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
Questions
4

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7

Cited legal and guidance references.

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Sorena AI
Published Jul 5, 2026
Updated Jul 24, 2026
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. 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.

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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 the national voluntary certification or supplier declaration routes and public-platform reporting.
  • 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.
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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.

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Question 4

China's current transition matters

GB 26572-2025 takes effect on 1 August 2027. It will make the ten-substance limits, marking, disclosure, testing, and technical-support-document requirements part of one mandatory national standard. 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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Operationalize the requirement

Prepare the China RoHS release evidence file

Sorena AI helps turn the answer to "Is China RoHS the same as EU RoHS?" into assigned controls and retained evidence.

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Map official sources to evidence

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Review the China route

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Primary sources

References and citations

National Standard GB 26572-2025
openstd.samr.gov.cn
Referenced sections
  • Official record showing publication on 1 August 2025 and implementation on 1 August 2027.
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