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China RoHS supplier material declaration checklist

Use this checklist to collect supplier evidence that can be traced from a material or component to the finished China model.

China RoHS does not prescribe a form. The producer or importer remains responsible for the finished product's marking, disclosure, applicable limit, and catalogue decisions.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Oct 15, 2026
4 sections5 primary sources
Overview

Before approving a China model, link every to the supplied part, manufacturing site, revision, material or component, and finished-product bill of materials. Collect facts for the six substances named in the 2016 Measures and, where the 2026 catalogue or the applicable standard requires them, the four named phthalates. A declaration is supporting evidence, not a government certificate or a substitute for the producer's or importer's finished-product decision.

Section 1

1. Confirm scope and the decision the evidence must support

The 2016 Measures apply to electrical and electronic products produced, sold, or imported in mainland China. A covered product relies on current or electromagnetic fields, or generates, transmits, or measures them, at rated voltage no more than 1,500 V DC or 1,000 V AC. Equipment for generating, transmitting, or distributing electrical energy is excluded from that definition.

Record whether the supplier evidence is needed for the general product marking and hazardous-substance disclosure, for a limit and conformity-assessment decision under the current catalogue, or for both. Catalogue status changes the limit and conformity route; it does not remove the general marking duty.

  • Identify the finished product, China model, producer or importer, manufacturing site, and release revision.
  • Match the product against the descriptions, boundaries, implementation dates, and exceptions in the 2026 Catalogue and Exception List.
  • For catalogue products, record whether the applicable date and conformity-assessment route require a state-promoted voluntary certification or result.
  • List each supplier part and revision used in the approved bill of materials; do not accept a company-wide policy statement as part-specific evidence.
Section 2

2. Collect a traceable declaration for each supplied item

A supplier may omit a China RoHS mark from a part, component, or raw material purchased for use in production, but MIIT's implementation guidance says the supplier must give the purchaser all information needed for the finished-product marking. This also covers production inputs purchased from outside China.

Ask for one conclusion per supplied item and substance. The six substances expressly named in the Measures are lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), and polybrominated diphenyl ethers (PBDE). The 2026 Catalogue also names dibutyl phthalate (DBP), diisobutyl phthalate (DIBP), benzyl butyl phthalate (BBP), and bis(2-ethylhexyl) phthalate (DEHP) for catalogue controls.

  • Identity: supplier legal name, actual manufacturer, manufacturing site, supplier part number, customer part number, description, revision, and covered date or lot range.
  • Coverage: each material, homogeneous test unit, component, subassembly, accessory, cable, battery, and other supplied item included in the declaration.
  • Substance result: substance name, reported concentration or limit conclusion, unit, affected material or component, and whether the result is measured, calculated, or based on upstream evidence.
  • Technical basis: report number and date, laboratory or data owner, sampling point, test method, applicable standard and amendment, and any uncertainty or untested location.
  • Exception: the exact entry and conditions relied on from the current Exception List; do not record a generic EU exemption as a China exception.
  • Authority and control: declarant name, role, signature or approval, declaration date, expiry or review date, and a commitment to notify the customer before a material, process, site, or evidence change.
  • Gap handling: mark missing or conflicting information as open. Do not convert an unknown result into an under-limit or compliant conclusion.
Section 3

3. Review the supplier evidence against the finished product

Reconcile the declaration set to the released bill of materials. A declaration that omits a component, covers a different site or revision, cites an obsolete exception, or cannot be tied to the China model leaves an evidence gap.

For a catalogue product, record the standard used for the conformity result. From 1 January 2026 through 31 July 2027, the official transition notice permits GB/T 26572-2011 with Amendment 1 or GB 26572-2025. From 1 August 2027, GB 26572-2025 applies. The corresponding parts of the GB/T 39560 series provide the test methods for these conformity-assessment activities.

  • Confirm that every released BOM line is covered by a declaration, test report, certificate, calculation, or documented risk-based evidence decision.
  • Compare substance and component results with the content table and mark planned for the finished product.
  • Check each claimed exception against the current China Exception List, its application, and its conditions.
  • For a catalogue product, retain the catalogue match, implementation date, conformity route, certificate or result, platform submission record, and standard edition.
  • Record open gaps, risk treatment, reviewer, decision date, approved China model and revision, and release authority.
Section 4

4. Set change triggers and keep the record current

An EU RoHS declaration can be supporting input, but it does not establish the China product's component-level disclosure, environmental protection use period, applicable Chinese standard, 2026 Catalogue status, or China conformity result.

Reopen the review before release when the supplier, manufacturing site, formulation, material, component revision, process, test basis, exception, standard, catalogue entry, artwork, instructions, or finished China model changes.

  • Require suppliers to notify the responsible product-compliance owner before implementing a covered change.
  • Link each notice to an impact assessment, updated declaration or test evidence, BOM revision, and release decision.
  • Review open-ended declarations on a defined cycle and sooner when a legal, catalogue, exception-list, or standards change affects the product.
  • Keep superseded evidence with its effective range so investigators can reconstruct which declaration supported each released unit or batch.
Operationalize the requirement

Prepare the China RoHS release evidence file

Sorena AI helps connect China RoHS supplier evidence to product decisions, owners, controls, and review records.

Research workflow
Map official sources to evidence

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

Explore next step
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

MIIT Announcement No. 11 of 2026: Catalogue and Exception List
wap.miit.gov.cn3 citations
Referenced sections
  • Current catalogue, controlled-substance set, exception framework, and replacement of the 2018 catalogue.
  • The announcement replaced the 2018 first-batch catalogue and exception list on 28 May 2026 and identifies ten controlled substances for catalogue products, subject to the catalogue's product-specific timing and exceptions.
  • Names the ten substances controlled for catalogue products and makes the current Exception List part of the product-specific limit decision.
MIIT Order No. 32: Measures for Restriction of Hazardous Substances in Electrical and Electronic Products
miit.gov.cn3 citations
Referenced sections
  • Binding 2016 Measures for scope, actor duties, marking and disclosure, environmental protection use period, catalogue controls, conformity assessment, and penalties.
  • Articles 2, 3, 13-18 establish mainland-China scope, the electrical and electronic product definition, marking and disclosure duties, and the separate catalogue and conformity-assessment system.
  • Articles 10-18 place the finished-product duties on producers, importers, and sellers; a supplier record does not transfer those duties or decide a changed product's status.
MIIT implementation FAQ for Order No. 32
miit.gov.cn2 citations
Referenced sections
  • Official guidance on evidence bases, supplier information transfer, marking, component grouping, and environmental protection use period.
  • Questions 27 and 31 describe acceptable information bases and require upstream suppliers of production parts, components, and raw materials to pass the purchaser all information needed for marking, even when the supplied input is not itself marked.
SAMR and MIIT Announcement No. 44 of 2025 on applicable conformity standards
samr.gov.cn2 citations
Referenced sections
  • Current conformity-assessment standards, transition dates, conversion rules, and test-method series.
  • Sets the 2026-2027 transition between GB/T 26572-2011 with Amendment 1 and GB 26572-2025, the conversion dates for continuing products, and use of the corresponding GB/T 39560 test methods.
MIIT interpretation of the 2026 Catalogue and Exception List
miit.gov.cn
Referenced sections
  • Explains that catalogue products use national voluntary certification or self-declaration, with results uploaded to the China RoHS public service platform, and distinguishes immediate coverage from the 1 August 2027 date for newly added or expanded product coverage.

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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.