Notes on Regulations Governing the Export of Electronic and Electrical Equipment

Notes on Regulations Governing the Export of Electronic and Electrical Equipment

Background

Electronic and electrical equipment (EEE) must conform to the regulations on public security, sanitation, environment and personal safety enacted by the Federal Government, local governments and other authorities before being placed on the US market. Relevant regulators may include but are not limited to:

The US Occupational Safety and Health Administration (OSHA), which was founded in 1970 to prevent and reduce the diseases, injuries and deaths caused by work by releasing and promoting safety and health standards for workplaces
The Federal Communications Commission (FCC), an independent US government agency established in 1934 to ensure the safety of radio and wire communication products. Electronic products must conform to electromagnetic compatibility and other applicable requirements before being placed on the US market.
The US Department of Energy (DOE), which aims to conserve energy, reduce emissions and save power for users, so as to lower energy demands and greenhouse effects.

Laws and regulations which need to be complied with may include but are not limited to:

California Proposition 65 (CP 65), enacted by California to ensure the safety of drinking water, requires businesses to execute the obligation to give warnings for listed chemicals.
The TPCH Legislation on packaging materials in the US – Restrictions on the content of hazardous substances in packaging materials as required in relevant acts.
The Public Law 104-142 (HR2024) on batteries in the US establishes restrictions on the use of hazardous substances in batteries.

Electronic and electrical equipment must obtain a CE marking before being placed on the EU market. It is a mandatory product safety marking required by the EU, indicating a product has been assessed and deemed to meet public security, health, environmental and personal safety requirements. Any product that has met the general requirements of the EU and gone through appropriate assessment procedures can be added with a CE marking. Directives that different products need to comply with may include but are not limited to:

The general product safety directive (GPSD) 2001/95/EC, which provides a list of safety standards for various products to ensure the safety of the products available on the market
The directive 2006/66/EC on batteries and accumulators and waste batteries and accumulators, which controls heavy metal content in products
The directive 2013/56/EU, an amendment to the directive 2006/66/EC on batteries and accumulators and waste batteries and accumulators
The energy-related products directive (ErP) 2009/125/EC, which lays down the application requirements for energy-consuming products
The low voltage directive (LVD) 2014/35/EU that covers health and safety risks on electrical equipment operating with an input or output voltage between 50 and 1,000V for alternating current and 75 and 1,500V for direct current
The electromagnetic compatibility (EMC) directive 2014/30/EU, which lays down the requirements on products' electromagnetic radiation and abilities to protect against disturbance
The radio equipment directive (RED) 2014/53/EU with unified regulations on radio equipment
The packaging and packaging waste directive 94/62/EC on the restriction of hazardous substances in packages in the EU
The directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment
The waste electrical and electronic equipment (WEEE) directive 2012/19/EU, which includes the requirements on recycling marks and recycling rates
The regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), a chemical supervision system established by the EU
The regulation (EU) 2019/1021 on the restriction of persistent organic pollutants (POPs) in all the substances, mixtures and articles in the EU

Scope

According to the US Environmental Protection Agency (EPA), EEE is defined as equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields. As a general rule of thumb, if it has a battery or needs a power supply to work properly, it is EEE and there are structures in place to reuse/recycle this equipment when it reaches end of life.

According to the Environment Agency of the UK, EEE is dependent on electric currents or electromagnetic fields to work properly. It is used for generating, transferring and measuring these currents and fields and designed for use with a voltage rating 1,000 volts or less for alternating current and 1,500 volts or less for direct current. EEE may also include wind-up, battery-powered and solar-powered products.

Regulations

The US

Plugs and sockets

Plugs and sockets are subject to ANSI's standards, such as UL 498.

A "warning" label shall be affixed to a product that contains substances listed in the US CP 65.

US TPCH: the total concentration of lead, cadmium, mercury, hexavalent chromium or their compounds in packaging or a packaging component shall not exceed 100 ppm.

Mobile power supply

Safety certificates: comply with standards UL 2056 or UL 62368-1 + UL2054/UL2056

The authorization procedure for FCC Part 15B is SDoC (without wireless function); while the authorization procedure for FCC Part 15C or FCC Part 18 and FCC Part 2.1091 is ID (with wireless function).

The requirements of the US DOE's 10 CFR 430.32(z) - Energy Conservation Program: Energy Conservation Standard for Battery Chargers (if products contain rechargeable batteries)

A "warning" label shall be affixed to a product that contains substances listed in the US CP 65.

US TPCH: the total concentration of lead, cadmium, mercury, hexavalent chromium or their compounds in packaging or a packaging component shall not exceed 100 ppm.

The US public law 104-142 (HR2024) (the Battery Act): The mercury amount in a battery shall be lower than the restriction.

Batteries in mobile phones and laptops

Safety certificates: comply with UL 2054 or UL 62133-2

The authorization procedure for FCC Part 15B is SDoC (without wireless function)

US TPCH: The total concentration of lead, cadmium, mercury, hexavalent chromium or their compounds in packaging or a packaging component shall not exceed 100 ppm.

The US public law 104-142 (HR2024) (the Battery Act): The mercury amount in a battery shall be lower than the restriction.

Chargers of mobile phones and laptops

Safety certificates (recognized by NRTL): comply with UL 62368-1 or UL 60950-1

The authorization procedure for FCC Part 15B is SDoC (without wireless function)

The requirements of the US DOE's 10 CFR 430.32(z) - Energy Conservation Program: Energy Conservation Standard for External Power Supplies

A "warning" label shall be affixed to a product that contains substances listed in the US CP 65.

US TPCH: The total concentration of lead, cadmium, mercury, hexavalent chromium or their compounds in packaging or a packaging component shall not exceed 100 ppm.

The EU

Plugs and sockets

Plugs and sockets are subject to European countries' socket standards, which generally include IEC 60884-1 + the plug and socket standard deviations of local countries (such as Germany's VDE 0620, France's NF C 61-314 and the UK's BS 1363)

According to the EU Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electronic and electrical equipment, all homogeneous materials in electronic and electrical products shall comply with the restrictions on controlled substances.

According to the regulation (EC) No 1907/2006 on the registration, evaluation, authorization and restriction of chemicals, if the contents of SVHC exceed 0.1%, obligations for notification and information transfer shall be performed. Contents of the substances listed in Annex XVII shall not exceed limitations.

As per the regulation (EU) No 2019/1021 on persistent organic pollutants, the contents of some substances in products shall not exceed the limitations listed in Annex XVII.

According to the directive 2012/19/EU on the control of waste electrical and electronic equipment, products shall meet the requirements for the recycling labels for waste and also reach the standards for collection and reuse rates if possible.

As per the directive 94/62/EC on packaging, the sum of concentration levels of Pb, Cd, Hg and Cr VI present in packaging or packaging components shall not exceed 100mg/kg.

Mobile power supply

The general product safety directive (GPSD) 2001/95/EC is implemented in accordance with standard EN 62368-1 or EN 60950-1.

The electromagnetic compatibility (EMC) directive 2014/30/EU is implemented in accordance with standards EN 55032, EN 61000-3-2, EN 61000-3-3 and EN 55035.

The radio equipment directive (RED) 2014/53/EU is implemented in accordance with standards ETSI EN 303 417, ETSI EN 301489-3 and EN 62311.

As per the regulation (EU) 2019/1021 on persistent organic pollutants, the contents of some substances in products shall not exceed the limitations listed in Annex XVII.

According to the directive 2006/66/EC on batteries, batteries shall comply with the restriction on certain substances and symbol requirements.

As per the directive 94/62/EC on packaging, the sum of concentration levels of Pb, Cd, Hg and Cr VI present in packaging or packaging components shall not exceed 100mg/kg.

Batteries in mobile phones and laptops

The battery directive 2013/56/EU and EN 62133-2

The electromagnetic compatibility (EMC) directive 2014/30/EU is implemented in accordance with standards EN 55032 and EN 55035.

As per the regulation (EU) 2019/1021 on persistent organic pollutants, the contents of some substances in products shall not exceed the limitations listed in Annex XVII.

According to the directive 2006/66/EC on batteries, batteries shall comply with the restriction on certain substances and symbol requirements.

As per the directive 94/62/EC on packaging, the sum of concentration levels of Pb, Cd, Hg and Cr VI present in packaging or packaging components shall not exceed 100mg/kg.

Chargers of mobile phones and laptops

The low voltage directive (LVD) 2014/35/EU is implemented in accordance with standard EN 62368-1 or EN 60950-1.

The ERP directive 2009/125/EC is implemented according to EU 2019/1782.

The electromagnetic compatibility (EMC) directive 2014/30/EU is implemented in accordance with standards EN 55032, EN 61000-3-2, EN 61000-3-3 and EN 55035.

As per the regulation (EU) 2019/1021 on persistent organic pollutants, the contents of some substances in products shall not exceed the limitations listed in Annex XVII.

As per the directive 94/62/EC on packaging, the sum of concentration levels of Pb, Cd, Hg and Cr VI present in packaging or packaging components shall not exceed 100mg/kg.

Legal Basis

For more information about the US's EEE regulations, visit the following website:

Plugs and sockets

Mobile power supply

Batteries in mobile phones and laptops

Chargers of mobile phones and laptops

For more information about the EU's EEE regulations, please visit the following websites:

Mobile power supply

Batteries in mobile phones and laptops

Chargers of mobile phones and laptops

Note: The above information does not constitute any legal advice and shall not be deemed or represent the legal opinion or conclusion of the regulatory body. Further, we do not undertake or warrant that the information represents the latest laws and regulations. For specific information, please consult the competent authority, law firms, or third-party certification/testing/consulting companies in the target country or region.

AliExpress
August 31, 2020