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What is China RoHS marking and disclosure evidence? Direct answer

Keep the approved China-facing mark or instructions, the hazardous-substance disclosure, and the technical record that supports both outputs for the exact product model.

Articles 13 and 14 place separate information and duties on producers and importers. Catalogue conformity assessment is an additional layer.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Oct 15, 2026
3 sections6 primary sources
Overview

China RoHS marking and disclosure evidence is the controlled record linking the exact product model to its hazardous-substance information, , approved mark or instructions, supporting technical data, and release approval.

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3 of 3 questions
Question 1

Short answer

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 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.

Question 2

What the release file should contain

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

  • Exact China model, configuration, bill-of-material revision, producer or importer, and release date.
  • Component-level substance map supporting each disclosed substance name, content, location, recyclability statement, and impact statement.
  • value, calculation or assessment method, assumptions, responsible producer or importer, and approval.
  • Applicable marking standard and edition, plus the approved product artwork, electronic display, packaging, or instruction revision.
  • Documented reason for using instructions instead of an on-product mark when size, shape, surface material, or function prevents product marking.
  • Catalogue match, exceptions review, substance-limit conclusion, and conformity-assessment record when the product enters that additional layer.
  • Change triggers for supplier, material, component, design, model, marking standard, catalogue status, or published instructions.
Question 3

Current transition to GB 26572-2025

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, allowing sales through 31 July 2028. Keep production or import dates and inventory status with the approved marking and disclosure revision when relying on that transition.

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Primary sources

References and citations

Measures for Restriction of Hazardous Substances in Electrical and Electronic Products
gov.cn3 citations
Referenced sections
  • Binding source for hazardous-substance information, environmental protection use period marking, fallback to instructions, catalogue management, and conformity assessment.
  • Articles 13 to 15 establish the hazardous-substance information, fallback to product instructions, environmental protection use period marking, and responsibility for determining that period.
  • Articles 13 to 18 support the required product information, marking, producer or importer responsibility, and separate catalogue/conformity assessment decision. The evidence-file fields listed here are operational controls, not a prescribed government form.
MIIT briefing on implementation of GB 26572-2025
miit.gov.cn2 citations
Referenced sections
  • Official explanation of the standard's marking and traceability requirements, 1 August 2027 implementation, and one-year inventory sell-through period.
  • Official explanation of the 1 August 2027 implementation date and the inventory sell-through period for products produced or imported before that date, allowing sales through 31 July 2028.
National Standard GB 26572-2025
openstd.samr.gov.cn2 citations
Referenced sections
  • Official status and implementation date for the mandatory standard that will govern substance limits, marking, disclosure, testing, and technical support documents from 1 August 2027.
  • Official standard record showing publication on 1 August 2025 and implementation on 1 August 2027.
SJ/T 11364-2024 official standards record
std.samr.gov.cn2 citations
Referenced sections
  • Current recommended industry marking standard, effective from 1 April 2025.
  • Official record showing that the current recommended industry marking standard took effect on 1 April 2025 and replaced SJ/T 11364-2014.
MIIT Explanation of GB 26572-2025
miit.gov.cn
Referenced sections
  • Official explanation of the forthcoming mandatory standard's marking, hazardous-substance disclosure, and technical-support-document requirements, including use of digital methods such as QR codes or electronic displays.

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