Apply the China RoHS function, rated-voltage, China-activity, supporting-product, and electricity-system exclusion tests before checking the 2026 catalogue.
A covered product relies on current or electromagnetic fields to work, or is intended to generate, transmit, or measure them, and stays within 1,500 V DC or 1,000 V AC rated working voltage. Equipment involved in generating, transmitting, or distributing electrical energy is excluded.
Structured answer sets in this page tree.
Cited legal and guidance references.
A product is in the general China RoHS scope when it meets the electrical and electronic product definition and is produced, sold, or imported in China. Catalogue inclusion is a separate check: it adds limits and conformity assessment but does not define the full scope of the Measures.
Start with function. Article 3 covers equipment and supporting products that rely on electric current or electromagnetic fields to work, or that are intended to generate, transmit, or measure current or electromagnetic fields. A product name, customs code, EU RoHS category, supplier declaration, or presence in another China product list does not replace this test.
Then check rated working voltage and China activity. The definition is limited to no more than 1,500 V DC or 1,000 V AC, and Article 2 applies the Measures to covered products produced, sold, or imported in China.
The definition decides general coverage; it does not by itself identify the responsible actor, prove compliance with substance or marking standards, set the environmental protection use period, or establish catalogue status. Make those decisions after recording scope.
Borderline systems need a configuration-specific rationale. If a marketed system combines electrical equipment, passive items, detachable accessories, or equipment used around electricity infrastructure, identify what is being produced, sold, or imported and explain which items meet the definition or the express exclusion. Do not extend the exclusion merely because equipment is installed near generation, transmission, or distribution equipment.
After confirming general scope, compare the exact product with the 2026 compliance-management catalogue. It contains 33 product groups and replaced the 2018 first-batch catalogue on 28 May 2026. The ten continuing groups remained subject to the catalogue route; the 23 new groups and expanded ranges generally enter it on 1 August 2027.
Examples of new groups include microwave ovens, rice cookers, drinking-water appliances, projectors, portable power banks, smart watches and bands, headphones, smart speakers, robot vacuum cleaners, electronic smart locks, servers, network switching and routing equipment, electronic blood-pressure monitors, blood-glucose meters, and hearing aids. These are examples of catalogue groups, not a complete list and not a substitute for the catalogue's exact scope wording.
Keep a scope record before production, import, or sale. Tie it to the exact model, revision, and marketed configuration, not a broad product family whose members have different functions, voltages, or accessories.
The Measures do not prescribe a named scope form. A useful record states the facts, cites Articles 2-3, identifies the responsible owner and approver, and separates the general coverage conclusion from the later catalogue conclusion.
Sorena AI helps record the product facts, general scope conclusion, catalogue decision, owner, approval, and reassessment triggers.
Research Copilot connects the official citation, decision, owner, retained evidence, and change history.
Check the China RoHS scope decision and unresolved launch questions with Sorena.