Standards Comparison

    PIPL

    Mandatory
    2021

    China's comprehensive law for personal information protection

    VS

    RoHS

    Mandatory
    2011

    EU regulation restricting hazardous substances in EEE

    Quick Verdict

    PIPL regulates personal data privacy for China market access, mandating consent and transfers. RoHS restricts hazardous substances in EEE for EU compliance, requiring material testing. Companies adopt PIPL for data operations in China, RoHS for electronics sales in Europe.

    Data Privacy

    PIPL

    Personal Information Protection Law (PIPL)

    Cost
    €€€€
    Complexity
    Medium
    Implementation Time
    6-12 months

    Key Features

    • Extraterritorial scope targeting services to Chinese individuals
    • Consent-first model without legitimate interests basis
    • Strict separate consent for sensitive personal information
    • Cross-border security assessments for large-volume transfers
    • Fines up to 5% annual revenue or RMB 50M
    Hazardous Substances

    RoHS

    Directive 2011/65/EU (RoHS 2)

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    6-12 months

    Key Features

    • Restricts 10 substances at homogeneous material level
    • Open scope: all EEE unless explicitly excluded
    • Time-limited exemptions via Annexes III/IV
    • Requires technical file and EU DoC
    • Tiered verification with IEC 62321 testing

    Detailed Analysis

    A comprehensive look at the specific requirements, scope, and impact of each standard.

    PIPL Details

    What It Is

    Personal Information Protection Law (PIPL) is China's comprehensive national regulation, effective November 1, 2021, governing collection, processing, storage, transfer, and deletion of personal information. It applies domestically and extraterritorially to organizations targeting Chinese individuals, using a risk-based approach with consent-centric principles, alongside Cybersecurity Law and Data Security Law.

    Key Components

    • Eight chapters, 74 articles covering processing rules, cross-border transfers, individual rights, handler obligations.
    • Core principles: lawfulness, necessity, minimization, transparency, accountability.
    • Sensitive personal information (SPI) like biometrics, health data requires explicit consent.
    • Compliance via security assessments, standard contractual clauses, certifications; no broad legitimate interests basis.

    Why Organizations Use It

    PIPL compliance mitigates fines up to 5% annual revenue, enables market access in China, builds customer trust, reduces breach risks, and supports cross-border operations. It enhances resilience, aids M&A, and positions firms competitively in digital economy.

    Implementation Overview

    Phased approach: gap analysis, data mapping, policy development, controls, audits (6-12 months). Applies to multinationals, domestic firms handling PI; requires PIPO appointment, PIPIAs for high-risk activities. No formal certification but CAC enforcement via audits, penalties.

    RoHS Details

    What It Is

    RoHS (Directive 2011/65/EU, recast as RoHS 2) is an EU regulation restricting hazardous substances in electrical and electronic equipment (EEE) to protect health and environment during waste management. It employs an open-scope approach (all EEE unless excluded) with homogeneous material concentration limits and time-limited exemptions.

    Key Components

    • Restricts 10 substances (e.g., Pb, Hg, Cd, Cr(VI), phthalates) at 0.1% (0.01% for Cd) in homogeneous materials.
    • Annex I categories (11 EEE types); Annexes III/IV for exemptions.
    • Built on CE-marking framework; requires technical documentation and EU Declaration of Conformity (DoC).
    • Compliance via IEC 63000 documentary methods and IEC 62321 testing.

    Why Organizations Use It

    • Mandatory for EU market access; prevents recalls, fines.
    • Enhances recyclability, supply chain governance, ESG reporting.
    • Reduces risks from exemptions expiry, global variants (e.g., China RoHS 2).
    • Builds stakeholder trust, competitive edge in sustainability.

    Implementation Overview

    • **Phased approachscoping, gap analysis, supplier controls, testing, documentation.
    • Applies to manufacturers/importers of EEE; all sizes, global reach.
    • No central certification; market surveillance audits technical files (10-year retention).

    Key Differences

    Scope

    PIPL
    Personal data processing, privacy rights
    RoHS
    Hazardous substances in EEE materials

    Industry

    PIPL
    All handling Chinese personal data
    RoHS
    EEE manufacturers, EU market

    Nature

    PIPL
    Mandatory national privacy law
    RoHS
    Mandatory product safety directive

    Testing

    PIPL
    DPIAs, security audits
    RoHS
    XRF/ICP-MS material analysis

    Penalties

    PIPL
    5% revenue or RMB 50M fines
    RoHS
    Product bans, fines vary by state

    Frequently Asked Questions

    Common questions about PIPL and RoHS

    PIPL FAQ

    RoHS FAQ

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