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China RoHS requirements

China RoHS duties by actor, including product controls, packaging, marking, disclosure, the 2026 catalogue, exceptions, and conformity-assessment transitions.

Apply two layers: the general duties under the 2016 Measures for covered products, then the additional limits, exception list, implementation date, and for products in the 2026 .

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

China RoHS duties vary by actor. First confirm that the product and China activity are in scope. Then assign the Measures' duties to the designer, producer, importer, and seller. Producers and importers must handle product information and environmental protection use period marking; catalogue products also enter the current substance-limit and conformity-assessment route.

Section 1

The two compliance layers

The 2016 Measures apply to produced, sold, or imported in China when they meet the function and rated-voltage definition. The general layer covers design, production, import, sale, packaging, hazardous-substance information, and environmental protection use period marking. Absence from the catalogue does not remove this layer.

The second layer applies when the exact product falls within a product name, range, and implementation date in the 2026 . That layer adds substance limits for ten listed substances, the current exception list, and the national conformity-assessment system.

  • General-layer substances: the Measures name lead and its compounds, mercury and its compounds, cadmium and its compounds, hexavalent chromium compounds, PBB, PBDE, and other hazardous substances designated by the state.
  • Catalogue-layer substances: the 2026 catalogue identifies lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DBP, DIBP, BBP, and DEHP.
  • Current catalogue: 33 product groups. Ten continuing groups remained subject to the catalogue route on 28 May 2026; 23 new groups and expanded ranges generally enter it on 1 August 2027.
  • Current marking standard: SJ/T 11364-2024 has applied since 1 April 2025.
  • Current limit-standard transition: through 31 July 2027, use amended GB/T 26572-2011 or GB 26572-2025 for catalogue ; GB 26572-2025 applies from 1 August 2027.
Section 3

Required market information and supporting evidence

Article 13 requires producers and importers to identify hazardous substances in marketed products under the applicable marking standard. The information includes the substance name, content, component location, whether the product can be recycled, and environmental or health effects from improper use or disposal.

Articles 14-15 require the producer or importer to determine and mark the environmental protection use period. This is the period during normal use in which the contained hazardous substances will not leak or suddenly change so as to cause serious pollution or serious personal or property damage. It is not a warranty or product service-life statement.

  • Keep the exact China model and revision, scope decision, legal actor map, and applicable standards.
  • Keep the approved product mark, substance information, environmental protection use period rationale, product instructions, and packaging review.
  • Keep the BOM, supplier declarations, test reports, risk-based evidence rationale, and mapping from each item to the finished-product conclusion it supports.
  • For a catalogue product, keep the exact catalogue row, implementation date, ten-substance assessment, each relied-on exception, conformity result, and platform record.
  • The Measures do not specify a universal retention period for this internal file. Record a retention rule that supports continued market activity and investigations.
Section 4

Exceptions, transitions, and change control

Do not treat an application as exempt merely because a similar exemption exists under EU RoHS. Use only the current China exception list and document how the product meets the listed application, conditions, and any time limit.

Reassess before release after a change to function, rated voltage, China activity, legal actor, material, component, supplier, process, model, mark, instructions, catalogue, exception list, standard, conformity result, or implementation date.

  • Do not skip the general layer for a product outside the catalogue.
  • Do not rely on the superseded 2018 catalogue or exception list after 28 May 2026.
  • Do not use unamended GB/T 26572-2011 for 2026 ; a product assessed only to that version and still leaving the factory or being imported must convert before 1 January 2027.
  • Keep China RoHS distinct from end-of-life rules, general product-safety certification, and EU RoHS.
Build the evidence file

Prepare the China RoHS release evidence file

Sorena AI helps map each China RoHS duty to the responsible actor, product evidence, release decision, and change trigger.

Research workflow
Map official sources to evidence

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

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Talk to Sorena
Review the China route

Check the China RoHS scope decision and unresolved launch questions with Sorena.

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Primary sources

References and citations

Measures for Restriction of Hazardous Substances in Electrical and Electronic Products
miit.gov.cn4 citations
Referenced sections
  • Binding source for scope, substances named in the Measures, actor duties, product information, environmental protection use period, catalogue structure, conformity assessment, and violation categories.
  • Articles 2-3 establish scope and the substances named in the Measures; Articles 9-18 establish general actor duties and the additional catalogue and conformity layers.
  • Articles 9-16 assign the stated designer, producer, importer, producer/importer, and seller duties.
Show 1 more
  • Article 3 defines the environmental protection use period; Articles 12-15 establish packaging, information, marking, instructions fallback, and responsibility for determining the period. The Measures do not name the listed internal evidence forms or a universal retention period.
SJ/T 11364-2024: marking requirements
std.samr.gov.cn2 citations
Referenced sections
  • Current marking-standard record.
  • Official record for the current marking standard, effective 1 April 2025.

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Covered electrical and electronic products under China RoHS

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?

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?

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?

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?

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.