Do not treat an EU RoHS conclusion as proof of China RoHS compliance.
The regimes differ in scope tests, market actors, required markings, conformity outputs, catalogue logic, and exemptions even where technical evidence can support both.
Make separate China and EU decisions. A bill of materials, supplier declaration, or test report may support both, but only after the team maps it to each regime's product scope, substance rule, exemption or exception, actor, standard, marking, and conformity output. For the EU decision, record the represented by each substance result.
Comparison boundary
Separate the China decision from the EU decision
Technical evidence may overlap, but scope, substance, exception or exemption, actor, marking, and conformity decisions remain jurisdiction-specific.
Function-and-rated-voltage product definition plus production, sale, or import within China; apply the statutory electricity-system exclusion and the additional use-specific exclusions in MIIT implementation guidance.
EEE within Annex I categories, with electricity or electromagnetic fields needed for at least one intended function, subject to Article 2 exclusions and the same 1,000 V AC and 1,500 V DC ceilings.
General product information applies across China RoHS scope. Catalogue products whose implementation date has arrived must meet the applicable limits for ten substances and any conditions in the China exception list.
Identifies the ten substances, catalogue-based limits, current exception list, product groups, and implementation timing.
Ten Annex II substances are restricted in each : 0.1% for nine substances and 0.01% for cadmium, subject to scope, transition, spare-part, and Annex III or IV exemption provisions.
Articles 3-5 and Annexes II-IV establish the homogeneous-material rule, ten substances, maximum concentration values, transition and spare-part provisions, and exemptions.
A shared result is useful only if its substance, material, method, threshold, product revision, and exception or exemption match both decisions.
Hazardous-substance information and marking under SJ/T 11364-2024, plus a self-declaration or voluntary-certification result and platform reporting when the catalogue route applies.
Explains the catalogue conformity routes, result reporting through the China RoHS public service platform, and product-specific implementation timing.
Technical documentation, internal production control or another permitted procedure, an EU declaration of conformity, CE marking, product and operator identification, and required accompanying documents.
Articles 7-16 establish EU economic-operator, documentation, conformity, declaration, identification, retention, and CE-marking duties.
An EU declaration, CE mark, or technical file does not replace the China mark or catalogue result, and the China outputs do not replace the EU declaration or CE marking.
SJ/T 11364-2024 has applied since 1 April 2025. The 2026 catalogue replaced the first-batch catalogue on 28 May 2026; newly added groups and scope generally enter the limit and conformity layer on 1 August 2027. GB 26572-2025 also takes effect on 1 August 2027.
Shows publication on 1 August 2025 and implementation on 1 August 2027.
Apply the Directive as transposed in the relevant Member State and check the current Annex III or IV exemption entry and expiry. The cited EUR-Lex consolidated text is dated 1 July 2026.
Cited consolidated Directive, including the Annex III and IV exemption text and dates in force on 1 July 2026.
Recheck both files after a product or supplier change and whenever a China standard or catalogue date, China exception, or EU exemption changes.
Scope decision
China RoHS
Function-and-rated-voltage product definition plus production, sale, or import within China; apply the statutory electricity-system exclusion and the additional use-specific exclusions in MIIT implementation guidance.
EEE within Annex I categories, with electricity or electromagnetic fields needed for at least one intended function, subject to Article 2 exclusions and the same 1,000 V AC and 1,500 V DC ceilings.
Articles 2-3 and Annex I establish EU product scope, categories, exclusions, dependency test, and voltage ceilings.
Operational implication
The voltage ceilings overlap, but the functional test, exclusions, categories, actors, and market trigger still require separate decisions.
Substances and limits
China RoHS
General product information applies across China RoHS scope. Catalogue products whose implementation date has arrived must meet the applicable limits for ten substances and any conditions in the China exception list.
Identifies the ten substances, catalogue-based limits, current exception list, product groups, and implementation timing.
EU RoHS
Ten Annex II substances are restricted in each : 0.1% for nine substances and 0.01% for cadmium, subject to scope, transition, spare-part, and Annex III or IV exemption provisions.
Articles 3-5 and Annexes II-IV establish the homogeneous-material rule, ten substances, maximum concentration values, transition and spare-part provisions, and exemptions.
Operational implication
A shared result is useful only if its substance, material, method, threshold, product revision, and exception or exemption match both decisions.
Market outputs
China RoHS
Hazardous-substance information and marking under SJ/T 11364-2024, plus a self-declaration or voluntary-certification result and platform reporting when the catalogue route applies.
Explains the catalogue conformity routes, result reporting through the China RoHS public service platform, and product-specific implementation timing.
EU RoHS
Technical documentation, internal production control or another permitted procedure, an EU declaration of conformity, CE marking, product and operator identification, and required accompanying documents.
Articles 7-16 establish EU economic-operator, documentation, conformity, declaration, identification, retention, and CE-marking duties.
Operational implication
An EU declaration, CE mark, or technical file does not replace the China mark or catalogue result, and the China outputs do not replace the EU declaration or CE marking.
Current dates and change checks
China RoHS
SJ/T 11364-2024 has applied since 1 April 2025. The 2026 catalogue replaced the first-batch catalogue on 28 May 2026; newly added groups and scope generally enter the limit and conformity layer on 1 August 2027. GB 26572-2025 also takes effect on 1 August 2027.
Shows publication on 1 August 2025 and implementation on 1 August 2027.
EU RoHS
Apply the Directive as transposed in the relevant Member State and check the current Annex III or IV exemption entry and expiry. The cited EUR-Lex consolidated text is dated 1 July 2026.
Cited consolidated Directive, including the Annex III and IV exemption text and dates in force on 1 July 2026.
Operational implication
Recheck both files after a product or supplier change and whenever a China standard or catalogue date, China exception, or EU exemption changes.
1
Section 1
Compare the legal tests before reusing evidence
China RoHS applies when a product produced, sold, or imported in China meets the Measures' definition: equipment and supporting products that depend on current or electromagnetic fields to work, or generate, transmit, or measure them, with rated voltage no more than 1,000 V AC or 1,500 V DC. Equipment for electrical-energy generation, transmission, or distribution is excluded. MIIT implementation guidance also identifies use-specific exclusions for military-use, special or extreme-environment, export-only, temporary-import or repair, research or testing, and exhibition equipment that is not sold. EU RoHS uses the same voltage ceilings, but its definition requires electricity or electromagnetic fields for at least one intended function and its scope is organised through Annex I categories and Article 2 exclusions.
China's general layer requires producers and importers to provide hazardous-substance information and an under the applicable marking standard, whether or not the product is in the compliance-management catalogue. For a catalogue product whose implementation date has arrived, the producer or importer must also apply the relevant limits, exception list, and China conformity-assessment route.
EU RoHS restricts ten Annex II substances in each : 0.1% by weight for lead, mercury, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP, and 0.01% for cadmium. The restriction is subject to the Directive's scope rules, transition and spare-part provisions, and application-specific exemptions in Annexes III and IV. The cited EUR-Lex consolidation is dated 1 July 2026; exemption entries and expiry dates still need to be checked at each release or change review.
For EU market placement, the manufacturer prepares technical documentation, uses the applicable conformity-assessment procedure, draws up the EU declaration of conformity, and affixes the CE marking. China RoHS uses its own marking and catalogue conformity system; an EU declaration or CE mark is not a China conformity result.
Scope owner: document the intended functions, rated voltage, product configuration, market activity, and exact exclusion or category analysis for each jurisdiction.
Materials owner: map each declaration or test result to the substance, material or component, supplier part revision, finished-product model, test method, and applicable limit.
China release owner: approve the required substance information, , SJ/T 11364-2024 presentation, current catalogue entry, implementation date, exception, and conformity result.
EU manufacturer: maintain the technical documentation and EU declaration of conformity for 10 years after market placement, apply CE marking, and keep series production in conformity.
Change control: reopen both decisions when a material, supplier, function, voltage, model configuration, market role, standard, catalogue entry, exemption, exception, or implementation date changes.
Explains the 33 catalogue product groups, ten restricted substances, continuing and 1 August 2027 implementation timing, exceptions, self-declaration or voluntary-certification routes, and platform reporting.
Consolidated text through 1 January 2025. Articles 2-4 and Annexes I-II establish EU scope, exclusions, definitions, substances, homogeneous-material limits, and specified transition or spare-part provisions; Annexes III-IV contain application-specific exemptions; Articles 7 and 13-16 establish technical documentation, conformity assessment, the EU declaration of conformity, ten-year retention, CE marking, and presumption-of-conformity rules.
Current official consolidation used to verify the EU scope, homogeneous-material limits, operator duties, and Annex III and IV exemption text and dates.
2
Section 2
Build two approvals from a controlled evidence set
Start with one controlled product identity and evidence index. Then issue two approvals: a China decision that identifies the applicable actor, marking, catalogue status, standard, exception, and conformity route; and an EU decision that identifies the economic operator, Annex I category, Article 2 exclusion analysis, homogeneous-material limits, exemption, technical documentation, declaration, and CE marking.
Do not infer one regime's exemption from the other. China's current exception list and EU Annexes III and IV have different wording, scope conditions, product categories, and dates. Record the exact entry and conditions used for each material or application.
A supplier declaration can reduce testing only when the responsible manufacturer or importer determines that it is adequate for the specific decision. Neither regime makes a generic supplier statement conclusive for every product configuration, material, exemption, or market output.
Reject evidence that cannot be tied to the exact supplier part, material, substance, revision, and finished-product configuration.
Keep separate approval dates and owners so a change can reopen one jurisdiction without silently invalidating the other.
Check the latest official catalogue, exception, exemption, and standard status at the time of release. The current cited EU consolidation is dated 1 July 2026, and the cited China catalogue material was issued in May 2026.
Consolidated EU RoHS text through 1 January 2025 for scope, restrictions, exemptions, actors, documentation, declaration, and CE marking.
Articles 4-5 and Annexes II-IV establish the EU substance restrictions, application-specific exemptions, their conditions, and exemption procedure.
Articles 2-3 and Annex I establish EU product scope, categories, exclusions, dependency test, and voltage ceilings.
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Articles 3-5 and Annexes II-IV establish the homogeneous-material rule, ten substances, maximum concentration values, transition and spare-part provisions, and exemptions.
Articles 7-16 establish EU economic-operator, documentation, conformity, declaration, identification, retention, and CE-marking duties.
Current official EU RoHS consolidation used for live scope, restriction, exemption, and operator decisions.
Current official consolidation used to verify the EU scope, homogeneous-material limits, operator duties, and Annex III and IV exemption text and dates.
Current official consolidation for checking the exact Annex III or IV entry, product category, condition, and expiry date at release.
Show 1 more
Cited consolidated Directive, including the Annex III and IV exemption text and dates in force on 1 July 2026.
Official China source for current catalogue scope, substances, exceptions, conformity routes, and implementation timing.
Explains the 33 catalogue product groups, ten restricted substances, continuing and 1 August 2027 implementation timing, exceptions, self-declaration or voluntary-certification routes, and platform reporting.
Official explanation of the current China catalogue, exception list, substances, implementation timing, and conformity routes.
Consolidated text through 1 January 2025. Articles 2-4 and Annexes I-II establish EU scope, exclusions, definitions, substances, homogeneous-material limits, and specified transition or spare-part provisions; Annexes III-IV contain application-specific exemptions; Articles 7 and 13-16 establish technical documentation, conformity assessment, the EU declaration of conformity, ten-year retention, CE marking, and presumption-of-conformity rules.