified by the Government of China Ministry of Information Industry. During Phase 2 all shipments to China will consist of EU RoHS Compliant Material.
All Packaging will continue to be marked per GB 18455-2001, and all Product will continue to be identified by Date of Manufacture and Logo 2 of SJ/T 11364-2006.
China is setting up laboratories throughout China where actual testing of Products for RoHS substances will take place. Testing shall be in accordance with SJ/T 11365-2006 – Testing. Once MII starts to publish lists of specific Products which must meet the RoHS MCV requirements, known as the Catalogue for Pollution Control in Key Electronic Information Products, these Products will have to be tested and certified Compliant by Chinese labs. The first Catalogue is not expected before October 2007; however, it is believed the first Catalogue may include, at least some, of the Exemptions allowed by EU RoHS.
Vicor will continue to review developments in China RoHS, in order to be able to respond to developments in a timely manner for our customers.
Vicor China RoHS Quality Systems Procedure