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China RoHS RoHS compliance checklist

Release checklist for China RoHS scope, actor duties, marking, disclosure, the 2026 catalogue, exceptions, conformity assessment, and transition dates.

Release only after the exact China model has a recorded scope decision, assigned actor duties, approved substance information and environmental protection use period marking, and a dated 2026 catalogue and conformity conclusion.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Jul 24, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
9

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Jul 5, 2026
Updated Jul 24, 2026
Overview

Use this checklist before a covered electrical or electronic product is produced, imported, or sold in China. General marking and disclosure duties apply even when the product is outside the compliance-management catalogue. Catalogue products also need the applicable substance-limit, exception, implementation-date, and conformity-assessment checks.

Section 1

Gate 1: confirm scope, activity, and actor

Record whether the product relies on electric current or electromagnetic fields to work, or is intended to generate, transmit, or measure them. Confirm that its rated working voltage does not exceed 1,500 V DC or 1,000 V AC. Equipment involved in generating, transmitting, or distributing electrical energy is excluded from this definition. MIIT implementation guidance also treats military-use equipment, equipment for special or extreme environments, export-only equipment, temporary imports or equipment entering China for repair but not sale, research or test prototypes, exhibition or display items not for sale, and their dedicated or customised supporting products as outside the Measures' scope.

Next record the China activity. The Measures apply to covered products produced, sold, or imported in China. Assign each applicable role because designers, producers, importers, and sellers have different duties, and one organization may hold more than one role.

  • Evidence owner: product or regulatory lead. Keep the exact China model and revision, intended function, rated-voltage source, China activity, inclusion or exclusion rationale, cited article, approver, and approval date.
  • Designer gate: confirm the design does not violate mandatory standards and applies the relevant hazardous-substance standards while meeting process requirements.
  • Producer gate: confirm materials, technologies, and processes follow the applicable standards, and block products that do not meet the Measures from leaving the factory or being sold.
  • Importer gate: confirm the imported product and its packaging meet the applicable standards before import release.
  • Seller gate: control intake and do not sell a product that violates the applicable hazardous-substance standards.
Sources for this answer
Measures for Restriction of Hazardous Substances in Electrical and Electronic Products
Articles 2-3 establish territorial and product scope; Articles 9-12 and 16 assign duties to designers, producers, importers, and sellers.
MIIT implementation FAQ for Order No. 32
Official explanatory guidance. Question 11 identifies additional use-specific exclusions that are not stated in Article 3's text.
Section 2

Gate 2: approve marking and product information

For every covered product, producers and importers must apply the relevant marking standard to disclose the hazardous substances contained in the marketed product. Article 13 calls for the substance name, content, component location, recyclability, and information about environmental or health effects from improper use or disposal.

They must also mark the environmental protection use period determined by the producer or importer. When the product's size, shape, surface material, or function prevents marking on the product, Articles 13 and 14 allow the information in the product instructions. SJ/T 11364-2024 is the current marking standard and has applied since 1 April 2025.

  • Evidence owner: producer or importer. Keep the approved mark, substance table or other permitted presentation, product instructions, environmental protection use period rationale, standard edition, approver, and exact model or model family covered.
  • Map each supplier declaration, test report, and BOM conclusion to the substance, homogeneous material or component addressed, supplier part revision, finished-product model, and decision it supports.
  • Treat supplier evidence as input to the producer's or importer's decision. The Measures do not make a supplier declaration, BOM, test report, release approval, or change log a named mandatory form.
  • Confirm that packaging materials follow applicable mandatory and packaging standards and use materials that are harmless, readily degradable, and convenient to recycle, as Article 12 requires.
Sources for this answer
Measures for Restriction of Hazardous Substances in Electrical and Electronic Products
Articles 12-15 establish packaging, hazardous-substance information, environmental protection use period marking, the instructions fallback, and responsibility for determining the use period.
SJ/T 11364-2024: marking requirements
Official standards record showing that SJ/T 11364-2024 is current, took effect on 1 April 2025, and replaced the 2014 edition.
Section 3

Gate 3: apply the 2026 catalogue and conformity route

Check the product against the exact name, range, definition, implementation date, and exceptions in the 2026 compliance-management catalogue. The catalogue contains 33 product groups. Its ten continuing groups remained in the catalogue route when the new material took effect on 28 May 2026; 23 new groups and expanded ranges generally have an implementation date of 1 August 2027.

For a catalogue product whose implementation date has arrived, address all ten listed substances: lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DBP, DIBP, BBP, and DEHP. Apply the 2026 exception list only when the product's material or application meets the stated entry and conditions.

  • Evidence owner: producer or importer. Keep the catalogue row, product-range match, implementation date, substance-limit assessment, each claimed exception and its conditions, and the approved conformity route.
  • For products already in the continuing catalogue groups, confirm the current national voluntary certification or self-declaration result is reported through the China RoHS public service platform. For self-declaration, the supplier must report product conformity information within 30 days after market placement. For voluntary certification, the certification body must report the result within five working days after issuing the certificate.
  • From 1 January 2026 through 31 July 2027, catalogue conformity assessment must use amended GB/T 26572-2011 or GB 26572-2025. From 1 August 2027, new conformity-assessment activity must use GB 26572-2025. Products already assessed to amended GB/T 26572-2011 and continuing to leave the factory or be imported may convert to GB 26572-2025 through natural transition when a certificate expires or the product changes.
  • A product assessed only to unamended GB/T 26572-2011 and still leaving the factory or being imported from 1 January 2026 must complete conversion by 1 January 2027.
  • Use the corresponding parts of the GB/T 39560 series for testing under the transition announcement.
Sources for this answer
MIIT Announcement No. 11 of 2026: compliance-management catalogue and exception list
Replaced the 2018 catalogue and exception list on 28 May 2026 and identifies the ten substances, product-specific timing, exception-list treatment, and conformity-assessment requirement.
MIIT policy explanation of the 2026 catalogue and exception list
Explains the 33 groups, continuity for the ten existing groups, and 1 August 2027 implementation for the 23 new groups and expanded ranges.
SAMR and MIIT Announcement No. 44 of 2025 on conformity-assessment standards
Sets the permissible standards during 2026-2027, the 1 January 2027 conversion deadline for products assessed only to the unamended 2011 standard, and use of the GB/T 39560 series.
MIIT China RoHS information reporting status through June 2026
Confirms the current reporting duty and public-service-platform route for the continuing catalogue product groups.
SAMR and MIIT China RoHS conformity-assessment implementation arrangement
Section I establishes national voluntary certification and self-declaration as the two catalogue-product routes; Sections II and III set the five-working-day certification reporting deadline and the 30-day self-declaration reporting deadline.
Section 4

Gate 4: approve release and control changes

Approve release only when the file identifies the exact product and revision, each applicable legal actor, the approved marking and instructions, current catalogue status, implementation date, exceptions, conformity result, and unresolved conditions. Keep China RoHS separate from EU RoHS, end-of-life rules, and general product-safety certification even when evidence overlaps.

The Measures do not set a universal retention period for this evidence file. Set and record an internal period that supports continued production, import, sale, market-surveillance questions, and change investigations.

  • Reopen scope when function, rated voltage, China activity, model configuration, or reliance on an exclusion identified by the Measures or MIIT implementation guidance changes.
  • Reopen substance and marking review when a material, component, supplier part, production process, environmental protection use period, label, instructions, or supplier declaration changes.
  • Reopen the catalogue route when the catalogue, exception list, applicable standard, product range, implementation date, certification, self-declaration, or platform submission changes.
  • Do not use an EU declaration or supplier form as the China conformity assessment unless the current China system recognizes the chosen route and the evidence meets its requirements.
Sources for this answer
Measures for Restriction of Hazardous Substances in Electrical and Electronic Products
Articles 9-19 identify the duties and violation categories that the release and change controls should continue to address; the Measures do not specify a universal retention period for an internal evidence file.
China RoHS public service platform
Official platform for reporting and public lookup of conformity-assessment information for catalogue products.
Build the evidence file

Prepare the China RoHS release evidence file

Sorena AI helps assign the China RoHS release gates, evidence, owners, and change reviews for each product model.

Research workflow
Map official sources to evidence

Research Copilot connects the official citation, decision, owner, retained evidence, and change history.

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Review the China route

Check the China RoHS scope decision and unresolved launch questions with Sorena.

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Primary sources

References and citations

China RoHS public service platform
chinarohs.miit.gov.cn
Referenced sections
  • Official platform for reporting and public lookup of conformity-assessment information for catalogue products.
SJ/T 11364-2024: marking requirements
std.samr.gov.cn
Referenced sections
  • Official standards record showing that SJ/T 11364-2024 is current, took effect on 1 April 2025, and replaced the 2014 edition.
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Covered electrical and electronic products under China RoHS
Apply the China RoHS function, rated-voltage, China-activity, supporting-product, and electricity-system exclusion tests before checking the 2026 catalogue.
Does China RoHS cover my electrical or electronic product?
Start with the China RoHS legal definition and product facts. Keep a covered-product note before collecting supplier material declarations or preparing marking/disclosure evidence.
How is China RoHS different from China e-waste rules?
China RoHS addresses hazardous substances, marking and disclosure before or during market placement; China e-waste rules address recovery and disposal at end of life.
Is China RoHS the same as EU RoHS?
No. China RoHS and EU RoHS overlap in substance control but use different scope rules, exclusions, actors, marking and disclosure outputs, conformity routes, and transition dates.
What is China RoHS marking and disclosure evidence?
Keep the approved China RoHS mark or instructions, hazardous-substance disclosure, environmental protection use period rationale, technical support, and release approval for the exact model.
What supplier evidence should we keep for China RoHS?
Keep supplier declarations and test evidence traceable to the exact part, material, site, revision, substance conclusion, and finished China model. Supplier data supports, but does not replace, the product-level China RoHS decision.