From the 1st March 2007 all ‘Electronic Information Products’ shipped to end customers in China must comply with the ‘China RoHS’ legislation first promulgated on February 28th 2006. China RoHS is similar to its European counterpart in that it prohibits the use of heavy metals (Lead, Mercury, Cadmium, Hexavalent Chromium) and two brominated compounds (PBB and PBDE). China RoHS differs in having two phases, having no exemptions, requiring marking of product to show compliance, and requiring testing of product to show conformity in implementing the second phase. The China RoHS legislation is captured in ‘Management Methods for the Control of Pollution by Electronic Information Products (Ministry of Information Industry, Order No. 39), and the set of standards developed to support this namely SJ/T 11363-2006 on Maximum Concentration Values, SJ/T 11364-2006 on Labelling and SJ/T 11365-2006 on test methods.
The first phase requires a label indicating the level of compliance on product shipped to end customers. If not compliant then the label must indicate the period for which the above materials are safely contained within the product, in a normal operating environment. This time period is referred to as the Environmental Protection Use Period (EPUP), the Environmentally Friendly Use Period (EFUP) or the Environmental Safety Period. For non-compliant product it is also necessary to make available, and to include with the product if shipped to an end customer, a materials declaration table in simplified Chinese showing the location of the controlled substances in the product.
The second phase will start when the Chinese authorities publish a catalogue of the products that must comply if they are to be sold in China. The first catalogue is expected in 2007. The implementation of this second phase has not been made clear from the Chinese MII at present.
Oclaro is fully committed to environment protection and sustainable development and has set in place a comprehensive program, in conjunction with our customers and suppliers, for removing polluting and hazardous substances from all of its products where this is technically feasible.
The Oclaro policies, procedures, and documentary evidence for RoHS compliance is audited by external independent auditors as part of our ISO9001 and 14001 assurances. This was specifically audited in April 2006 and was fully approved by the independent auditors.
Oclaro is implementing changes in accord with Phase 1 of the legislation. During the first quarter of 2007 Oclaro will add the appropriate label showing the level of compliance and the ‘EPUP’ to all products, or to the primary packaging where this is appropriate. The materials declaration table required by the legislation will also be prepared for each product family and attached to the current RoHS Materials Declaration.
Oclaro recognizes two levels of conformance for its products:
The Materials Declaration Statement can be provided to customers on request.