Article 19 identifies punishable conduct, but the Measures do not state one fine amount or penalty formula.
Determine exposure by matching the product, actor, violated duty, applicable standard or catalogue date, current competent authority, and separate legal basis for the sanction. Do not quote a fixed China RoHS fine from the Measures alone.
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The China RoHS Measures identify seven categories of violations by producers, importers, and sellers. Article 19 directs the competent commerce, customs, quality-supervision, and other departments to punish them according to law within their responsibilities, but it does not set a universal monetary fine. The controls when the seventh category can apply to a listed product.
Article 19 supplies the violation categories and connects each one to duties in Articles 10-17. It then assigns punishment to commerce, customs, quality-supervision, and other competent departments according to law within their respective responsibilities.
The Measures do not state a monetary amount, range, calculation method, automatic recall, or single sanction for every violation. A defensible penalty statement therefore needs the current enforcing authority and the separate law, regulation, standard, or procedure that authorizes the remedy in the specific case.
Start by confirming scope. The Measures apply to producing, selling, and importing covered electrical and electronic products within China. The product definition includes rated-voltage limits and excludes equipment for electrical-energy generation, transmission, and distribution.
Match the facts to the actor and underlying article. Producer, importer, and seller duties overlap in places but are not interchangeable. The seventh category has an additional timing condition: it applies to products in the from the relevant hazardous-substance restriction implementation date.
The 2026 catalogue took effect on 28 May 2026 and replaced the 2018 first-batch catalogue and exception list. The ten reorganised existing product groups continued without a new gap; the 23 newly added groups and newly added product scope generally enter the catalogue limit and conformity-assessment layer on 1 August 2027. Examples of newly added groups include microwave ovens, rice cookers, portable power banks, smart watches and bands, headphones, smart speakers, robot vacuum cleaners, servers, network switches and routers, electronic blood-pressure monitors, and hearing aids. Confirm the exact catalogue definition and implementation date rather than classifying from a marketing name.
Assess the issue in sequence. First identify the exact product, model, transaction, actor, and date. Then confirm China RoHS scope, the duty in force on that date, the applicable standard or catalogue entry, and the evidence of what occurred. Only then identify the current competent authority and the legal basis for a sanction.
Article 21 allows any organization or individual to complain or report a suspected violation to the relevant department. A report does not itself establish a violation or determine the sanction.
The Measures alone cannot determine a fine amount. The result can depend on the conduct, product, actor, date, applicable standard or catalogue rule, authority, procedural posture, and another law that supplies the sanction. This page therefore cannot calculate case-specific exposure.
Keep administrative enforcement separate from contractual supplier remedies, customer claims, voluntary or mandatory corrective action, customs consequences, product-quality liabilities, and duties under other environmental or market-access regimes. The same facts may matter under more than one regime, but the legal bases should not be merged.
Article 20 concerns administrative sanctions for government personnel who abuse authority, engage in favoritism or fraud, shield violations, or help a party evade investigation. It is not a fine schedule for producers, importers, or sellers.
The 2016 Measures do not state one fine amount, range, or calculation formula. Article 19 lists punishable conduct and directs competent departments to act according to law within their responsibilities. Determine any monetary or other sanction from the current authority and the separate legal basis applicable to the specific product, actor, conduct, and date.
Article 19 includes a seller-specific category for selling electrical or electronic products that violate applicable hazardous-substance national or industry standards. It also includes producers, sellers, and importers in the catalogue substance-limit category from the relevant restriction implementation date. The facts and applicable rule still determine whether a violation occurred.
No such protection is stated in the Measures. Supplier declarations, bills of materials, test evidence, and change records can help establish the product facts and the basis for a release decision, but they do not replace the statutory duties assigned to producers, importers, and sellers.
Map the product, actor, duty, date, evidence, current authority, and sanction basis before stating enforcement exposure.
Research Copilot connects the official citation, decision, owner, retained evidence, and change history.
Check the China RoHS scope decision and unresolved launch questions with Sorena.