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China RoHS Covered electrical and electronic products under

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. The Measures exclude equipment involved in generating, transmitting, or distributing electrical energy, and MIIT implementation guidance identifies additional use-specific exclusions.

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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
4

Cited legal and guidance references.

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

A product is in the general China RoHS scope when it meets the electrical and electronic product definition, is produced, sold, or imported in China, and is not within an applicable exclusion identified by the Measures or MIIT implementation guidance. Catalogue inclusion is a separate check: it adds limits and conformity assessment but does not define the full scope of the Measures.

Section 1

The coverage test

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.

  • Function: identify what the marketed product does and whether current or electromagnetic fields are needed for that function, or whether generating, transmitting, or measuring them is the intended purpose.
  • Voltage: record each applicable rated DC and AC working voltage and the controlled specification, rating plate, or technical document that supplies it.
  • Configuration: identify the equipment, supporting products, model variants, supplied accessories, and power arrangements covered by the decision. Do not assume every accessory follows the main product without applying the definition to the marketed configuration.
  • Territory and activity: record whether the exact model is produced, sold, or imported in China and which organization acts as producer, importer, or seller.
  • Exclusions: document any reliance on the Measures' exclusion for equipment involved in electrical-energy generation, transmission, or distribution. 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 scope. The Measures and guidance do not state blanket exclusions for industrial, professional, medical, automotive, spare-part, or component products.
Sources for this answer
Measures for Restriction of Hazardous Substances in Electrical and Electronic Products
Article 2 supplies the China production, sale, and import trigger. Article 3 supplies the function, equipment and supporting-product wording, voltage ceilings, and express electricity-generation, transmission, and distribution exclusion.
MIIT implementation FAQ for Order No. 32
Official explanatory guidance. Question 11 identifies the use-specific exclusions in addition to the exclusion written in Article 3.
Section 2

Decisions that follow the coverage test

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.

  • A product can be covered by the Measures even if it is outside the compliance-management catalogue.
  • A catalogue entry is not enough on its own; match the exact product name, definition, range, and implementation date.
  • A supplier's China RoHS statement may support material review but does not decide the finished product's function, voltage, China activity, or actor.
  • If the available facts do not establish how a supporting product or mixed system fits the definition, record the unresolved boundary and obtain product-specific advice rather than inventing an exclusion.
Sources for this answer
Measures for Restriction of Hazardous Substances in Electrical and Electronic Products
Articles 2-3 establish general coverage; Articles 9-18 separately establish actor, marking, catalogue, and conformity duties.
MIIT Announcement No. 11 of 2026: compliance-management catalogue and exception list
Current source for the separate catalogue-layer decision, its product-specific timing, exceptions, and conformity requirement.
Section 3

Catalogue status is the second decision

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.

  • Record the catalogue product name, range and definition, applicable scope note, implementation date, and exact model match.
  • If included and the implementation date has arrived, apply the ten-substance limits, current exception list, and conformity-assessment system.
  • If outside the catalogue, retain the general-layer marking, disclosure, packaging, and actor-duty analysis.
  • Do not use the repealed 2018 catalogue or exception list for a decision made after 28 May 2026.
Sources for this answer
MIIT Announcement No. 11 of 2026: compliance-management catalogue and exception list
Makes the 2026 catalogue and exception list effective, repeals the 2018 versions, and establishes the additional limits, exceptions, timing, and conformity layer for listed products.
MIIT policy explanation of the 2026 catalogue and exception list
Explains the 33 product groups, representative new groups, continuity for ten existing groups, and 1 August 2027 implementation for new groups and expanded ranges.
Section 4

Scope record and reassessment triggers

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.

  • Reassess general scope when function, intended purpose, rated working voltage, power architecture, marketed configuration, China activity, or reliance on an exclusion identified by the Measures or MIIT implementation guidance changes.
  • Reassess actor duties when the producer, importer, seller, supply route, or private-label arrangement changes.
  • Reassess the second layer when the model, catalogue, product-range wording, implementation date, or exception list changes.
  • A material or supplier change may leave scope unchanged but still requires a new substance, marking, exception, and release review.
Sources for this answer
Measures for Restriction of Hazardous Substances in Electrical and Electronic Products
Articles 2-3 are the source for the scope record; the Measures do not prescribe a named internal scope form.
MIIT Announcement No. 11 of 2026: compliance-management catalogue and exception list
Current source for catalogue and exception-list change triggers.
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Primary sources

References and citations

MIIT implementation FAQ for Order No. 32
miit.gov.cn
Referenced sections
  • Official explanatory guidance. Question 11 identifies the use-specific exclusions in addition to the exclusion written in Article 3.
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