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QuestionChina

Is China RoHS the same as EU RoHS? Direct answer

No. Assess each market separately. China RoHS and EU RoHS differ in scope, exclusions, actor duties, restricted-substance implementation, marking and disclosure, conformity assessment, and evidence.

Technical supplier data may be reused when it fits both analyses, but a conclusion, mark, declaration, or exception from one regime does not establish compliance with the other.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Jul 24, 2026
4 sections10 primary sources
Overview

No. China RoHS and EU RoHS are separate legal regimes. Run a market-specific scope, substance, exception, marking, conformity, and evidence review for each product, including the EU represented by each substance result.

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4 of 4 questions
Question 1

Short answer

China RoHS applies to covered electrical and electronic products produced, sold, or imported in China, subject to the exclusion in the Measures and additional use-specific exclusions identified in MIIT implementation guidance. It requires China-specific hazardous-substance information and marking, and adds substance-limit and conformity-assessment duties for products in the compliance-management catalogue.

EU RoHS applies to electrical and electronic equipment in the Annex I categories, subject to Article 2 exclusions. It restricts Annex II substances at homogeneous-material level, subject to applicable exemptions, and requires technical documentation, an EU declaration of conformity, and CE marking before covered equipment is placed on the EU market.

Question 2

Key differences to document

Both regimes cover electrical and electronic products and currently address lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, BBP, DBP, and DIBP in relevant standards or legislation. That overlap does not make the legal tests interchangeable.

  • Scope: China uses the 2016 Measures' function, voltage, supporting-product, and China-activity test; the EU uses the Directive's EEE definition, Annex I categories, and Article 2 exclusions.
  • Limits: EU Annex II sets maximum concentrations by weight in homogeneous materials and provides application-specific exemptions in Annexes III and IV. China applies its own standards, catalogue timing, and exceptions list.
  • Marking: China requires hazardous-substance information and marking. EU RoHS uses CE marking and an EU declaration of conformity; it does not use China's environmental protection use period mark.
  • Conformity: EU manufacturers prepare technical documentation and the EU declaration under Article 7. China's catalogue products use national voluntary certification or self-declaration through a formal supplier conformity declaration. For self-declaration, the supplier must report product conformity information to the China RoHS public service platform within 30 days after market placement.
  • Actors: China assigns duties to designers, producers, importers, and sellers. EU duties attach to manufacturers, authorised representatives, importers, and distributors as defined in the Directive.
  • Exceptions: evaluate the exact China catalogue exceptions list and the current EU Annex III or IV exemption separately, including scope and expiry.
Question 3

What evidence can be reused

Supplier declarations, material composition data, test reports, bill-of-material mappings, and change controls may support both files if they cover the correct substances, materials, models, revisions, methods, and dates. Record the reason each item is suitable for each regime.

Do not reuse the legal conclusion. Keep an independent China scope and actor decision, China marking and disclosure approval, catalogue and conformity conclusion, EU scope and exclusion decision, homogeneous-material and exemption review, EU technical documentation, declaration, and CE-marking approval.

Question 4

China's current transition matters

GB 26572-2025 takes effect on 1 August 2027. It will make ten-substance limits for catalogue products and marking, disclosure, testing, and technical-support-document requirements part of one mandatory national standard. Products produced or imported before that date may continue to be sold through 31 July 2028. Until then, follow the official transition schedule for the applicable China product and conformity-assessment route.

The 2026 China catalogue contains 33 product groups. Its reorganised existing groups continued when the catalogue was published on 28 May 2026, while newly added groups and newly added scope generally enter the limit and conformity-assessment layer on 1 August 2027. Examples of newly added groups include portable power banks, smart watches and bands, headphones, robot vacuum cleaners, servers, electronic blood-pressure monitors, and hearing aids.

The substance lists will align more closely, but the regimes will still differ in scope, exceptions, markings, declarations, responsible actors, and enforcement. Alignment of technical limits does not create mutual recognition.

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Prepare the China RoHS release evidence file

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Primary sources

References and citations

Directive 2011/65/EU on restriction of hazardous substances in electrical and electronic equipment
eur-lex.europa.eu4 citations
Referenced sections
  • Consolidated EU RoHS text used for EU scope, exclusions, homogeneous-material limits, exemptions, actor duties, technical documentation, EU declaration of conformity, and CE marking.
  • Articles 2 to 4 and 7 to 16 establish EU scope and exclusions, homogeneous-material limits, exemptions, economic-operator duties, technical documentation, EU declaration of conformity, and CE marking.
  • Binding EU source for categories and exclusions, homogeneous-material limits, Annex III and IV exemptions, economic operators, technical documentation, EU declaration of conformity, CE marking, and ten-year records.
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  • Article 7 requires technical documentation, conformity assessment, an EU declaration of conformity, CE marking, production controls, and retention for ten years.
Directive 2011/65/EU, consolidated text at 1 July 2026
eur-lex.europa.eu4 citations
Referenced sections
  • Current official EU RoHS consolidation used for live scope, substance, exemption, actor, and documentation decisions.
  • Current official consolidation used to verify the EU scope, homogeneous-material rule, operator duties, and Annex III and IV exemption text and dates.
  • Current official EU text for the ten Annex II limits, economic-operator duties, and application-specific exemptions and expiry dates.
Show 1 more
  • Current official consolidation for checking whether shared evidence still matches the applicable EU limit and exemption.
Measures for Restriction of Hazardous Substances in Electrical and Electronic Products
gov.cn4 citations
Referenced sections
  • Binding China source for product scope, actor duties, hazardous-substance information, environmental protection use period marking, catalogue management, and conformity assessment.
  • Articles 2, 3, and 9 to 18 establish the China scope, roles, marking and disclosure, catalogue, and conformity-assessment structure.
  • Binding China source for the product definition, actors, marking and disclosure, catalogue, and conformity-assessment structure.
Show 1 more
  • Supports the independent China product, actor, marking, disclosure, catalogue, and conformity decisions.
National Standard GB 26572-2025
openstd.samr.gov.cn2 citations
Referenced sections
  • Official implementation date for China's forthcoming mandatory ten-substance standard.
  • Official record showing publication on 1 August 2025 and implementation on 1 August 2027.

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