FAQChina

China RoHS FAQ

Start with the 2016 Measures' product definition and China activity trigger. Then assign actor duties, prepare marking and disclosure, and check the separate catalogue and conformity-assessment layer.

The 2026 catalogue is now in force, while GB 26572-2025 becomes mandatory on 1 August 2027. Record the standard and implementation date used for each model.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Jul 25, 2026
FAQ modules
5

Structured answer sets in this page tree.

Primary sources
9

Cited legal and guidance references.

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Sorena AI
Published Jul 5, 2026
Updated Jul 25, 2026
Overview

China RoHS regulates hazardous substances in covered electrical and electronic products produced, sold, or imported in China. These answers explain the scope decision, actor duties, product information, evidence, catalogue route, and boundaries with EU RoHS and China's e-waste rules.

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FAQ module

Does China RoHS cover my electrical or electronic product?

Start with the China RoHS legal definition and product facts. Keep a covered-product note before collecting supplier material declarations or preparing marking/disclosure evidence.

3 items
FAQ module

How is China RoHS different from China e-waste rules?

China RoHS addresses hazardous substances, marking and disclosure before or during market placement; China e-waste rules address recovery and disposal at end of life.

3 items
FAQ module

Is China RoHS the same as EU RoHS?

No. China RoHS and EU RoHS overlap in substance control but use different scope rules, exclusions, actors, marking and disclosure outputs, conformity routes, and transition dates.

4 items
FAQ module

What is China RoHS marking and disclosure evidence?

Keep the approved China RoHS mark or instructions, hazardous-substance disclosure, environmental protection use period rationale, technical support, and release approval for the exact model.

3 items
FAQ module

What supplier evidence should we keep for China RoHS?

Keep supplier declarations and test evidence traceable to the exact part, material, site, revision, substance conclusion, and finished China model. Supplier data supports, but does not replace, the product-level China RoHS decision.

3 items
Question 1

Most China RoHS questions start with scope

The Measures cover equipment and supporting products that rely on electric current or electromagnetic fields to work, or are intended to generate, transmit, or measure them, when the rated working voltage does not exceed 1,500 V DC or 1,000 V AC. Equipment involved in producing, transmitting, or distributing electrical energy is excluded from that definition.

The Measures apply when a covered product is produced, sold, or imported in China. Identify whether the organisation acts as designer, producer, importer, seller, or more than one role because the duties differ.

Does China RoHS cover my electrical or electronic product?

China RoHS generally covers equipment and supporting products produced, sold, or imported in China when they rely on current or electromagnetic fields to work, or are intended to generate, transmit, or measure them, and their rated working voltage does not exceed 1,500 V DC or 1,000 V AC. Equipment involved in producing, transmitting, or distributing electrical energy is excluded from the definition. Apply those tests to the exact marketed configuration; a product name, customs code, EU RoHS category, or absence from the compliance-management catalogue does not decide general scope.

Which company is responsible for China RoHS compliance?

Responsibility follows the activity named in the 2016 Measures. Designers control design choices and applicable standards; producers control materials, processes, factory release, marking, and product information; importers control imported-product compliance, packaging, marking, and product information; sellers must not sell products that violate the applicable standards. One company can hold several roles, so record every role for the China supply route rather than assigning the whole file to a generic supplier.

Does the compliance-management catalogue define the full scope of China RoHS?

No. The electrical and electronic product definition and the China production, sale, or import trigger determine general coverage. The compliance-management catalogue is a second layer: once a listed product reaches its implementation date, it must also meet the applicable substance limits, exceptions, and conformity-assessment requirements. A covered product outside the catalogue can still have design, packaging, marking, disclosure, and sales duties.

Are components, spare parts, industrial products, or medical products automatically excluded?

The 2016 Measures do not state blanket exclusions for components, spare parts, industrial products, or medical products. Apply the electrical and electronic product definition to the item or marketed configuration and document whether it is equipment or a supporting product within the voltage limits. The express product-definition exclusion is for equipment involved in producing, transmitting, or distributing electrical energy; unclear component and system boundaries need a product-specific rationale.

  • Document the product function, rated voltage, supporting products, exact China activity, and any reliance on the electrical-energy equipment exclusion.
  • Assign designer, producer, importer, and seller duties to named owners.
  • Map product and supplier evidence to the exact China model and bill-of-material revision.
  • Prepare the hazardous-substance information and environmental protection use period mark required of producers and importers.
  • Check the 2026 catalogue, product definition, implementation date, exceptions list, and conformity-assessment route separately.
  • Reopen the file when a supplier, component, material, model, standard, catalogue entry, or exception changes.
Sources for this answer
Measures for Restriction of Hazardous Substances in Electrical and Electronic Products
Articles 2, 3, and 9 to 18 establish the product and activity scope, voltage ceilings, exclusion, actor duties, marking and disclosure, catalogue, and conformity-assessment layers.
MIIT Announcement No. 11 of 2026: Compliance Management Catalogue and Exceptions List
Current binding catalogue and exceptions announcement, effective from publication on 28 May 2026, replacing the 2018 first-batch documents.
Question 2

General duties and catalogue duties are separate

Covered products generally need China-specific hazardous-substance information and environmental protection use period marking whether or not they are in the compliance-management catalogue. Producers and importers own those outputs under Articles 13 to 15.

Catalogue products also enter the substance-limit and conformity-assessment system. Under the national implementation arrangement, the routes are national voluntary certification or a supplier declaration of conformity, with results reported to the China RoHS public service platform.

Does a covered product outside the catalogue still need China RoHS marking and disclosure?

Yes. Producers and importers of covered products must provide the hazardous-substance information required by Article 13 and mark the environmental protection use period required by Article 14 under the applicable marking standard. Catalogue status is a separate check that adds limits, exceptions, and conformity assessment; it does not switch off the general information and marking duties.

What is the environmental protection use period?

The environmental protection use period is the period during normal use in which hazardous substances contained in the product will not leak or suddenly change in a way that causes serious environmental pollution or serious personal or property damage. The producer or importer determines it. It is not the product warranty, storage life, or a promise that the product will remain functional for the marked number of years.

Is a supplier declaration enough to release a finished product?

No. A supplier declaration can support the material and component review, but it does not decide the finished product's scope, legal actors, marking, environmental protection use period, catalogue status, exception, or conformity result. The producer or importer should reconcile supplier evidence to the released bill of materials, resolve gaps, approve the China-market information, and retain the model-specific release decision.

What conformity-assessment routes apply to catalogue products?

The national implementation arrangement provides two routes for products in the compliance-management catalogue: national voluntary certification or a supplier declaration of conformity. The responsible enterprise must use the route applicable to the product and report the result through the China RoHS public service platform. This catalogue conformity result is separate from ordinary upstream supplier material declarations.

  • Keep the covered-product and actor decision.
  • Keep the bill of materials, supplier declarations, test support, and gap review.
  • Keep the approved hazardous-substance information and environmental protection use period rationale.
  • Keep the product or instruction marking revision and any reason for using instructions instead of an on-product mark.
  • Keep the catalogue match, applicable exception, implementation date, conformity route, platform record, and approval.
Sources for this answer
Measures for Restriction of Hazardous Substances in Electrical and Electronic Products
Articles 13 to 18 distinguish general information and use-period marking from catalogue limits and conformity assessment.
China RoHS conformity-assessment implementation arrangement
Official arrangement establishing national voluntary certification and supplier declaration of conformity as the two routes for products in the compliance-management catalogue.
Question 3

Current dates and standards

The 2026 catalogue and exceptions list took effect on 28 May 2026 and replaced the 2018 first-batch documents. Existing catalogue products continued immediately; newly added product types and expanded scopes have product-specific timing, with the new coverage generally beginning on 1 August 2027.

GB 26572-2025 was published on 1 August 2025 and becomes mandatory on 1 August 2027. It combines limits, marking, disclosure, testing, and technical-support-document requirements for ten substances. Until then, use the official transition schedule and record the standard applied to each conformity assessment.

Which China RoHS catalogue and exception list should we use now?

Use the catalogue and exception list issued in MIIT Announcement No. 11 of 2026. They took effect on 28 May 2026 and replaced the 2018 first-batch catalogue and exception list. Match the exact product name, range, definition, implementation date, and exception conditions instead of relying on a category label alone.

When do the newly added 2026 catalogue groups become subject to the catalogue controls?

The ten continuing product groups remained in the catalogue route when the 2026 material took effect. The 23 newly added groups and expanded portions of existing ranges generally enter the catalogue controls on 1 August 2027. The official catalogue wording and the product-specific implementation date still control each model.

When does GB 26572-2025 become mandatory?

GB 26572-2025 becomes mandatory on 1 August 2027. For catalogue-product conformity assessment from 1 January 2026 through 31 July 2027, the official transition permits GB/T 26572-2011 with Amendment 1 or GB 26572-2025. Record the exact standard, amendment, test-method parts, product model, and assessment date used during the transition.

Can an older assessment to unamended GB/T 26572-2011 remain in use?

A catalogue product assessed only to unamended GB/T 26572-2011 that continues to leave the factory or be imported from 1 January 2026 must complete conversion by 1 January 2027 under the joint transition announcement. Check the assessment record, production or import status, and conversion evidence rather than assuming an older result remains sufficient.

  • 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.
  • From 1 August 2027, GB 26572-2025 is the required conformity-assessment standard.
  • Do not treat a future implementation date as current law for a product, or rely on the superseded 2018 catalogue without checking the 2026 replacement.
Sources for this answer
MIIT Policy Explanation for the 2026 Catalogue and Exceptions List
Official explanation of the 33 product types, continuation for existing coverage, transition for newly added or expanded coverage, ten substances, and conformity-assessment duties.
National Standard GB 26572-2025
Official standard record showing publication on 1 August 2025 and implementation on 1 August 2027.
SAMR and MIIT Announcement No. 44 of 2025 on China RoHS conformity-assessment standards
Official transition schedule for standards and testing methods used in catalogue-product conformity assessment.
Question 4

Use the focused answers for the next decision

Use the product-scope answer first. Then open the marking and disclosure answer and the supplier-evidence answer for the release file. Use the EU RoHS and e-waste comparisons only when the product also enters those separate regimes.

What is China RoHS marking and disclosure evidence?

China RoHS marking and disclosure evidence is the model-specific file supporting the producer's or importer's market information. It should connect the applicable marking standard to the substance results, affected component locations, approved product mark or instructions, environmental protection use period rationale, released bill of materials, and artwork revision. For a catalogue product, keep the separate limit, exception, conformity-assessment, and platform records as well.

What supplier evidence should we keep for China RoHS?

Keep declarations, test reports, calculations, certificates, and change notices that identify the supplier, actual manufacturing site, supplied part, revision, covered material or component, substance result, unit, method, standard, date, and any China exception. Reconcile the set to every released bill-of-material line and record missing, conflicting, or obsolete evidence as an open gap. Supplier evidence supports the finished-product decision but does not replace it.

Is China RoHS the same as EU RoHS?

No. China RoHS uses its own product definition, general marking and disclosure layer, environmental protection use period, compliance-management catalogue, exception list, Chinese standards, and national conformity routes. EU RoHS evidence may support a material review, but an EU declaration or exemption does not establish the China product's scope, marking, catalogue status, exception, or conformity result.

How is China RoHS different from China e-waste rules?

China RoHS controls hazardous-substance use, product information, environmental protection use period marking, and catalogue-product conformity before and during market supply. China's e-waste rules address collection, recycling, treatment, and other end-of-life responsibilities under separate instruments. A product can enter both regimes, so keep the scope decisions, actors, records, and deadlines separate.

  • Does China RoHS cover my electrical or electronic product?
  • What is China RoHS marking and disclosure evidence?
  • What supplier evidence should we keep for China RoHS?
  • Is China RoHS the same as EU RoHS?
  • How is China RoHS different from China e-waste rules?
Sources for this answer
Measures for Restriction of Hazardous Substances in Electrical and Electronic Products
Binding China source for finished-product marking, environmental protection use period, catalogue management, conformity assessment, and producer or importer duties.
MIIT implementation FAQ for Order No. 32
Official guidance on evidence bases, upstream information transfer, mark selection, content tables, component grouping, and environmental protection use period.
Directive 2011/65/EU on restriction of hazardous substances in electrical and electronic equipment
Binding EU source showing the separate EU scope, exclusions, homogeneous-material limits, exemptions, economic-operator duties, EU declaration of conformity, and CE marking.
Regulation on the Administration of the Recovery and Disposal of Waste Electrical and Electronic Products
Binding e-waste source for the waste-product catalogue trigger, recovery and centralised treatment system, producer duties, treatment fund, and treatment-operator qualification.
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Primary sources

References and citations

MIIT implementation FAQ for Order No. 32
miit.gov.cn
Referenced sections
  • Official guidance on evidence bases, upstream information transfer, mark selection, content tables, component grouping, and environmental protection use period.
National Standard GB 26572-2025
openstd.samr.gov.cn
Referenced sections
  • Official standard record showing publication on 1 August 2025 and implementation on 1 August 2027.
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