Frequently Asked Questions about China's "General Rules for the Environmentally Friendly Use Period of Electronic Information Products"
To help manufacturers of electronic information products determine the environmentally friendly service life of their products, the Ministry of Industry and Information Technology recently issued the "General Rules for the Environmentally Friendly Service Life of Electronic Information Products." Experts have provided answers to frequently asked questions regarding these rules as follows:
1. Question :Does the "General Rules for Environmental Protection Service Life" serve as the basis for determining the accuracy of the environmental protection service life indicated on a company's label?
A: The purpose of formulating the "General Rules for Environmentally Friendly Use Periods" is to help enterprises determine the environmentally friendly use period of their products and to further improve the pollution control labeling of electronic information products. The "General Rules for Environmentally Friendly Use Periods" is an industry-guided technical document and is not intended to determine the accuracy of the environmentally friendly use period labeled by an enterprise. However, if the environmentally friendly use period determined and labeled on the corresponding product according to the "General Rules for Environmentally Friendly Use Periods" or other methods exceeds the actual environmentally friendly use period of the product, the producer or importer will bear corresponding legal responsibility.
2. Question: Does the "General Rules for Environmentally Friendly Use Period" apply to products that do not contain toxic or harmful substances or elements?
A: The "General Rules for Environmentally Friendly Use Period" apply to electronic information products whose content of toxic and hazardous substances or elements exceeds the limits specified in SJ/T 11363-2006, which falls within the scope of the "Administrative Measures for Pollution Control of Electronic Information Products". Products that do not contain toxic and hazardous substances or elements do not require a defined environmentally friendly use period, therefore the "General Rules for Environmentally Friendly Use Period" do not apply to them.
3. Question: Must the conditions for the environmental protection usage period be determined? Are the conditions for the environmental protection usage period unique?
A: The definition of environmentally friendly usage period sets a prerequisite for its determination, namely, "under normal use conditions." First, the environmentally friendly usage period of the same product may differ under different use conditions. Therefore, to determine the environmentally friendly usage period, the product's use conditions must first be determined. Second, depending on different sales strategies and target customers, the "normal use conditions" of a product may also vary. Therefore, the "normal use conditions" for environmentally friendly usage period are not uniform and should be determined by the manufacturer or importer of the electronic information product.
4 Question: Why is the unit for environmentally friendly usage period in years? Is it scientifically inaccurate to classify products with an environmentally friendly usage period of more than 10 years into 5-year increments?
A: Unlike short-life products (such as unpreserved food), electronic information products typically have a longer lifespan. The expiration dates for the environmentally friendly usage period can vary significantly between different products of the same type, making it impossible to pinpoint the exact date to "day" or "month." Therefore, it must be expressed in "years." Furthermore, based on the distribution characteristics of the lifespan of electronic information products, and to avoid unfair competition between products due to varying environmentally friendly usage periods (such as similar products slightly inflating their environmentally friendly usage periods), the "General Rules for Environmentally Friendly Usage Periods" provides the range of values for environmentally friendly usage periods as described in Clause 4.1 of the standard.
5. Question: Is the priority order of the method for determining the environmental protection service life based on the order of the standard clauses?
A: To ensure that the determined environmentally friendly service life is closer to the actual value, when electronic information product manufacturers or importers have sufficient practical experience or scientific testing techniques, the practical method should be chosen first, followed by the experimental method, and finally the conceptual environmentally friendly service life method. However, there is no specific order in which conceptual environmentally friendly service life methods such as the safe service life method, technical life method, analogy method, and table lookup method should be selected.
6. Question: Are there any specialized testing techniques to determine the environmentally friendly service life of a product?
A: Environmentally friendly service life is a relatively new concept worldwide. Currently, there is no universal testing technology specifically for the environmentally friendly service life of electronic information products. However, some existing product aging test methods can provide a basis for determining the environmentally friendly service life.
7. Question: Are the concepts of safe service life and environmentally friendly service life the same? Why can the environmentally friendly service life be determined by the safe service life?
A: The safe usage period and the environmentally friendly usage period are two completely different concepts. Their respective values may be greater than, less than, or equal to the environmentally friendly usage period. In many cases, safety issues are often accompanied by the leakage of toxic or hazardous substances or elements. When both the safe usage period and the environmentally friendly usage period expire simultaneously, their values will be the same.
8. Question: What types of products can use the technology life method? Why is a difference added to the technology life method?
A: If the manufacturer determines the technical life of an electronic information product during the design phase, and environmental factors such as the leakage or mutation of toxic or hazardous substances are considered during the design process, then the product's environmentally friendly service life can be calculated using its technical life. In the actual circulation of electronic information products, the market life (such as transportation and storage before sale) does not diminish the product's actual environmentally friendly service life. However, the refurbishment life (such as repair and replacement of parts after damage) can increase the product's environmentally friendly service life. Therefore, the technical life method must consider the difference between the market life and the refurbishment life.
9. Question: Is it reliable to determine the environmentally friendly service life of a product using the analogy method?
A: The leakage or mutation of toxic or hazardous substances or elements in electronic information products is closely related to the product's manufacturing technology and raw material usage. Generally, products using the same or similar manufacturing technologies and raw materials have similar environmentally friendly lifespans. Therefore, in the absence of the aforementioned methods, producers or importers can determine the environmentally friendly lifespan of a product through comparisons between products.
10. Question: Why are other common electronic information products, such as televisions and batteries, not included in the environmental protection usage period provided by the table lookup method?
A: The "Average Environmentally Friendly Service Life of Some Electronic Information Products" cited in the table lookup method was jointly developed by more than 100 industry representatives from the Working Group on Pollution Control Standards for Electronic Information Products, and basically reflects the environmentally friendly service life of the listed products under the current technological level. However, there are still some products whose environmentally friendly service life could not be agreed upon within the group, or whose members were not representative enough, and therefore were not included.
– Reference source: Ministry of Industry and Information Technology of China, 2009-11-30
