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On September 29, 2024, China's State Administration for Market Regulation (SAMR) and Standardization Administration of China (SAC) jointly released a recommended national standard (GB/T 44652-2024), which establishes requirements of declaration for hazardous substance (HS)/ hazardous substance group (HSG) in electrical and electronic products (EEP). This standard shall take effect on September 29, 2024.
The declaration of HS/HSG in EEPs forms an integral part of material declaration as stipulated under GB/T 26668-2024 Material declaration of electronic and electrical products, and therefore, the formatting rules for HS/HSG declaration shall remain consistent with those established under this standard.
This standard stipulates voluntary material declaration requirement to facilitate the hazard communication throughout the supply chain. Manufacturers and suppliers may utilize this information to assess whether their products comply with hazardous substances restrictions. It will also enables the use of data for environmentally conscious design (eco-design, green design), and assist in handling electrical and electronic waste.
What HS/HSG needs to be declared?
Generally, any HS/HSG that meets the following criteria shall be declared:
Prohibited or restricted in EEP under China's existing laws/regulations/mandatory national standards (GB)
Required to be reported or labelled under China's existing laws/regulations/mandatory national standards
The current laws/regulations/GBs in this regard include but are not limited to Measures for the Administration of the Restricted Use of the Hazardous Substances Contained in Electrical and Electronic Products (China RoHS 2.0) and GB 24427-2021 Content limitation of mercury, cadmium and lead for zinc anode primary battery.
For exporting products, HS/HSG to be declared shall also be determined by the control measures of the specific exporting country. Here is a reference list of hazardous substance regulation in China's major trading partners:
EU REACH
EU RoHS Directive
Ecodesign for Sustainable Products Regulation (ESPR)
POPs Regulation
California Proposition 65
Washington CHCC
Japan CSCL
South Korea Quality Control and Safety Management of Industrial Products Act
Industries are also encouraged to report HS/HSG in EEPs with restrictive provisions in recommended national standards (e.g., GB/T 39498) , industry standards, or group standards.
Substances that are carcinogenic, mutagenic, reproductive toxic, persistent, bioaccumulative, toxic (PBT), or very persistent and very bioaccumulative (vPvB), or with valid evidence of negative impacts on the environment, may also be included in the optional declaration.
Reporting threshold level
The reporting threshold level is consistent with the concentration value established under relevant laws/regulations/standards. Suppliers are required to declare if the concentration of their substance exceeds the reporting threshold, even if it is out of the regulation scope or fits the criteria for exemption. In case there is no applicable reporting threshold for HS/HSG, 0.1% is considered the default value for reporting.
Declaration content
Each reported HS/HSG should be linked to a specific product, or spare parts/ materials ideally. The IUPAC name and CAS number shall be included for identification.
If the reported HS/HSG meet the reporting threshold for declaration as required under the hazardous substance list (HSL), it shall be marked with an affirmative"yes" and provided with a quantitative value (mass percentage). In case the value occurs in ranges, the value for the worst scenario shall be indicated (e.g., if the mass percentage is 1.1%~1.2%, the declared value shall be 1.2%)
In case the application of HS/HSG is out of regulation scope or exempted, the regulatory information for this provision including publishing authority, article number, content and corresponding concentration shall be reported and communicated throughout the supply chain.
For HS/HSG with concentration below the reporting threshold provided under HSL, or the product in question does not contain any HS/HSG listed under HSL, or other inapplicable situations, the HS/HSG shall be market with a negative "no".
Declaration under China RoHS
Although information disclosure of HS under China RoHS is simply built on industry consensus for hazard communication, China RoHS 2.0 do require mandatory marking and disclosure of the following hazardous substances in accordance with SJ/T 11364-2014 Marking for the Restriction of Hazardous Substances in Electrical and Electronic Products:
Lead
Mercury
Cadmium
Hexavalent chromium [Cr(VI)]
Polybrominated biphenyls(PBB)
Polybrominated diphenyl Ethers (PBDE)
