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What supplier evidence should we keep for China RoHS? Direct answer

Keep supplier declarations and test evidence traceable to the exact part, material, manufacturing site, revision, substance conclusion, and finished China model.

Supplier data supports the producer's or importer's product-level decision. The 2016 Measures do not prescribe a supplier declaration form or a general retention period.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Jul 24, 2026
Questions
3

Structured answer sets in this page tree.

Primary sources
6

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Jul 5, 2026
Updated Jul 24, 2026
Overview

Keep that connect supplier material declarations, test or analytical evidence where needed, bill-of-material links, change notices, gap reviews, and approvals to the exact China product model.

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3 of 3 questions
Question 1

Short answer

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 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 responsible producer for a catalogue product 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.

Citations
Question 2

Minimum supplier evidence record

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.

  • Supplier legal name, manufacturing site, part number, and revision.
  • Material or test-unit mapping for each substance conclusion, at the level required by the applied limit or test method.
  • Declaration, test report, analytical method, laboratory identity, sample identity, date, result, applied standard, and any exception basis.
  • Finished-product bill-of-material revision and exact China model mapping.
  • Review of missing substances, ambiguous thresholds, expired exceptions, model mismatch, and conflicting evidence.
  • Approval owner, open gaps, supplier change-notification commitment, and refresh trigger.
Citations
MIIT Explanation of GB 26572-2025

Official explanation that China RoHS technical support may include raw-material and component test reports or supply-chain compliance evidence and that the forthcoming mandatory standard requires traceable technical support documents.

MIIT implementation FAQ for the China RoHS Measures

Official guidance identifies upstream self-declaration information and supporting technical documents, valid product test reports, testing by the enterprise or a third party, and valid third-party certification as possible evidence inputs, with the relevant party responsible for truth and validity.

Question 3

When to refresh the file

Reassess supplier evidence when the supplier, site, material, formulation, sub-tier source, part revision, manufacturing process, applicable standard, catalogue status, exception, or finished model changes. Also reopen the record when incoming inspection, testing, or market feedback conflicts with the supplier's conclusion.

From 1 January 2026 through 31 July 2027, catalogue-product conformity assessment may use GB/T 26572-2011 with Amendment 1 or GB 26572-2025. GB 26572-2025 becomes mandatory on 1 August 2027. The transition adds a concrete reason to check whether older supplier evidence covers the four added phthalates: DEHP, BBP, DBP, and DIBP.

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Prepare the China RoHS release evidence file

Sorena AI helps turn the answer to "What supplier evidence should we keep for China RoHS?" into assigned controls and retained evidence.

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Map official sources to evidence

Research Copilot connects the official citation, decision, owner, retained evidence, and change history.

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Primary sources

References and citations

MIIT Explanation of GB 26572-2025
miit.gov.cn
Referenced sections
  • Official explanation that China RoHS technical support may include raw-material and component test reports or supply-chain compliance evidence and that the forthcoming mandatory standard requires traceable technical support documents.
MIIT implementation FAQ for the China RoHS Measures
miit.gov.cn
Referenced sections
  • Official guidance identifies upstream self-declaration information and supporting technical documents, valid product test reports, testing by the enterprise or a third party, and valid third-party certification as possible evidence inputs, with the relevant party responsible for truth and validity.
National Standard GB 26572-2025
openstd.samr.gov.cn
Referenced sections
  • Official record showing that GB 26572-2025 was published on 1 August 2025 and will take effect on 1 August 2027.
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