CHINA ROHS COMPLIANCE
Conformity with China RoHS is mandatory for anyone introducing electrical or electronic equipment into China.
With Classic China RoHS, you allow Enviropass to take over documentary assessments of your products.
Enviropass will also prepare a table in Simplified Chinese for each substance to be examined, along with the recommendation of the applicable EFUP marking.
Deluxe China RoHS service shows you how to fish! Indeed, Deluxe China RoHS includes:
- Verifying products according to the requirements, preparing the RoHS table in Chinese and determining the applicable marking;
- Product assessment training that will allow you to analyze your new products yourself and to update your compliance statements as required (i.e., when design changes).
What does China RoHS Mean?
China RoHS (Restriction of Hazardous Substances), officially known as the Administrative Measure on the Control of Pollution Caused by Electronic Information Products, is a Chinese government regulation that restricts the use of certain hazardous substances in electrical and electronic products sold in China.
Aren't Europe and China RoHS the Same?
Complying with the European RoHS directive requirements is generally helpful. Indeed, both RoHS regulations share the same thresholds and the same controlled substances at the homogeneous material level:
* or 1000 parts per million (ppm)
** or 100 parts per million
However, this information alone does not establish compliance with the China RoHS regulation, i.e., Ministry of Industry and Information Technology MIIT Order #32 – Management Methods for the Restriction of the Use of hazardous Substances in Electrical and Electronic Products.
China RoHS primarily communicates hazardous substances above the threshold levels rather than limiting their concentrations.
Furthermore, every device placed in China requires a specific label and a RoHS table in Chinese, identifying restricted substances exceeding the general thresholds. If a product lacks the RoHS table or Environmental-Friendly Use Period (EFUP) label, authorities can easily identify non-compliance and retain the product at the border.
China RoHS Marking and Table
On the other hand, if any of the above-mentioned threshold limits are exceeded in the homogeneous materials level of a device, then:
- The product must bear a manufacturing year, marking the beginning of the EFUP year period.
- A table, similar to the above-mentioned one must appear in the product documentation. The X must be written in the table whenever a restricted substance exceeds a threshold in a sub-assembly; otherwise, an O must be written.
GB 26572-2025 Implementation
GB 26572-2025 defines the requirements for the restricted use of hazardous substances in electrical and electronic products in China. Accordingly, the standard combines substance limits, labeling rules, and information disclosure requirements into a single mandatory framework.
Additionally, the standard classifies products into two categories:
- Category I products appear in the China RoHS conformity assessment catalog and must meet both substance restriction limits and labeling requirements.
- Category II products do not appear in the catalog and must follow labeling and information disclosure requirements. These products may also align with substance limits voluntarily.
GB 26572-2025 lists ten restricted substances, including lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs, and four phthalates (BBP, DBP, DEHP, and DIBP). Moreover, the standard references the GB/T 39560 series, which aligns with IEC 62321, for testing and analysis of hazardous substances.
Furthermore, the standard allows both physical and digital labeling formats, including on-product marks, electronic displays, and QR codes, provided that users can easily access the required information.
China RoHS 2019
Additionally, since November 1st, 2019, the following product categories must meet the RoHS requirements of ‘The Implementation Arrangements for the Conformity Assessment System for the Restriction of Hazardous Substances in Electrical Appliances and Electronic Products’:
Similar to the EU RoHS, restrictions on lead, mercury, cadmium, hexavalent chromium, PBBs, and PBDEs apply to these product categories.
To show compliance, producers must either choose:
- The voluntary certification with a third-party certification body. Then, certified products are published on the ‘Public Service Platform for the Restriction of Hazardous Substances in Electrical Appliances and Electronic Product’
- Self-declaration, with the submission of technical documentation and declaration of conformity on the Public Service Platform.
It is important to distinguish between the general China RoHS substance list and the catalog-based conformity assessment requirements. Although GB 26572-2025 lists ten restricted substances, including four phthalates, the China RoHS conformity assessment catalog applies substance restrictions only to lead, mercury, cadmium, hexavalent chromium, PBBs, and PBDEs. Accordingly, the phthalates listed in GB 26572-2025 do not apply to the catalog products listed above.
Finally, depending on the adopted certification approach, compliant products must be marked with one of the following logos:
CNCA’s Role in China RoHS
China’s National Certification and Accreditation Administration (CNCA) plays a pivotal role in implementing and enforcing the China RoHS regulatory framework. CNCA acts as the central authority overseeing China’s conformity assessment system for electrical and electronic products. Its key responsibilities encompass:
- Developing and Managing Conformity Assessment Systems: CNCA establishes and maintains the frameworks for both voluntary and mandatory certification schemes related to hazardous substances in electrical and electronic products.
- Designating and Supervising Certification Bodies: It accredits and monitors testing laboratories and certification bodies that assess products for RoHS compliance, ensuring they meet national standards.
- Updating Testing Standards: In line with international practices, CNCA updates testing standards to align with global benchmarks. For instance, effective March 1, 2024, CNCA replaced the GB/T 26125 standard with the GB/T 39560 series, harmonizing China’s testing methods with the IEC 62321 series used in the EU RoHS directive.
- Publishing Compliance Guidelines: CNCA issues detailed guidelines on product labeling, documentation, and the list of products subject to mandatory compliance, known as the “Catalogue.”
In short, while the Ministry of Industry and Information Technology (MIIT) is the primary policymaker for China RoHS, the CNCA coordinates with the Standardization Administration of China (SAC) and other relevant bodies to align certification, testing, and conformity assessment protocols.
VOC Emissions from Electronic Manufacturers
- GB 38507-2020 – Limits of volatile organic compounds (VOCs) in printing ink
- GB 38508-2020 – Limits for volatile organic compounds content in cleaning agents
These standards are NOT part of China RoHS. However, they impose limitations not only on VOCs, but also on heavy metals, halogenated hydrocarbons, formaldehyde, Polycyclic Aromatic Hydrocarbons (PAHs), and other chemicals used in electronics production.
FAQ on China RoHS