China RoHS

Requirements for Restricted Use of Hazardous Substances in Electrical and Electronic Products (GB 26572-2025)

10 Restricted Substances. Mandatory Standard by August 2027. Your Suppliers Still Have 6-Substance Declarations.

China RoHS now restricts 10 hazardous substances—including four phthalates added January 1, 2026. The new mandatory standard GB 26572-2025 takes effect August 2027. Every product sold in China requires EFUP labeling and hazardous substance tables in Simplified Chinese. Certivo automates substance verification, supplier declaration collection, and China RoHS documentation—so you maintain market access.

Regulation Overview

• Jurisdiction: People's Republic of China
• Regulatory Body: MIIT (Ministry of Industry and Information Technology), SAMR, CNCA
• Regulation Number: GB 26572-2025 (mandatory Aug 2027); GB/T 26572-2011 + Amendment 1 (current)
• Effective Date: July 1, 2016 (RoHS 2); January 1, 2026 (phthalates); August 1, 2027 (mandatory standard)
• Official Source: MIIT Order No. 32 (2016); GB 26572-2025
• Key Threshold: 0.1% (1000 ppm) for most substances; 0.01% (100 ppm) for cadmium

What is China RoHS?

China RoHS restricts hazardous substances in electrical and electronic products (EEPs) sold in the Chinese market. The regulation operates on a two-tier system: catalogued products require substance limits and conformity assessment, while all other EEPs must comply with labeling requirements.

As of January 1, 2026, China RoHS restricts 10 substances—matching EU RoHS. The four phthalates (DEHP, BBP, DBP, DIBP) join the original six substances. The new mandatory standard GB 26572-2025 consolidates substance limits and labeling into a single enforceable framework.

Key Components / Sub-Frameworks

Key Compliance Requirements

• Who Must Comply:
  • Manufacturers producing EEPs for the Chinese market
  • Importers bringing EEPs into China
  • Distributors and brand owners selling EEPs in China
  • Foreign companies selling through Chinese distributors or e-commerce
  • Component suppliers providing parts for catalogued products
  • Online platforms facilitating EEP sales

Key Thresholds

• 0.1% (1000 ppm): Maximum concentration for Pb, Hg, Cr6+, PBB, PBDE, DEHP, BBP, DBP, DIBP
• 0.01% (100 ppm): Maximum concentration for cadmium (Cd)
• Homogeneous Material: Concentration measured at material level, not product level
• 12 Categories: Products requiring mandatory conformity assessment

Core Obligations

1. 10-Substance Compliance
   Meet concentration limits for all 10 restricted substances
   Deadline: January 1, 2026 (phthalates)
2. EFUP Labeling
   Mark products with Environmental Friendly Use Period
   Deadline: All EEPs—ongoing
3. Substance Table
   Provide hazardous substance content table in Simplified Chinese
   Deadline: All EEPs—ongoing
4. Conformity Assessment
   CCC or supplier self-declaration for catalogued products
   Deadline: 12 categories—mandatory
5. GB 26572-2025
   Full compliance with mandatory standard
   Deadline: August 1, 2027

China RoHS-Specific Pain Points

• Your Declarations Are Already Outdated: Your supplier database shows 6-substance compliance. China now requires 10. The phthalate restrictions took effect January 1, 2026—but most suppliers haven't updated declarations.
• EFUP Labels and Tables in Simplified Chinese: Every product needs an EFUP icon and hazardous substance table—in Simplified Chinese. Your team doesn't read Chinese.
• China's Exemption List Doesn't Match EU RoHS: You're EU RoHS compliant. You assume China accepts the same exemptions. Wrong.
• The Two-Tier Trap: Catalogued products require conformity assessment. Non-catalogued products need labeling only.

China RoHS Workflow

1. Get Evidence In
   Collect 10-Substance Declarations from Your Supply Chain
2. Make Sense of It
   Validate Substance Data Against China RoHS Requirements
3. Prove Compliance Out
   Generate EFUP Labels and Hazardous Substance Tables

One Declaration. Ten Substances Validated. China-Ready Labels Generated.

Certivo collects supplier declarations, validates against China's specific substance limits and exemption list, and generates compliant EFUP labels and hazardous substance tables in Simplified Chinese.

Features Tabs

• Declaration Collection: CORA's automated campaigns collect updated 10-substance declarations.
• Substance Extraction: Regulatory intelligence extracts substance data to CAS number level.
• China-Specific Validation: Validated against China's requirements.
• Label Generation: Generate compliant labels without translation guesswork.
• Audit Response: Complete China RoHS evidence for customers, distributors, and customs.

Related Regulations

• EU RoHS: Same 10 substances; different exemptions and labeling
• REACH (SVHC): Some restricted substances overlap; REACH requires broader disclosure
• Korea RoHS: Similar substance restrictions; different marking requirements
• Taiwan RoHS: Based on EU RoHS framework; Taiwan-specific labeling
• CCC Certification: Safety certification often required alongside RoHS
• WEEE: End-of-life management complements RoHS substance restrictions

Industries Most Impacted

• Electronics Manufacturing: Complex BOMs; phthalate exposure in plastics and connectors
• Automotive Manufacturing: Tier 1/Tier 2 classification; OEM flowdown requirements
• Industrial & Heavy Equipment: Large appliances in Catalogue; EFUP calculation complexity
• Aerospace & Defense: Stringent documentation requirements; China-specific exemption gaps
• Medical Devices & Equipment: Overlapping requirements with NMPA; exemption complexity
• Consumer Goods: High SKU counts; rapid product cycles; phthalate exposure in plastics

Frequently Asked Questions

• How does China RoHS differ from EU RoHS?
• What changed with the January 2026 phthalate restrictions?
• What is the EFUP label requirement?
• When does GB 26572-2025 become mandatory?
• How does Certivo handle China's conformity assessment requirements?

Ready to Automate China RoHS Compliance?

See how Certivo transforms China market access from exemption guesswork to validated compliance.