It’s ironic that China’s environmental and recycling laws appear to be the most stringent to date. For example, China’s Restriction on Hazardous Substances (RoHS) law bans more materials than similar laws and leaves the door open for substances to be added to the list. Even more ironically, the limitations placed on lead and other materials apply to products imported to China– but not to exports out of the country.
Although the legislation is drafted to target e-waste, restrictions also apply to automotive electronics, medical devices and packaging materials. The official implementation date for “China RoHS” was March 1, 2007, but the actual restrictions are being phased in during an unspecified period of time. One of the difficulties U.S. companies face is interpreting the law, which was released in Chinese. Several translations are available.
Manufacturers of all sizes will be affected by the requirement that materials used in an imported product be fully disclosed. Many companies are already asking their suppliers for their products’ “recipes” or testing products themselves. Testing and labeling these parts is beginning to add costs throughout the supply chain. Additionally, some suppliers balk at the idea of sharing their materials data because it’s considered proprietary information.
Whether or not your business deals directly with China:
- Stay apprised of where your products are going. Even if the sales transaction takes place in the U.S., final assembly could be done in China.
- Know your products’ “recipes.” Someone is going to ask you for that if they haven’t already.
- If you use a banned substance in your product, see if there are alternatives available.
- Familiarize yourself with foreign environmental laws. The “green” movement is not going away. If you aren’t directly affected now, you will be.
- Run through some “what-if” scenarios: if you are forced to change your product, what will it cost? How can you head off some of those costs?