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CHINA ROHS COMPLIANCE

Conformity with China RoHS is mandatory for anyone introducing electrical or electronic equipment into China.

The Enviropass Approach for China RoHS Testing

You can choose two types of services for your China RoHS testing, declaration, and label logo symbol:

  • Classic
  • Deluxe

China RoHS vs EU RoHS: If you already have sufficient Europe RoHS technical documentation, Enviropass can reuse and adapt the information for China RoHS conformity at a fraction of the price.

Classic China RoHS

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 EU RoHS

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:

China RoHS Restricted Chemicals

Threshold Limits

Lead and lead compounds (Pb)

0.1% (weight/weight) *

Mercury and mercury compounds (Hg)

0.1% (w/w)

Cadmium and cadmium compounds (Cd)

0.01% (w/w) **

Hexavalent chromium and compounds (Cr VI+)

0.1% (w/w)

Polybrominated biphenyls (PBBs)

0.1% (w/w)

Polybrominated diphenyl ethers (PBDEs)

0.1% (w/w)

Four phthalates (BBP, DBP, DEHP, and DIBP), per the mandatory RoHS standard GB/T 26572-2025

0.1% (w/w)

* 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

Examples of EFUP marking symbols
Examples of EFUP marking symbols

If none of the restricted substances exceed threshold limits, the green ‘e’ EFUP symbol must appear on the product. However, the green color is optional.

e logo EFUP China RoHS

On the other hand, if any of the above-mentioned threshold limits are exceeded in the homogeneous materials level of a device, then:

  • An orange EFUP symbol must be marked on the product.  The orange color is also optional. The figure (5, 10, 15, 20, 25, etc.) on this symbol represents the number of years during which no hazardous substances would leak or mutate under normal conditions of use. The standard SJ/Z 11388-2009 – General Guideline of Environmental-friendly Use Period of Electronic Information Products – gives guidance on how to estimate this EFUP year period.
10 years EFUP logo China RoHS
  • 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’:

  • Air conditioners
  • Copiers
  • Electric water heaters
  • Fax machines
  • Handheld phones for mobile communication
  • Micro-computers
  • Monitors
  • Printers
  • Refrigerators
  • Telephone sets
  • TVs
  • Washing machines

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:

China RoHS compliance logos of Declarations of Conformity

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

China produces large quantities of electronics, which emit Volatile Organic Compounds (VOCs) into the atmosphere, contaminating the air.

To fight air pollution in China, the State Council of the People’s Republic of China has published a ‘three-year action plan to win the battle for a blue sky’. As a result, four mandatory standards targeting VOCs were published in 2020:

  • GB 30981-2020 – Limit of harmful substances of industrial protective coatings
  • GB 33372-2020 – Limit of volatile organic compounds content in adhesive
China Manufacturer Electronic air pollution
  • 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

Who must comply with China RoHS requirements?

Anyone who places electrical or electronic equipment on the Chinese market must comply with China’s hazardous substance restrictions. Authorities can detain non-compliant products at the border.

China RoHS and the EU directive share the same substance thresholds and restricted chemicals at the homogeneous material level. However, China RoHS focuses on disclosure, labeling, and EFUP marking rather than strict concentration bans.

Each product must display an EFUP symbol and include a RoHS table in Simplified Chinese. If restricted substances exceed thresholds, the product must show an EFUP year, a manufacturing year, and an “X” in the substance table.

GB 26572-2025 defines mandatory substance limits, labeling rules, and information disclosure requirements. The standard lists ten restricted substances and allows both physical and digital labeling formats, including QR codes.

GB 26572-2025 lists four phthalates as restricted substances. However, the China RoHS conformity assessment catalog limits mandatory substance restrictions to six substances, excluding phthalates.