VIETNAM ROHS

The Vietnam RoHS regulation, Circular 30/2011/TT-BCT, came into effect as of December 1^st, 2012.

Electronics Manufacturers Within the Vietnam RoHS Scope

The Vietnam RoHS details substance restrictions for which retailers, suppliers, producers, and manufacturers of Electrical and Electronic Equipment (EEE) must comply in order to engage in the Vietnamese market. Not all business-to-business (B2B), and business-to-consumer (B2C) products are within the scope. See the table below for a detailed list of applicable EEE.

Targeted Categories of EEE

Annex I of the EU RoHS lists the 11 different categories of EEE that the Directive covers. The categories covered by the Vietnamese RoHS are these same categories referenced 1 to 7, and 10. Categories 8 and 9 are not applicable under the Circular. The following are the categories to which the Vietnam RoHS applies.

	Category	Product Examples
1	Large household appliances	Refrigerators, freezers, dryers, washers, stoves, dishwashers, air conditioners, etc.
2	Small household appliances	Vacuum cleaners, sewing machines, hairdryers, toasters, coffee makers, clocks, irons, etc.
3	IT and telecommunications equipment	Minicomputers, copiers, personal computers, printers, satellite TV, cellular phones, antennas, cell tower equipment, etc.
4	Consumer equipment	Radios, stereos, TVs, video cameras, DVD players, audio amps, etc.
5	Lighting equipment	Fluorescent lamps, lighting fixtures, halogen lamps, lightbulbs, high-/low-pressure sodium lamps, etc.
6	Electrical and electronic tools	Electric drills, nail guns, power saws, sprayers, milling machines, lathes, lawnmowers, blowers, etc.
7	Toys, leisure, and sports equipment	Toy electric trains, treadmills, car racing sets, videogames, talking dolls, slot machines, etc.
10	Automatic dispensers	Hot drink vending machines, vending machines, ATMs (automated teller machines), etc.

Integrating the RoHS Directive 2011/65/EU

The objective of the EU RoHS (Directive 2011/65/EU) is to restrict the use of certain hazardous substances in EEE. European directives such as this one are binding to the member states of the European Union. However, it is not uncommon for other countries to integrate EU directives into their own legislation. Vietnam is one of these countries that has adopted part of the EU RoHS Directive into their jurisdiction. This law is known as Circular 30/2011/TT-BCT.

Differences Between the EU and Vietnam RoHS

The specifics of the EU RoHS Directive can be found on our Europe RoHS Compliance page.

The Vietnamese RoHS follows in part the limitations of this directive. Only 6 of the 10 EU RoHS restricted substances are regulated in Vietnam. Namely: lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyls (PBB), and polybrominated diphenyl ethers (PBDE).

Substance Name	EU RoHS	Vietnam RoHS	Concentration Limit
Lead (Pb) and lead compounds	X	X	< 0.1% or 1000 ppm*
Cadmium (Cd) and cadmium compounds	X	X	< 0.01% or 100 ppm
	Mercury (Me) and mercury compounds	X	X	< 0.1% or 1000 ppm
		Hexavalent Chromium (Cr6+) and hexavalent chromium compounds	X	X	< 0.1% or 1000 ppm
			Polybrominated biphenyls (PBBs)	X	X	< 0.1% or 1000 ppm
Polybrominated diphenyl ethers (PBDEs)				X	X	< 0.1% or 1000 ppm
	Butyl benzyl phthalate (BBP) – CAS # 85-68-7			X	Unregulated	< 0.1% or 1000 ppm
		Di-n-butyl phthalate (DBP) – CAS # 84-74-2		X	Unregulated	< 0.1% or 1000 ppm
			Di(2-ethylhexyl) phthalate (DEHP) – CAS # 117-81-7	X	Unregulated	< 0.1% or 1000 ppm
Diisobutyl phthalate (DIBP) – CAS # 84-69-5				X	Unregulated	< 0.1% or 1000 ppm

*ppm: parts per million

Vietnam RoHS: Responsibilities of Manufacturers or Importers

Similar to the EU RoHS, conformity is a self-declaration process. That is, once a product complies with the Circular 30/2011/TT-BCT regarding allowable limits of toxic substances, the information must be disclosed by the manufacturer. Self-declaration can be in one of the following forms:

On the website of the manufacturer/importer
In instruction documents (ex. manuals, instruction sheets)
Stored in electronic media (ex. CDs)
Directly written on the product or packaging

Implementing parts of the EU RoHS, as mentioned, is not uncommon in Asia. In fact, regulations such as China RoHS, Taiwan RoHS, Japan J-Moss, and Korea RoHS have also adopted restrictions against substances in EEE just like Vietnam.

Manufacturers should have enough evidence to demonstrate full compliance with RoHS.

For any assistance with RoHS, Enviropass is fully equipped to ensure you comply in Asia.