- Articles 2-3 define territorial and product scope; Articles 9-16 assign design, production, import, packaging, marking, use-period, and seller duties; Articles 17-18 establish the catalogue and conformity-assessment layers.
Product
China RoHS
Apply China RoHS scope, marking, disclosure, 2026 catalogue, conformity-assessment, and transition requirements to .
- China RoHS effective
- covered product scope
- producer/importer determines it
- 2026 catalogue
Understand China RoHS
Decide whether the 2016 China RoHS Measures cover a product, assign the duties of each China-market actor, prepare the required marking and substance information, and apply the current catalogue and conformity route.
The Measures apply to covered produced, sold, or imported in China. All covered products enter the general control, marking, and disclosure layer. Products in the also face substance limits, listed exceptions, implementation dates, and conformity assessment.
Quick scan
Decide covered EEP status
Apply the function, rated-voltage, China activity, and express energy-equipment exclusion tests.
Control hazardous-substance evidence
Support each substance, content, component-location, and exception conclusion for the responsible producer or importer.
Prepare marking and disclosure records
Approve substance information and use-period marking, then document catalogue status, the implementation date, any exception, and conformity assessment.
Decisions to make
- 1
Decide covered EEP status
Check whether the product depends on current or electromagnetic fields, has a rated operating voltage no higher than 1,500 V DC or 1,000 V AC, is produced, sold, or imported within China, and is not electricity generation, transmission, or distribution equipment.
- 2
Control hazardous-substance evidence
Check the six substances named in the Measures and any additional substances required by the current catalogue and standards. Keep model- and component-level support for each disclosure and release decision.
- 3
Prepare marking and disclosure records
Apply the current marking standard to the Article 13 substance information and Article 14 , then check the 2026 catalogue, its exceptions, and the relevant implementation date.
Key dates for China RoHS
The Measures were promulgated on 6 January 2016 and took effect on 1 July 2016. The 2026 catalogue and exception list replaced the 2018 versions on 28 May 2026. Existing catalogue product groups continued immediately; 23 new groups and expanded ranges generally enter the catalogue route on 1 August 2027.
Make the China RoHS decision in order
Start with product scope and your role. Then apply the general duties, prepare marking and disclosure evidence, check catalogue status, and keep the release decision current when the product or its materials change.
Start here: scope and duties
Decide whether the Measures apply, which actor duties attach, and whether the product needs only the general route or also the 2026 catalogue route.
Implementation and evidence
Apply SJ/T 11364-2024, control substance information and use-period marking, and connect supplier inputs to the responsible actor's release approval.
Dates and enforcement
Separate commencement of the Measures from catalogue, exception-list, standard-transition, conversion, and product-specific implementation dates.
Comparisons and focused questions
Keep China RoHS separate from EU RoHS and end-of-life regulation, or jump directly to a common implementation question.
Sources
- The 2026 catalogue and exception list replaced the 2018 versions on 28 May 2026, identify ten controlled substances for catalogue products, and make product-specific implementation dates and listed exceptions part of the decision.
- Explains the 33 product groups, immediate continuity for the ten existing groups, and the 1 August 2027 implementation date for 23 new groups and expanded product ranges.
- Sets the 2026-2027 transition between amended GB/T 26572-2011 and GB 26572-2025, including conversion dates and use of the GB/T 39560 test-method series.
- Official standards record showing that SJ/T 11364-2024 is the current marking standard, effective 1 April 2025, and replaced SJ/T 11364-2014.
Next steps
Prepare the China RoHS release evidence file
Sorena AI connects China RoHS requirements to scope decisions, evidence records, owners, and change reviews.
- Start with the exact China product model, function, rated voltage, China activity, responsible actor, current marking standard, and 2026 catalogue status.
- Research Copilot keeps the official citation, decision owner, evidence record, and approval history connected.
- SSOT preserves official citations, product facts, evidence files, and refresh history when model, material, supplier, standard, or catalogue facts change.
- Open Research Copilot
Map covered-product status, BOM review, supplier declarations, marking, disclosure, catalogue dates, exceptions, conformity assessment, and release approval to official citations and owners.
- Open SSOT
Keep official citations, decisions, approvals, and evidence with the relevant product and compliance records.
- Review unresolved triggers
Check product scope, actor, marking, applicable standard, and catalogue edge cases before production, import, or sale.