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Analysis Report of EU Violation Notification in the First Half of 2022

Time：

2022-07-21

RAPEX (The EU rapid alert system for dangerous non-food products) is the EU rapid alert system for non-food consumer products, which is established in accordance with Article 12 of the General Product Safety Directive 2001/95/EC

RAPEX (The EU rapid alert system for dangerous non-food products) is the EU rapid alert system for non-food consumer products. Violations of one or more legal rules are likely to be notified in the system, each alert contains information on the type of product detected as dangerous, a description of the risk and actions taken by the economic operator or ordered by the authorities, other members Chinese authorities follow up on every warning and take their own measures if they find the same product in their home market.

◉ High Frequency Reporting Countries

In the first half of 2022, there were about 1,020 violation notifications, of which 50.4% of the products were sourced from China. The top five countries in terms of number of notification submissions were Germany, France, Poland, Hungary and Sweden, which was consistent with the top five in 2021. Only the ranking order has changed, and the total number of notifications from the five countries exceeds 50%. Therefore, companies exporting products from these five countries need to pay special attention to law enforcement.

◉High Frequency Notification Product Type

　　According to the official classification, the top five product types in the number of notifications are toys, motor vehicles, clothing, textile and fashion products, jewelry and electrical equipment; among them, there are also battery-powered products in the toy category, which were notified for violating the RoHS directive.

◉ High Risk Types

Chemicals, injuries, suffocation, electric shock, fire, burns, environmental, health risks, hearing/vision impairment, and strangulation were the top ten risk types for violations. Among them, cases involving chemical risks accounted for 34.5%, and cases involving environmental risks accounted for 6.3%. Cases that violated the RoHS Directive, REACH regulations and POPs regulations basically belong to "chemical" or "environmental" risks. It can be seen that the proportion of notifications involving chemical and environmental risks in the first half of 2022 violation notifications is larger than that of chemical and environmental risks in the whole year of 2021 (27.2%).

Note: Since the same product may involve multiple risk types, the sum of the percentages of all risk types may be greater than 100%;

　　Cases involving violations of the RoHS Directive, REACH regulations and POPs regulations accounted for 21.6% of all notifications, 55.1% of chemical and environmental risk cases, and 90.4% of the products were mainly sourced from China (notifications with unknown origin of products). except). It should be noted that the number of RoHS violation notifications in the first half of 2022 has reached 80% of that in 2021. Enterprises that manufacture electrical and electronic equipment and export them to the EU need to pay special attention to the RoHS compliance of their products.

◉ Examples of Violations of Electrical and Electronic Equipment

product name	Reason for violation	Violations & Penalties	countries involved
earphone	Solder contains excess lead, measured at 19% by weight	Violation of RoHS Directive, product withdrawn from the market	Notifying country: Sweden Country of Origin: China
facial electric massager	Solder contains excess lead, measured at 32% by weight	Violation of RoHS Directive, product withdrawn from the market	Notifying country: Sweden Country of Origin: China
Wireless Headphones	The insulating plastic material of the charging cable contains an excessive amount of bis(2-ethylhexyl) phthalate (DEHP) and dibutyl phthalate (DBP), and the measured values are as high as 1.98% and 1.75% (both by weight). ); the solder contained an excess of lead, measured at 43.2% by weight	Violation of the RoHS Directive, product withdrawal from the market, notice of remedial measures	Notifying country: Norway Country of Origin: China
automatic mixing cup	Two solders contain excess lead, measured as high as 58% and 48% (both by weight)	Violation of RoHS Directive, product withdrawn from the market	Notifying country: Sweden Country of Origin: China
night light	Solder contains excess lead, measured at 7.93% (by weight)	Violation of RoHS Directive, product withdrawn from the market	Notifying country: Sweden Country of Origin: China
Wireless Headphones	The black plastic material on the cable contains short-chain chlorinated paraffins (SCCPs), measured at 0.4% by weight	Violation of POPs regulations, stop selling	Notifying country: Norway Country of Origin: China
remote control car	The plastic material contained excess di(2-ethylhexyl) phthalate (DEHP) and diisobutyl phthalate (DIBP), the measured values were 13.7% and 0.32% (both by weight)	Violation of REACH regulations and RoHS directive, product recall	Notifying country: Malta Country of Origin: China
electric toothbrush	Solder contains excess lead, measured at 84% (by weight)	Violation of RoHS Directive, sales prohibited	Notifying country: Luxembourg Country of Origin: China
LED lighting	Excessive lead in solder, excess short-chain chlorinated paraffin (SCCP) and bis(2-ethylhexyl) phthalate (DEHP) in plastic, measured at 10.66%, 0.43% and 1.8%, respectively ( All weight ratios)	Products withdrawn from the market in violation of RoHS 2.0 directive and POPs regulations	Notifying country: Norway Country of Origin: Unknown
Outdoor solar light	Solder contains excess lead, measured at 67% (by weight)	Violation of RoHS Directive, sales prohibited	Notifying country: Luxembourg Country of Origin: Unknown