China RoHS RoHS deadlines and compliance calendar

Order No. 32 promulgated the Measures for Restriction of Hazardous Substances in Electrical and Electronic Products on 6 January 2016. The Measures took effect on 1 July 2016, when the 2006 Administrative Measures for Control of Pollution Caused by Electronic Information Products were repealed.

The Measures apply to producing, selling, and importing covered electrical and electronic products within the People's Republic of China. A covered product is equipment, or a supporting product, that relies on current or electromagnetic fields or is designed to generate, transmit, or measure them, at rated voltages no higher than 1,500 V DC or 1,000 V AC. Equipment for generating, transmitting, or distributing electrical energy is excluded from that definition. 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.

A date shown on a government webpage may be the page's posting or update date. It does not replace the promulgation or effective date stated in the legal text.

The Measures do not state a recurring annual filing, renewal, or reporting deadline. The operational calendar should instead follow the activity and actor: design and production controls before manufacture, importer checks before import, and seller checks before sale.

Catalogue-product conformity reporting has route-specific deadlines. For self-declaration, the supplier must report product conformity information to the China RoHS public service platform within 30 days after market placement. For national voluntary certification, the certification body must report the result within five working days after issuing the certificate.

For products placed on the market, producers and importers must provide the hazardous-substance information required by Article 13 and mark the environmental protection use period under Article 14. If product size, shape, surface material, or function prevents marking on the product, the required information may be stated in the product instructions as those articles provide.

The producer or importer determines the environmental protection use period. It is a product marking decision, not a recurring renewal date under the Measures.

Article 3 defines the compliance-management catalogue as the instrument that identifies product categories, restricted substances, restriction timing, and exceptions. Articles 17 and 18 provide for catalogue management and conformity assessment. The 2016 Measures do not themselves list a single implementation date for every catalogue product.

The 2026 catalogue and exception list took effect on 28 May 2026 and replaced the 2018 first-batch documents. The ten continuing product groups remained in the catalogue route. The 23 newly added groups and expanded portions of existing ranges generally enter the catalogue controls on 1 August 2027, but the official entry and product-specific implementation date control each model.

For each product, record the exact product category, product-range match, restricted substances, implementation date, exception, limit standard, assessment route, and platform record. Do not copy a date from another category or treat the Measures' 1 July 2016 commencement as the restriction date for every catalogue entry.

The conformity-standard transition is separate again. From 1 January 2026 through 31 July 2027, catalogue-product conformity assessment may use GB/T 26572-2011 with Amendment 1 or GB 26572-2025. A product assessed only to unamended GB/T 26572-2011 and still leaving the factory or being imported from 1 January 2026 must convert by 1 January 2027. 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 through natural transition when a certificate expires or the product changes. Products produced or imported before 1 August 2027 may continue to be sold through 31 July 2028.

A useful compliance calendar identifies the legal trigger, affected product and actor, required action, owner, source, due date, and completion evidence. Label an internally selected review or approval date as a company control, not a statutory China RoHS deadline.

Retain enough product-specific evidence to reconstruct the release decision. A supplier declaration can support the file, but it does not replace the producer's, importer's, or seller's own duty under the Measures.