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China RoHS marking and disclosure evidence

Choose the China RoHS mark from the product's substance result, then retain the content table, use-period rationale, artwork, and applicable-standard evidence.

Articles 13-15 require the producer or importer to communicate hazardous-substance information and, when applicable, an . The current marking standard controls the symbol and table format.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Oct 15, 2026
4 sections7 primary sources
Overview

For a covered product placed on the mainland-China market, first compare the product's hazardous-substance results with the applicable limit standard and apply the current SJ/T 11364-2024 marking standard. MIIT's implementation guidance for the preceding 2014 edition explains the two practical paths: an when every covered substance is within the limits, or a numbered mark and component-level content table when a covered substance exceeds a limit. Use the current standard for the released presentation and keep catalogue conformity assessment as a separate decision.

Section 1

1. Confirm the product and responsible actor

The 2016 Measures apply to electrical and electronic products produced, sold, or imported in mainland China. The definition covers equipment and supporting products that rely on current or electromagnetic fields, or generate, transmit, or measure them, at rated voltage no more than 1,500 V DC or 1,000 V AC. It excludes equipment for generating, transmitting, or distributing electrical energy.

The producer or importer is responsible for the product's hazardous-substance mark and information. Catalogue inclusion adds limit and conformity-assessment duties, but MIIT states that products must carry the required hazardous-substance information and use the correct mark whether or not they are in the catalogue.

SJ/T 11364-2024 took effect on 1 April 2025 and replaced SJ/T 11364-2014. Treat the Measures as the binding source of the marking duty, the current standard as the controlling technical presentation, and MIIT's implementation FAQ for the 2014 edition as official guidance for the mark-selection and information-transfer explanations it contains.

  • Record the finished China model, product revision, producer or importer, manufacturing date, and released BOM.
  • Document the scope rationale, including rated voltage and any claimed exclusion.
  • Match the model to the product descriptions and timing in the 2026 Catalogue and the current Exception List.
  • Identify the substance standard, amendment, test basis, and conformity period used for the marking decision.
Section 2

2. Choose the mark and content-table output

MIIT's implementation guidance for SJ/T 11364-2014 describes two paths. If every covered substance is at or below the applicable GB/T 26572 limit, it directs the producer or importer to apply the and does not require the hazardous-substance content table for that path. If any covered substance exceeds a limit, it directs the producer or importer to apply the numbered mark and provide the content table. SJ/T 11364-2024 now controls the released marking presentation, so verify the current edition rather than treating the older FAQ as the standard itself.

For the numbered-mark path, identify affected components clearly. MIIT guidance says component grouping should cover all constituent parts and should generally use a single component or group of the same type. It does not permit 'other' as a catch-all component name. In the current table convention, an over-limit result is marked with X; the table may be expanded with more information but the required information cannot be removed or obscured.

  • Substance map: connect each result to the material, component, evidence record, standard, amendment, and released BOM line.
  • path: retain the evidence showing that all covered results meet the applicable limits and the approved mark artwork.
  • Numbered-mark path: retain the over-limit component results, decision, content table, use conditions, and approved artwork.
  • Placement: put the required information on the product. If product size, shape, surface material, or function prevents this, place it in the product instructions as allowed by Articles 13 and 14.
  • Appearance: keep the mark clear, durable, and readily identifiable. SJ/T guidance treats green and orange as recommended colors rather than mandatory colors; do not alter the required mark geometry or meaning.
  • Do not treat an EU RoHS declaration, CE mark, recycling symbol, or supplier statement as the finished-product China RoHS mark.
Section 3

3. Determine the environmental protection use period

The is the period during which hazardous substances in the product will not leak or suddenly change under normal use in a way that causes serious environmental pollution or serious personal or property damage. It is not a warranty, storage life, general service life, or statement that the product will remain functional for the marked number of years.

The producer or importer determines the period. MIIT guidance states that it begins on the product's manufacturing date. Where a numbered mark is used, the product instructions should state the normal-use conditions that support the period and explain any specially marked supporting part.

  • Record the selected period, unit, manufacturing-date rule, responsible producer or importer, and approval date.
  • Document the method, product category, expected normal-use conditions, temperature or environmental assumptions, maintenance assumptions, and evidence supporting the period.
  • Check whether an industry association's guidance applies; such guidance can inform the method but does not replace the producer's or importer's decision.
  • Align the number in the product mark, the instructions, supporting-part information, and the controlled artwork file.
  • Reassess the period when a material, component, supplier, process, use condition, or product design change affects the underlying assumptions.
Section 4

4. Record catalogue status, transition dates, and release evidence

The 2026 Catalogue and Exception List replaced the 2018 versions on 28 May 2026. Existing catalogue product coverage continued immediately; newly added product types and expanded portions of existing categories become subject to the catalogue controls on 1 August 2027. Check the attachment's product definition and implementation date rather than relying on the category name alone.

For catalogue conformity assessment from 1 January 2026 through 31 July 2027, the official transition notice permits GB/T 26572-2011 with Amendment 1 or GB 26572-2025. GB 26572-2025 becomes mandatory on 1 August 2027 and formally replaces GB/T 26572-2011; it also incorporates marking requirements currently addressed by SJ/T 11364-2024. It covers the six substances named in the Measures plus DBP, DIBP, BBP, and DEHP.

  • Keep the scope rationale, released BOM, supplier declarations, test or analytical evidence, and applicable exception assessment.
  • Keep the mark-selection worksheet, rationale, content table, product or instruction placement decision, and approved artwork version.
  • For a catalogue product, keep the matched entry, implementation date, conformity route, certificate or self-declaration result, platform submission record, standard edition, and conversion plan.
  • Record reviewer, approval date, approved model and revision, unresolved conditions, and every change trigger.
  • Reapprove the output when a material, component, supplier, substance conclusion, use-period assumption, product surface, instructions, standard, catalogue status, or China model changes.
Operationalize the requirement

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Primary sources

References and citations

MIIT Order No. 32: Measures for Restriction of Hazardous Substances in Electrical and Electronic Products
miit.gov.cn4 citations
Referenced sections
  • Binding requirements for scope, hazardous-substance information, environmental protection use period, catalogue controls, conformity assessment, and actor duties.
  • Articles 2, 3, and 13-18 establish mainland-China scope, the product definition, producer and importer duties, marking, environmental protection use period, and the separate catalogue system.
  • Articles 13 and 14 require hazardous-substance information and environmental protection use period marking under the applicable marking standard and allow instructions when the product cannot carry the information for the specified physical or functional reasons.
Show 1 more
  • Article 3(6) defines environmental protection use period; Articles 14 and 15 require marking and assign the determination to the producer or importer.
MIIT implementation FAQ for Order No. 32
miit.gov.cn3 citations
Referenced sections
  • Official guidance for mark selection, content tables, component grouping, placement, environmental protection use period, and supplier evidence.
  • Questions 36-44 explain the e-mark and numbered-mark paths, content-table convention, component grouping, color flexibility, minimum mark treatment, and allowed additions to the table.
  • Questions 28 and 44 state that the period starts on the manufacturing date and explain the normal-use conditions and supporting-part information associated with the numbered mark.
SJ/T 11364-2024: marking requirements
std.samr.gov.cn3 citations
Referenced sections
  • Official record for the current marking standard, effective 1 April 2025.
  • Official standards record showing that SJ/T 11364-2024 took effect on 1 April 2025 and replaced SJ/T 11364-2014.
  • Official record for the current marking standard and its 1 April 2025 implementation date.
MIIT Announcement No. 11 of 2026: Catalogue and Exception List
wap.miit.gov.cn2 citations
Referenced sections
  • Current catalogue, ten-substance control set, product timing, and exception framework.
  • Replaced the 2018 catalogue and exception list on 28 May 2026, names ten substances for catalogue controls, and contains the current product entries, timing, and exceptions.

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Keep the approved China RoHS mark or instructions, hazardous-substance disclosure, environmental protection use period rationale, technical support, and release approval for the exact model.

What supplier evidence should we keep for China RoHS?

Keep supplier declarations and test evidence traceable to the exact part, material, site, revision, substance conclusion, and finished China model. Supplier data supports, but does not replace, the product-level China RoHS decision.