Everything Businesses Need to Know About the China RoHS Update

China RoHS is expanding in several key ways. Many companies that were not previously in the directive’s scope will soon have to comply with the chemical regulation.

Kelsey Dozier

7 min read
Everything Businesses Need to Know About the China RoHS Update

Article Highlights:

  • Officially known as the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products, China RoHS is China's primary regulation restricting the use of hazardous substances in electrical and electronic products.
  • The publication of GB 26572-2025 last year represented one of the most substantial updates to China RoHS since the regulation was first introduced nearly two decades ago.
  • In addition to adding new categories to the product catalog, China RoHS has also expanded its list of restricted substances.

Manufacturers selling electrical and electronic products in China are facing the most significant changes to China RoHS in years. The latest regulatory updates expand both the lists of covered products and those of restricted substances. This means that many companies that previously fell outside the regulation's scope may soon have new compliance obligations.

In brief, the 2026 updates to China RoHS include:

  • The introduction of 23 new product categories.
  • The expansion of five existing categories.
  • The addition of four phthalates to the list of restricted substances.
  • Revisions to existing exemption.
  • A phased implementation timeline culminating in mandatory compliance beginning August 1, 2027, for newly covered products.

For global manufacturers, these changes make it increasingly important to maintain accurate material declarations, supplier documentation, and BOM-level visibility across products destined for the Chinese market.

This guide explains everything businesses need to know about the latest updates to China RoHS. It includes key compliance deadlines, explains how the impending changes differ from obligations under EU RoHS, and outlines steps manufacturers, suppliers, and importers should take now to help strengthen compliance moving forward.

What Is China RoHS?

China RoHS is China's primary regulation restricting the use of hazardous substances in electrical and electronic products. Officially known as the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products, the regulation is jointly administered by China's Ministry of Industry and Information Technology (MIIT) and several other government agencies.

Like the European Union's RoHS Directive, China RoHS aims to reduce environmental pollution and protect human health by limiting hazardous substances in electrical and electronic equipment (EEE).

The regulation originally entered into force in 2007. Since then, it has gradually expanded through revisions to:

  • Product catalogs
  • Restricted substances
  • Labeling requirements
  • Conformity assessment procedures
  • National testing standards

Unlike EU RoHS, however, China uses a phased catalog approach. Rather than applying substance restrictions to nearly all electrical and electronic equipment simultaneously, products become subject to full restriction requirements as they are added to the hazardous substances catalog. This means businesses must continually monitor whether their products have been added to the regulated catalog, not simply whether they manufacture electronics.

What Does the 2026 China RoHS Update Change?

The publication of GB 26572-2025 last year represented one of the most substantial updates to China RoHS since the regulation was first introduced nearly two decades ago.

Three major areas changed:

Expanded Product Catalog

The largest change is the expansion of the China RoHS catalog. The updated catalog adds:

  • 23 entirely new electrical and electronic product categories
  • 5 expanded existing categories

Newly covered items include the following product categories:

  • Consumer electronics
  • Household appliances
  • Information technology equipment
  • Communications equipment
  • Smart devices
  • Industrial electronics
  • Medical electronics
  • Wearable devices

For many manufacturers, products that previously required only environmental labeling may now become subject to full China RoHS compliance requirements.

Companies should carefully review product classifications to determine whether existing products now fall within the expanded catalog.

New Restricted Substances List

In addition to adding new categories to the product catalog, China RoHS has also expanded its list of restricted substances. Historically, China RoHS restricted the same six substances that formed the basis of the original EU RoHS Directive:

  • Lead (Pb)
  • Mercury (Hg)
  • Cadmium (Cd)
  • Hexavalent Chromium (Cr(VI))
  • Polybrominated Biphenyls (PBB)
  • Polybrominated Diphenyl Ethers (PBDE)

Under GB 26572-2025, however, four additional phthalates have been added. This expands the list from six chemicals to ten—nearly doubling the number of restricted substances:

  • Bis(2-ethylhexyl) phthalate (DEHP)
  • Butyl benzyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)

These are the same four phthalates already restricted under EU RoHS, bringing greater alignment between the two regulatory systems. In order to maintain compliance in the Chinese market, manufacturers will need supplier declarations and material data capable of identifying these substances throughout their supply chains.

Revised Exemption List

The updated regulation also revises the available exemptions for restricted substances. Although many exemptions remain similar to those available under EU RoHS, China maintains its own exemption framework, applicability criteria, and implementation schedule. Because of these distinctions, companies should avoid assuming that an exemption accepted under EU RoHS automatically applies under China RoHS. Each exemption should be reviewed independently against the current Chinese requirements.

Key China RoHS Compliance Deadlines

January 2026

Updated requirements were published through GB 26572-2025, introducing the expanded product catalog, updated restricted substances list, and revised exemptions.

August 2027

Mandatory enforcement begins for products covered under the expanded catalog. The phased timeline between the updated requirements and the August enforcement date gives manufacturers approximately eighteen months to carry out the following compliance measures:

  • Review affected product portfolios
  • Collect updated supplier information
  • Verify material compositions
  • Perform required testing
  • Complete conformity assessment activities
  • Update labeling and documentation

Organizations waiting until 2027 to begin preparations may find themselves facing significant supplier data gaps and testing bottlenecks.

China RoHS vs. EU RoHS: What's the Difference?

  • Product scope: China RoHS applies through a regulated product catalog, while EU RoHS applies broadly to nearly all electrical and electronic equipment.
  • Administering body: China RoHS is administered by MIIT and other Chinese authorities; EU RoHS is administered by ECHA and the European Commission.
  • Standards: China RoHS uses Chinese national standards (GB standards); EU RoHS uses harmonized European standards.
  • Labeling: China RoHS requires China-specific environmental labeling; EU RoHS requires CE marking and technical documentation.
  • Conformity assessment: China RoHS uses China-specific conformity assessment options; EU RoHS uses EU conformity assessment procedures.
  • Exemptions: Both maintain separate exemption frameworks with independent review processes.

Although substance restrictions have become increasingly aligned between EU RoHS and its Chinese counterpart, companies should not assume that achieving compliance with one directive automatically triggers adherence to the other.

There are still a number of key differences between the regulations. China maintains its own:

  • Product scope
  • Compliance documentation
  • Labeling rules
  • Testing standards
  • Certification pathways

Global manufacturers should evaluate each market—and its accompanying compliance responsibilities—independently.

What Industries and Products Are Affected?

China RoHS's expanded catalog significantly broadens the range of affected industries.

Examples of new product categories include:

  • Household appliances
  • Consumer electronics
  • Computers and IT equipment
  • Networking and telecommunications equipment
  • Servers and storage devices
  • Wearables and smart devices
  • Industrial electronic equipment
  • Medical and healthcare devices
  • Audio and video products
  • Smart home equipment

Because many electronic assemblies are incorporated into larger products, manufacturers should also evaluate subassemblies, control systems, printed circuit boards, displays, and electronic modules that may now fall within regulated categories. Suppliers throughout the electronics supply chain may receive increased requests for full material declarations (FMDs) and updated substance disclosures as manufacturers prepare for compliance.

How to Achieve China RoHS Compliance

Conformity Assessment Options

Products covered by China RoHS must complete an approved conformity assessment before entering the Chinese market.

Depending on the product category, manufacturers may be able to use:

  • Approved voluntary certification
  • Self-declaration pathways (where permitted)
  • Third-party testing and certification

The appropriate route depends on the product category and its specific regulatory requirements.

Testing Standards

Compliance verification typically relies on Chinese national standards, particularly the following:

  • GB/T 39560 series
  • IEC 62321 testing methods (referenced by the GB standards)

These standards provide analytical methods for determining concentrations of restricted substances within homogeneous materials. Manufacturers should ensure testing laboratories are familiar with the applicable Chinese requirements rather than relying solely on European testing documentation.

Labeling and Marking Requirements

China RoHS continues to require environmental protection use period labeling and other prescribed product markings.

Depending on the product, manufacturers may need to provide:

  • Environmental protection use period symbols
  • Hazardous substance disclosure tables
  • Product identification markings
  • Required documentation accompanying the product

Packaging, manuals, and product labels should all be reviewed to ensure compliance with current Chinese marking requirements.

Public Platform Disclosure Obligations

Manufacturers may also have obligations to submit compliance information through designated public disclosure platforms, depending on the specific conformity assessment process that applies to them.

Maintaining accurate product compliance records, supplier declarations, laboratory reports, and technical documentation will help support these disclosure requirements, while also reducing compliance risk during regulatory inspections.

For organizations looking for comprehensive compliance support for the updates to China RoHS, compliance tool Z2 provides extensive capabilities that streamline the entire adherence process.

To learn more about Z2's compliance services, schedule a free trial with one of our product experts.