Background: The first phase of the China RoHS Regulations was incorporated into Chinese legislation on 01-March 2007. Unlike the EU RoHS directive (2002/95/EC), the first phase of the China RoHS Regulations does not require the removal of the six (6) restricted, hazardous substances (i.e. lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers (PBDEs)) from the Electronic Information Products (EIPs) at present. However it does require: labeling of the EIPs; including a Table of Toxic Substances (TTS) in the product documentation; labeling of the packaging.
1. Labeling of the EIPs: EIPs should be labeled in accordance with the "Electronics Industry Standard of the People's Republic of China" specification SJ/T11364-2006. The label, which is affixed by the manufacturer, indicates whether the EIP has or does not have hazardous substances present at concentrations greater that the Maximum Concentration Values (MCVs) allowed. If the EIP has NO hazardous substances present at concentrations greater than the MCVs allowed, then the EIPs should carry a label, with an "E" in a circle, with arrows on it (reference figure 1 in the China RoHS Product and Packaging labels document below). If the EIP has hazardous substances present at concentrations greater than the MCVs allowed, then the EIPs should carry a label, with a number in the middle of a circle, with arrows on it. This number is called the Environmental Protection Use Period (EPUP). The EPUP details the number in years that the EIP will last for before hazardous substances could leak out into the environment. In the case of Network Infrastructure Equipment, the EPUP used by Avaya is "50" years (reference figure 2 in the China RoHS Product and Packaging labels document below). 2. Including a Table of Toxic Substances (TTS) in the product documentation: If the EIP has NO hazardous substances present at concentrations greater than the MCVs allowed, then it is not necessary to include a TTS in the product documentation. If the EIP has hazardous substances present at concentrations greater than the MCVs allowed, then it is necessary to include a TTS in the product documentation. The TTS details which subassembly contains a restricted hazardous substance (reference the TTS document below). 3. Labeling of the packaging: Packaging should be labeled in accordance with the "Packaging Recycle Marks" specification GB-18455-2001. For simplicity, the following packaging needs / does not need to be labeled: Label: Do not label: Examples of packaging labels can be seen in the China RoHS Product and Packaging labels document - reference figures 3 - 6. The first phase of the China RoHS Regulations applies to products that ship into the People's Republic of China or products that ship within the People's Republic of China. It does not apply to products that are exported from the People's Republic of China. The second phase of the China RoHS Regulations requires that a company demonstrates compliance (i.e. do not have hazardous substances present at concentrations greater than the MCVs allowed) in the event that the EIP is called up in the China "Catalogue". The Chinese Ministry of Information Industry (MII) expects to release the first issue of the "Catalogue" by the end of 2007, although release could be delayed until mid / late 2008. To demonstrate compliance it will be necessary to submit the EIPs to test laboratories in China, which will certify the EIPs before regulators will allow the EIPs onto the Chinese market. Avaya’s Commitment:
Avaya is fully compliant with the first phase of the China RoHS Regulations, which were incorporated into Chinese legislation on 01-March-2007.
What Avaya Customers Can Expect
Business Partners and Customers can expect Avaya designed and Avaya branded OEM (original equipment manufacturer) products manufactured and purchased from Avaya directly or from an authorized Avaya Business Partner on or after 01-March-2007 to be fully compliant with the first phase of the China RoHS Regulations. What Avaya Employees Can Expect There are no changes to the sales and ordering processes. A small number of OEM products that are not compliant with the new regulations will not be available for sale in China. These products will be indicated as restricted as one goes through the ordering process. Contacts
For questions regarding the China Directive you can contact the Environmental Hotline on agtc@avaya.com | 
China RoHS product and packaging labels
