Is China RoHS the same as EU RoHS? Direct 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 environmental protection use period 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.

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.

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.

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.