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China RoHS supplier declaration template

Use these fields to collect a supplier declaration that is traceable to the part, site, revision, substance result, and supporting evidence.

This is a voluntary evidence template, not an official China RoHS form or certificate. The finished-product producer or importer must still make and document the marking, disclosure, catalogue, and conformity decisions.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Oct 15, 2026
4 sections6 primary sources
Overview

Use one controlled declaration for each supplier and defined group of parts. State exactly what the declaration covers, report each substance result and its basis, identify any China exception, and require notice before a covered change. Do not sign the internal product-release block until the declared parts match the released China bill of materials.

Section 1

Template status and scope

The 2016 Measures do not prescribe a supplier declaration form. MIIT guidance allows an upstream supplier to omit a China RoHS mark from parts, components, or raw materials bought for production, but the supplier must give the purchaser all information needed to mark the finished product.

Use this template only as evidence input. It does not establish that a finished product is in scope, that an exception applies, that an environmental protection use period is correct, or that a catalogue product has completed its conformity-assessment route.

Do not confuse this voluntary upstream template with the formal route for catalogue products. Under that route, the supplier completes the product conformity evaluation and reports the conformity information to the China RoHS public service platform within 30 days after market placement.

  • Intended recipient: name the producer, importer, or purchasing entity that will use the information.
  • Finished-product context: record the China model, product family, BOM revision, and intended release.
  • Supplier scope: list every covered supplied part, revision, material, component, accessory, site, and effective lot or date range.
  • Status statement: label the document as a supplier-provided evidence record, not a government-issued form, approval, or China RoHS certificate.
Section 2

Supplier and supplied-item fields

Complete the identity block before entering substance results. If the legal supplier and actual manufacturer differ, name both. A declaration tied only to a trade name or sales office cannot show which site and process produced the released part.

Use an attachment when the declaration covers many parts, but give the attachment a revision and incorporate it into the signed declaration.

  • Supplier: legal name, registered address, contact, and declaration owner.
  • Manufacturer: legal name, manufacturing site address, and site identifier if used.
  • Supplied item: supplier and customer part numbers, description, revision, material or formulation identifier, and production date or lot coverage.
  • Composition coverage: materials, components, subassemblies, accessories, cables, batteries, coatings, solders, and other included elements.
  • Excluded coverage: list anything not assessed. Do not use 'all products' unless the evidence covers every named item, site, and revision.
Section 3

Substance-result and evidence fields

Create one row for each substance and assessed material or component. Cover lead, mercury, cadmium, hexavalent chromium, PBB, and PBDE. For a product within the 2026 Catalogue controls, also cover DBP, DIBP, BBP, and DEHP, subject to the catalogue's implementation date and the applicable standard.

Report a numeric result when the source evidence provides one. If the supplier gives only a limit conclusion, record the stated limit, standard, amendment, and evidence basis. Use 'not assessed' for an unknown; do not replace it with zero, not detected, or compliant.

  • Result: substance, material or component location, value, unit, reporting limit, and pass/fail conclusion against the named requirement.
  • Basis: measured, calculated, upstream declaration, certification, or other documented method.
  • Test evidence: report identifier, laboratory, sample description, sample date, report date, preparation method, and applicable GB/T 39560 part or other stated method.
  • Standard: exact designation, year, amendment, and the conformity period for which it is used.
  • Exception: current China Exception List entry, application, conditions, expiry or review trigger, and supporting rationale.
  • Attachments: test reports, upstream declarations, calculations, certificates, and the controlled covered-parts list.
Section 4

Declaration, change-control, and internal review blocks

The supplier declaration should state that the information applies only to the named parts, sites, revisions, and evidence set. The authorised declarant should confirm the stated basis and agree to notify the customer before a change that could affect the results.

The producer or importer should complete a separate internal review to decide scope, BOM coverage, marking and content-table output, environmental protection use period, 2026 Catalogue status, exception use, conformity route, unresolved gaps, and release approval.

  • Supplier approval: declarant name, job title, authority, signature or controlled electronic approval, place, and date.
  • Change notice: supplier, site, material, formulation, process, sub-supplier, part revision, test method, standard, and exception changes.
  • Internal match: China model, released BOM revision, covered-parts reconciliation, reviewer, review date, gaps, conditions, and follow-up owner.
  • Catalogue record: matched entry, implementation date, exception status, certification or route, result, and platform submission reference where applicable.
  • Release result: approved, conditionally approved, or rejected, with the decision owner and the evidence version retained.
Operationalize the requirement

Prepare the China RoHS release evidence file

Sorena AI helps connect supplier declarations to China RoHS product decisions, controls, owners, and review records.

Research workflow
Map official sources to evidence

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

Explore next step
Talk to Sorena
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

MIIT implementation FAQ for Order No. 32
miit.gov.cn3 citations
Referenced sections
  • Official guidance for upstream information transfer, evidence bases, component grouping, marking, and environmental protection use period.
  • Question 31 explains the information-transfer rule for production parts, components, and raw materials, including inputs bought from outside China.
  • Questions 31 and 41 explain that upstream information must cover the finished product's constituent parts and that component grouping should allow the hazardous-substance information to reflect the product fully.
MIIT Order No. 32: Measures for Restriction of Hazardous Substances in Electrical and Electronic Products
miit.gov.cn3 citations
Referenced sections
  • Binding duties for producers, importers, and sellers, including marking, disclosure, environmental protection use period, catalogue limits, and conformity assessment.
  • Articles 10-18 place duties on producers, importers, and sellers and do not create a prescribed supplier declaration form.
  • Articles 13-18 establish the producer's or importer's finished-product marking, environmental protection use period, catalogue, and conformity duties that remain after supplier evidence is collected.
MIIT Announcement No. 11 of 2026: Catalogue and Exception List
wap.miit.gov.cn2 citations
Referenced sections
  • Current catalogue-controlled substances, product coverage, implementation timing, and exception framework.
  • Names the ten catalogue-controlled substances and makes the 2026 Exception List applicable from publication, with product timing set by the catalogue.

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What supplier evidence should we keep for China RoHS?

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