China RoHS 2026-2027 Compliance

On May 28, 2026, the Ministry of Industry and Information Technology (MIIT) officially released the new edition of the China RoHS Compliance Management Catalog and its exemption list. This upgrade marks the most significant adjustment since the implementation of China RoHS:

1.The original 12 categories of products have been integrated and optimized into 10 categories.

2.23 new categories of products have been added to mandatory control.

3.A total of 33 categories of electrical and electronic products are now subject to China RoHS Compliance requirements.

4.Full implementation of GB 26572-2025 (Requirements of concentration limits for certain restricted substances in electrical and electronic products).

The biggest change in this upgrade is that the regulatory scope has officially expanded from traditional large home appliances and IT equipment to a vast number of consumer electronics, small home appliances, and smart terminal products. For brand owners, manufacturers, and traders, China RoHS Compliance has gradually shifted from a "partial industry requirement" to a "basic threshold."

Which Products Are Affected?

Original 10 Categories (Effective immediately from May 28, 2026)

1.Air conditioners

2.Refrigerators

3.Washing machines

4.Electric water heaters

5.Televisions

6.Monitoring equipment

7.Printer/copier/scanner/fax all-in-one machines (merged from the original 3 categories)

8.Microcomputers

9.Mobile communication handsets

10.Telephone sets

Note: The implementation for some subdivided products is delayed until August 1, 2027. For example:

1.Laser TVs

2.Single-function scanners

3.Separately sold power adapters

4.Learning machines

5.E-ink tablets

6.Cameras, etc.

23 New Categories (Mandatory implementation on August 1, 2027)

The coverage of this newly added round has expanded significantly, primarily involving:

1.Home/Office Equipment: Water dispensers, dishwashers, electric ovens, microwave ovens, rice cookers, gas water heaters, projectors, portable power banks, etc.

2.Smart Terminals/Wearables: Smart speakers, electronic smart locks, smart bands/smart watches, earphones, robot vacuum cleaners, etc.

3.IT and Network Equipment: Servers, network switching equipment, routing equipment, etc.

4.Children's and Medical Equipment: Desk lamps for reading and writing, electric toys, electronic blood pressure monitors, blood glucose meters, hearing aids, etc.

5.Living Appliances: Air purifiers, vacuum cleaners, humidifiers, etc.

Overall, the regulatory scope of China RoHS is moving from a "few industries" to the "vast majority of consumer electronic products."

What Does the Addition of 23 Categories Mean?

Simply put—the regulation has expanded from "large home appliances + IT" to the consumer electronics you touch every day. Previously, products like smart bands, power banks, robot vacuums, rice cookers, and electric toys did not need to go through China RoHS conformity assessment. Now, they all require testing, declaration, and platform uploading.

For manufacturers and brands:

1.Beneficial for export enterprises: Those already complying with the EU RoHS 10-substance control only need to supplement the China platform upload and labeling.

2.Pure domestic sales for small appliances/digital manufacturers: Facing RoHS compliance obligations for the first time, these companies urgently need to screen their supply chain materials.

Why Are the "4 Phthalates" the Biggest Risk in 2026?

Compared to previous versions, one of the biggest changes in GB 26572-2025 is that the controlled substances have been upgraded from 6 to 10. The 4 newly added phthalates (Phthalates) are:

1.DEHP

2.BBP

3.DBP

4.DIBP

The limit requirement is: Homogeneous materials ≤ 0.1%. Phthalate substances are commonly used in:

1.PVC cables and data cable jackets

2.Silicone keys and soft plastic shells

3.Sealing rings and rubber parts

4.Soft plastic components of children's products

5.Wires and flexible materials in small home appliances

Top 3 Risks for Enterprises to Fall Into

Risk 1: Historical Materials are "Presumed Compliant"

In the past, many enterprises only tested for 6 RoHS substances and ignored phthalate plasticizers. Especially with low-cost soft plastics, cables, and PVC parts, it is easy to directly exceed the limits.

Risk 2: Supply Chain Out of Control

Many suppliers cannot provide valid material declarations or RoHS 10-substance compliance documents. The result is often: the upstream doesn't control it, the downstream doesn't know, and the brand ultimately bears the risk.

Risk 3: Changes in Testing Methods

The new testing method adopts the GB/T 39560 series (equivalent to IEC 62321). Special attention is required: XRF rapid screening cannot detect phthalates. Phthalates must be confirmed through chemical analysis, so enterprises need to arrange material verification in advance.

How Can Enterprises Achieve China RoHS Compliance at a Low Cost?

Currently, there are two schemes for products within the catalog:

National Voluntary Certification

(State-promoted voluntary certification for the restriction of hazardous substances in electrical and electronic products)

1.Applicable for: Large customer requirements, bidding scenarios, and high brand endorsement needs.

2.Characteristics: Higher cost, more comprehensive process.

Enterprise Self-Declaration (Mainstream Method)

(Supplier Declaration of Conformity for the restriction of hazardous substances in electrical and electronic products) Currently, most enterprises adopt this method.

1.Characteristics: No certification qualification required, short cycle, low cost.

It is recommended to execute according to the following 4 steps:

Check the Catalog Confirm whether the product is included in the new China RoHS Compliance Management Catalog.

Collect Materials Obtain the following from suppliers:

1.MSDS

2.Material Declarations

3.RoHS Compliance Documents At the same time, conduct RoHS 10-substance testing on high-risk materials (plastics, wires, rubber parts, etc.).

Establish Technical Files Organize the following to form complete technical support documents:

1.BOM (Bill of Materials) list

2.Test Reports

3.Risk Assessment Records

4.Declaration of Conformity

Complete Platform Filing Enterprises must complete the self-declaration within 30 days after the product is launched on the market.

1.Process: Register on the platform → Fill in information → Upload supporting testing documents → Submit declaration.

2.Additionally: The product itself, packaging, and manuals must also meet China rohs labeling requirements, including the Environment-Friendly Use Period (EFUP) and hazardous substance labels.

Core Differences Between China RoHS and EU RoHS

Many enterprises mistakenly believe: Doing EU RoHS is equivalent to China RoHS compliance. In reality, the two are not exactly the same.

Core Difference:

1.EU RoHS: In principle, it covers the vast majority of electrical and electronic products.

2.China RoHS: You must first check whether the product falls into the Compliance Management Catalog.

Other Differences:

1.Controlled Substances: Both have 10 items.

2.EU Path: Technical file + eu doc + CE mark.

3.China Path: Self-declaration / National voluntary certification + Platform upload + Chinese archives. China also requires the Environment-Friendly Use Period (EFUP) and China rohs labels.

Therefore: Export enterprises should focus on EU requirements, while domestic sales enterprises must prioritize determining whether their products fall into the China RoHS catalog.

How Can Enterprises Reduce Risks in Advance?

It is recommended that enterprises complete the following actions as soon as possible:

1.Check whether products fall into the 33-category catalog.

2.Sort out high-risk materials (PVC, wires, soft plastic parts).

3.Verify the completeness of suppliers' RoHS 10-substance documents.

4.Arrange phthalate testing and technical file establishment in advance.

The later you start, the higher the supply chain rectification costs.