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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.

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 addresses design and materials, applicable substance standards, packaging, hazardous-substance information, environmental protection use period marking, seller controls, and a catalogue-based limit and conformity-assessment layer.

The e-waste Regulation applies to products in the Waste Electrical and Electronic Product Disposal Catalogue after they become waste. It establishes recovery and centralised treatment controls, producer information duties, and qualification requirements for treatment operators. Although Article 7 established a treatment-fund payment duty, collection of that fund stopped on 1 January 2024 and central special-fund support replaced subsidies for newly treated products. A China RoHS conclusion does not decide whether the waste-product catalogue or treatment rules apply.

Repair, refurbishment, and resale after repair or refurbishment are outside the e-waste regulation's treatment definition. A repaired product sold as second-hand goods must still meet the applicable mandatory health and safety specifications and be visibly identified as second-hand. If a recovery business dismantles or otherwise treats a catalogue product, it must hold the treatment qualification; without that qualification, it must transfer the recovered product to a qualified treatment enterprise.

For China RoHS, the main release actors are designers, producers, importers, and sellers. For e-waste treatment, the key actors include producers, recovery operators, and qualified treatment enterprises. A company may hold duties under both regimes, but the duty must be traced to the correct role and lifecycle stage.

The China RoHS file should record scope, actor, substance and marking conclusions, catalogue status, applicable standard, conformity assessment, and release approval. The e-waste file should record the waste-catalogue trigger, responsible actor, recovery or treatment route, qualified operator where required, environmental records, and approval.

Do not treat the environmental protection use period as a warranty, a mandatory disposal date, or a substitute for e-waste duties. Under the China RoHS Measures, it is the period during normal use in which contained hazardous substances will not leak or suddenly change so as to cause serious environmental pollution or serious harm to people or property.

Reopen the China RoHS file when the model, function, voltage, material, supplier, actor, scope-exclusion facts, standard, catalogue entry, exception, or implementation date changes. Reopen the end-of-life file when waste status, treatment-catalogue coverage, collector, transfer route, treatment method, licence category, facility, equipment, or authorised capacity changes.

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.

For a covered product placed on the China market, the producer or importer must disclose the hazardous-substance name, content, component location, recyclability, and potential effects of improper use or disposal on the environment and human health. If product size, shape, surface material, or function prevents product marking, the information must appear in the product instructions.

The producer or importer must also mark the environmental protection use period under the applicable marking standard. The producer or importer determines that period; an industry body may issue guidance on product categories, methods, and periods.

SJ/T 11364-2024 is the current recommended industry marking standard. It took effect on 1 April 2025 and replaced SJ/T 11364-2014. Record the edition used for the released model; GB 26572-2025 will combine the limit, marking, disclosure, testing, and technical-support requirements in one mandatory national standard from 1 August 2027.

The Measures state the required outputs but do not prescribe a single evidence-file format or general retention period. Build technical support documents that let a reviewer trace each public statement and mark to the product configuration and supporting data.

GB 26572-2025 was published on 1 August 2025 and takes effect on 1 August 2027. It combines substance limits, marking, disclosure, testing, and technical-support-document requirements in one mandatory national standard and covers ten substances, including four phthalates.

Do not label the 2027 requirements as already mandatory. During the transition, record which accepted standard route supports the release. For conformity-assessment activity, the November 2025 joint announcement permits GB/T 26572-2011 with Amendment 1 or GB 26572-2025 from 1 January 2026 through 31 July 2027; GB 26572-2025 is required from 1 August 2027.

MIIT's official implementation explanation gives products produced or imported before 1 August 2027 a one-year inventory sell-through period, ending on 1 August 2028. Keep production or import dates and inventory status with the approved marking and disclosure revision when relying on that transition.

For each supplied part or material, keep the supplier's legal name, manufacturing site, part number, revision, covered materials, substance conclusion, supporting method, applicable standard, declaration date, authorised signatory, and change-notification commitment.

Map that evidence through the controlled bill of materials to the exact finished China model. A supplier declaration or EU RoHS document can be an input, but it does not establish the finished product's China marking, environmental protection use period, catalogue status, exception, or conformity-assessment conclusion.

Treat the nationally recognised finished-product self-declaration as a separate conformity output. It is completed by the catalogue product's supplier, which can include the producer or an authorised representative, and supported by evidence such as raw-material or component reports and supply-chain compliance records; a component supplier's declaration does not replace it.

Use a risk-based evidence package. A signed declaration may be enough for a low-risk, well-characterised material when its scope and basis are clear. Seek more specific analytical or test support when the declaration is incomplete, the material is high risk, supplier controls are weak, the result conflicts with other data, or the applicable standard or conformity route requires it. Record the reason for accepting the evidence or escalating to testing.