--- title: "China RoHS penalties and enforcement exposure" canonical_url: "https://www.sorena.io/artifacts/apac/china-rohs-regulation/penalties-and-fines" source_url: "https://www.sorena.io/artifacts/apac/china-rohs-regulation/penalties-and-fines" author: "Sorena AI" description: "China RoHS Article 19 violations, responsible actors, enforcement boundaries, and why the Measures do not provide one universal fine amount." published_at: "2026-07-05" updated_at: "2026-07-24" keywords: - "China RoHS" - "Hazardous substances" - "Electrical and electronic products" - "Product compliance" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # China RoHS penalties and enforcement exposure China RoHS Article 19 violations, responsible actors, enforcement boundaries, and why the Measures do not provide one universal fine amount. *Product* *China* ## China RoHS RoHS penalties and enforcement exposure 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 Do not quote a fixed China RoHS fine from the Measures alone. 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 compliance-management catalogue controls when the seventh category can apply to a listed product. ## Definitions ### China RoHS compliance-management catalogue **Term:** compliance-management catalogue The compliance-management catalogue is the official China RoHS list that identifies product groups subject to the additional hazardous-substance limit and conformity-assessment layer, the substances covered, the implementation time, and applicable exceptions. The 2026 catalogue contains 33 product groups and replaced the 2018 first-batch catalogue on 28 May 2026. **Why it matters here:** Catalogue inclusion does not create the general China RoHS scope test. It changes when a covered product must also meet the listed substance limits and complete the national conformity-assessment route. Article 19's seventh violation category depends on the applicable catalogue implementation date. Sources: - [Measures for Restriction of Hazardous Substances in Electrical and Electronic Products](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - [MIIT Announcement No. 11 of 2026: Compliance Management Catalogue and Exceptions List](https://wap.miit.gov.cn/jgsj/jns/wjfb/art/2026/art_c8f5ccd5bd7e465c99ade198358d5ccc.html?ref=sorena.io) ## What Article 19 does and does not establish 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. - Do not treat every documentation gap as the same violation; identify the duty and actor named in the relevant article. - Do not apply the catalogue substance-limit violation before the applicable restriction implementation date. - Do not present a contractual charge, internal risk score, recall decision, or penalty under another law as a fine written in the Measures. - Do not assume that the authority names in a 2016 instrument settle current institutional responsibility; confirm the authority handling the specific conduct. Related resources: - [China RoHS covered-product scope](/artifacts/apac/china-rohs-regulation/covered-electrical-electronic-products.md): Confirm whether the product and China activity fall within the Measures before assessing a violation. Sources for this answer: - [Measures for Restriction of Hazardous Substances in Electrical and Electronic Products](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Articles 2 and 3 define territorial and product scope. Article 19 lists punishable conduct and refers punishment to competent departments acting according to law; it states no universal monetary amount or penalty formula. ## The seven violation categories by actor 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 compliance-management catalogue 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. - Producer - Article 10: uses materials, technologies, or processes that violate the applicable hazardous-substance national or industry standards, or releases or sells a product that does not meet the Measures. - Importer - Article 11: imports an electrical or electronic product that violates the applicable hazardous-substance national or industry standards. - Producer or importer - Article 12: makes or uses product packaging that violates the applicable national or industry packaging standards. - Producer or importer - Article 13: fails to mark the hazardous-substance name, content, component location, recyclability, and information about effects of improper use or disposal as required. - Producer or importer - Article 14: fails to mark the environmental protection use period as required. - Seller - Article 16: sells an electrical or electronic product that violates the applicable hazardous-substance national or industry standards. - Producer, seller, or importer - catalogue timing: from the applicable restriction implementation date, produces, sells, or imports a listed product whose hazardous-substance content exceeds the applicable national or industry limit standard. Related resources: - [China RoHS marking and disclosure evidence](/artifacts/apac/china-rohs-regulation/marking-and-disclosure-evidence.md): Review the Article 13-15 information, marking location, use-period decision, and supporting records. - [China RoHS deadlines and compliance calendar](/artifacts/apac/china-rohs-regulation/deadlines-and-compliance-calendar.md): Separate the Measures' effective date from catalogue implementation dates and product-release gates. Sources for this answer: - [Measures for Restriction of Hazardous Substances in Electrical and Electronic Products](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Article 19(1)-(7) supplies the seven categories; Articles 10-17 provide the underlying producer, importer, packaging, disclosure, use-period marking, seller, and catalogue duties. - [MIIT explanation of the 2026 compliance-management catalogue and exceptions list](https://www.miit.gov.cn/zwgk/zcjd/art/2026/art_5e3da83febf5461ca1b063165c660dea.html?ref=sorena.io) - Explains the 33 product groups, immediate continuation for reorganised existing groups, 1 August 2027 implementation for newly added groups and scope, and the need to apply each catalogue definition and exception. ## How to assess an enforcement issue 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. - Scope: record the product function, rated voltage, supporting-product status, excluded power-equipment analysis, and activity in China. - Actor: distinguish the producer, importer, and seller involved in the specific conduct. - Duty and timing: identify the underlying article, applicable standard, catalogue entry, restriction implementation date, and exception. - Facts: preserve the bill of materials, supplier declarations, test or analytical evidence, packaging, product markings, instructions, purchase and import records, sales records, and change history relevant to the allegation. - Authority and remedy: verify the department with current responsibility and the separate legal basis for any warning, correction order, confiscation, fine, recall, or other claimed action. - Response record: keep the allegation, factual findings, containment or correction steps, authority communications, decision, and closure evidence. Sources for this answer: - [Measures for Restriction of Hazardous Substances in Electrical and Electronic Products](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Articles 2-3, 9-19, and 21 support the scope, actor, duty, timing, enforcement, and complaint sequence. The recommended evidence and response record are operational controls, not prescribed forms in the Measures. ## Limits of a China RoHS penalty estimate 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. - A missing supplier declaration is not automatically one of Article 19's seven categories; test the underlying product, standard, marking, disclosure, or catalogue duty. - A supplier declaration or test report does not by itself transfer the producer's, importer's, or seller's statutory duty. - A government webpage posting date is not an enforcement or restriction implementation date unless the legal instrument says so. - China RoHS hazardous-substance controls should not be treated as the same regime as end-of-life electronic-waste recovery and disposal rules. ### What is the fine for a China RoHS violation? 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. ### Can a seller be liable even if the producer supplied the product? 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. ### Does keeping supplier evidence prevent enforcement? 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. Related resources: - [China RoHS supplier evidence checklist](/artifacts/apac/china-rohs-regulation/supplier-material-declaration-checklist.md): Collect the supplier and material records needed to test product facts and change impacts. - [China RoHS and China e-waste compared](/artifacts/apac/china-rohs-regulation/china-rohs-vs-china-e-waste.md): Separate pre-market hazardous-substance duties from end-of-life recovery and disposal controls. Sources for this answer: - [Measures for Restriction of Hazardous Substances in Electrical and Electronic Products](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Article 19 contains no monetary schedule; Article 20 addresses misconduct by government personnel; Article 21 provides the complaint and reporting right. *Operationalize the requirement* *Placement: Before primary sources* ## Prepare the China RoHS release evidence file Map the product, actor, duty, date, evidence, current authority, and sanction basis before stating enforcement exposure. - [Map official sources to evidence](/solutions/research-copilot.md): Research Copilot connects the official citation, decision, owner, retained evidence, and change history. - [Review the China route](/contact.md): Check the China RoHS scope decision and unresolved launch questions with Sorena. ## Primary sources - [Measures for Restriction of Hazardous Substances in Electrical and Electronic Products](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Primary official text for scope, actor duties, catalogue timing, the seven Article 19 violation categories, enforcement allocation, government-personnel misconduct, and complaint rights. - [Beijing market regulation reprint of China RoHS measures](https://scjgj.beijing.gov.cn/cxfw/flfgcxfw/cpzll/202006/t20200618_1928018.html?ref=sorena.io) - Official Beijing market-regulation reprint used as a second text of Articles 19-21 and the underlying duties. - [MIIT Announcement No. 11 of 2026: Compliance Management Catalogue and Exceptions List](https://wap.miit.gov.cn/jgsj/jns/wjfb/art/2026/art_c8f5ccd5bd7e465c99ade198358d5ccc.html?ref=sorena.io) - Binding current catalogue and exceptions announcement used to determine the product, substances, exception, and implementation time for Article 19's seventh category. - [MIIT explanation of the 2026 compliance-management catalogue and exceptions list](https://www.miit.gov.cn/zwgk/zcjd/art/2026/art_5e3da83febf5461ca1b063165c660dea.html?ref=sorena.io) - Official explanation of the 33 product groups and the different implementation timing for continuing and newly added catalogue scope. ## Related Topic Guides - [China RoHS compliance checklist](/artifacts/apac/china-rohs-regulation/checklist.md): Release checklist for China RoHS scope, actor duties, marking, disclosure, the 2026 catalogue, exceptions, conformity assessment, and transition dates. - [China RoHS deadlines and compliance calendar](/artifacts/apac/china-rohs-regulation/deadlines-and-compliance-calendar.md): China RoHS legal dates, product-release triggers, catalogue timing, and evidence to review before production, import, or sale in China. - [China RoHS FAQ](/artifacts/apac/china-rohs-regulation/faq.md): Practical China RoHS answers on product scope, actor duties, marking and disclosure, supplier evidence, the 2026 catalogue, the 2027 standard transition, EU RoHS, and e-waste. - [China RoHS marking and disclosure evidence](/artifacts/apac/china-rohs-regulation/marking-and-disclosure-evidence.md): How to choose and document China RoHS product marks, substance information, environmental protection use period, and catalogue evidence. - [China RoHS requirements](/artifacts/apac/china-rohs-regulation/requirements.md): China RoHS duties by actor, including product controls, packaging, marking, disclosure, the 2026 catalogue, exceptions, and conformity-assessment transitions. - [China RoHS supplier declaration template](/artifacts/apac/china-rohs-regulation/china-rohs-supplier-declaration-template.md): A voluntary China RoHS supplier declaration template with fields for part coverage, substances, evidence, exceptions, and change control. - [China RoHS supplier material declaration checklist](/artifacts/apac/china-rohs-regulation/supplier-material-declaration-checklist.md): A China RoHS checklist for supplier declarations, BOM mapping, substance evidence, catalogue status, and change control. - [China RoHS vs China e-waste rules](/artifacts/apac/china-rohs-regulation/china-rohs-vs-china-e-waste.md): Compare China RoHS product duties with China's separate recovery, treatment, processor-licensing, and end-of-life evidence requirements. - [China RoHS vs EU RoHS](/artifacts/apac/china-rohs-regulation/china-rohs-vs-eu-rohs.md): Compare China RoHS and EU RoHS scope, substance limits, exemptions, marking, conformity routes, actors, and evidence without treating one decision as proof of the other. - [Covered electrical and electronic products under China RoHS](/artifacts/apac/china-rohs-regulation/covered-electrical-electronic-products.md): Apply the China RoHS function, rated-voltage, China-activity, supporting-product, and electricity-system exclusion tests before checking the 2026 catalogue. - [Does China RoHS cover my electrical or electronic product?](/artifacts/apac/china-rohs-regulation/faq/does-china-rohs-cover-my-electrical-electronic-product.md): Start with the China RoHS legal definition and product facts. Keep a covered-product note before collecting supplier material declarations or preparing marking/disclosure evidence. - [How is China RoHS different from China e-waste rules?](/artifacts/apac/china-rohs-regulation/faq/how-is-china-rohs-different-from-china-e-waste-rules.md): China RoHS addresses hazardous substances, marking and disclosure before or during market placement; China e-waste rules address recovery and disposal at end of life. - [Is China RoHS the same as EU RoHS?](/artifacts/apac/china-rohs-regulation/faq/is-china-rohs-the-same-as-eu-rohs.md): No. China RoHS and EU RoHS overlap in substance control but use different scope rules, exclusions, actors, marking and disclosure outputs, conformity routes, and transition dates. - [What is China RoHS marking and disclosure evidence?](/artifacts/apac/china-rohs-regulation/faq/what-is-china-rohs-marking-and-disclosure-evidence.md): 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?](/artifacts/apac/china-rohs-regulation/faq/what-supplier-evidence-should-we-keep-for-china-rohs.md): 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. --- [Privacy Policy](https://www.sorena.io/privacy.md) | [Terms of Use](https://www.sorena.io/terms-of-use.md) | [DMCA](https://www.sorena.io/dmca.md) | [About Us](https://www.sorena.io/about-us.md) (c) 2026 Sorena AB (559573-7338). All rights reserved. Source: https://www.sorena.io/artifacts/apac/china-rohs-regulation/penalties-and-fines.md