Does China RoHS cover my electrical or electronic product? Direct answer

The product is within the definition if it relies on electric current or electromagnetic fields to work, or is intended to generate, transmit, or measure current or electromagnetic fields, and its rated working voltage does not exceed 1,500 V DC or 1,000 V AC. The definition also includes supporting products. Equipment involved in producing, transmitting, or distributing electrical energy is expressly excluded. 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 apply when a covered product is produced, sold, or imported within China. They assign different duties to designers, producers, importers, and sellers, so record each China activity and actor rather than treating market presence as a single role.

First document the product's intended functions and whether electric current or electromagnetic fields are needed for any of them. Next record the rated AC and DC working voltage from controlled technical documentation. Then identify the production, sale, or import activity in China and the responsible actor.

If the product is covered, apply the general marking and information duties even if it is outside the compliance-management catalogue. For a catalogue product, also check the product definition, implementation date, applicable exceptions, substance limits, and required conformity-assessment route.

The 2026 catalogue contains 33 product groups. Continuing groups include refrigerators, air conditioners, washing machines, televisions, microcomputers, mobile handsets, and telephones. Newly added examples include microwave ovens, rice cookers, portable power banks, smart watches and bands, headphones, robot vacuum cleaners, servers, network switches and routers, electronic blood-pressure monitors, and hearing aids. The reorganised existing groups continued when the catalogue was published on 28 May 2026; newly added groups and newly added scope generally enter the limit and conformity-assessment layer on 1 August 2027. Use the exact catalogue definition and date for the model.

A product name alone cannot settle scope. Mixed mechanical and electrical equipment may still qualify if current or electromagnetic fields are needed for a function, while equipment for electrical-energy production, transmission, or distribution may fall within the express exclusion. Document the actual function, voltage, configuration, and China activity.

Do not use absence from the catalogue as an exclusion from China RoHS. The 2026 catalogue controls the additional limit and conformity-assessment layer. The broader marking and hazardous-substance information duties arise from the Measures for covered electrical and electronic products.