China RoHS Update: New Compliance Obligations For Electrical Products

I. Regulatory Background and Legislative Developments

The regulatory framework for China RoHS (Restriction of Hazardous Substances) was established by the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products, which took effect on July 1, 2016. This regulation applies to all electrical (and electronic) products¹ manufactured, sold, or imported into China, covering consumer household appliances and electronics as well as industrial machinery and equipment. The regulation introduces specific compliance management requirements for certain products: Products listed in the Catalog of Compliance Management for the Restriction of Hazardous Substances in Electrical and Electronic Products (the “Compliance Management Catalog”) must meet strict limits on hazardous substances and undergo a formal conformity assessment. In November 2025, the Ministry of Industry and Information Technology(MIIT) issued the 2025 Edition of the Compliance Management Catalog (Draft for Public Comment) (see below for details).

On August 1, 2025, China’s State Administration for Market Regulation (SAMR) issued the first mandatory national standard supporting these regulations: Requirements for Restricted Use of Hazardous Substances in Electrical and Electronic Products (GB 26572-2025, hereinafter the “New National Standard”). This New National Standard will officially take effect on August 1, 2027.

II. The Dual Compliance Obligations Under the New National Standard

The New National Standard applies to all electrical products circulating in the Chinese market. It specifies the exact limits on hazardous substances for products listed in the “Compliance Management Catalog,” and sets out labeling obligations for all manufacturers and importers of electrical products. 

1. Compliance Management Obligations

For products that fall within the “Compliance Management Catalog” (including refrigerators, air conditioners, mobile phones, copiers and other listed electrical products commonly used in daily life and work), manufacturers must test the content of hazardous substances in (1) the various components of a product (the New National Standard uses the term “various homogeneous materials constituting the product”), (2) its anti-corrosion coatings, and (3) “small parts or materials that cannot be further disassembled under current conditions” (as defined by the New National Standard) , using testing methods² specified by the New National Standard. A product is deemed compliant only if the testing results for all three units meet the maximum limits shown in the table below. If any single unit exceeds the limit, the entire product is classified as non-compliant and cannot be sold on the market. 

It is worth noting that the 2025 Edition of the Compliance Management Catalog (Draft for Public Comment), recently released by the MIIT in November 2025, has expanded the scope of the catalog. The product categories proposed for inclusion include: home medical devices such as hearing aids, blood glucose meters, and electronic blood pressure monitors; devices intended for children, such as electronic toys and reading and writing desk lamps; various new types of everyday electronic devices, such as power banks, headphones, smartwatches/fitness trackers, and smart speakers; various new types of home appliances, such as robotic vacuum cleaners, air purifiers, rice cookers, microwave ovens, and dishwashers; as well as professional equipment for industrial and commercial use, such as industrial washing machines, network switches and routers, and servers. The 2025 Edition of the Compliance Management Catalog has not yet been finalized or implemented, but we recommend that manufacturers, importers, and other parties involved with the above products continue to monitor revisions to the “Compliance Management Catalog” and prepare for potential changes.

2. Obligation to Label Hazardous Substances

The New National Standard mandates that ALL electrical products circulating in the Chinese market must display a hazardous substance label. The New National Standard requires that manufacturers or importers of electrical products first verify whether their products meet the hazardous substance content requirements shown in the table above. If they do, the product packaging must bear the mark shown in Figure 1 below; If they do not meet these requirements, products listed in the “Compliance Management Catalog” may not be placed on the market. Products not listed in the “Compliance Management Catalog” must display the symbol shown in Figure 2 below, replacing the number in the center of the symbol with the product’s actual environmental service life. Additionally, products displaying the symbol in Figure 2 must further specify information such as the types and concentrations of hazardous substances contained in the product.

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As an exception, if an electrical product serves as a component or material in a end product, the New National Standard classifies it as a “product procured for production purposes”, thereby exempting it from the obligation to label hazardous substances. However, in such cases, the component supplier must provide all information required for the hazardous substance labeling of the finished product, as requested by the purchaser.

III. Transitional Arrangements for the Implementation of the New National Standard

Effective August 1, 2027, all newly manufactured electrical products must comply with the mandatory requirements of the new national standard. At the same time, the New National Standard grants enterprises a one-year grace period for existing inventory: products manufactured or imported prior to the effective date of the New National Standard (August 1, 2027) may continue to be sold on the market until July 31, 2028.

IV. RoHS Compliance Recommendations

We recommend that manufacturers, importers, and distributors promptly prepare for the new RoHS regulations. These enterprises should closely monitor updates to the “Compliance Management Catalog,” strengthen supply chain due diligence and contractual obligations with suppliers to ensure compliance at the source, and fully utilize the grace period provided by the New National Standard to optimize production schedules and develop plans for clearing existing inventory. This will help avoid the risk of having unsold inventory of non-compliant products after July 31, 2028.

Footnotes

^{1 According to Article 3 of the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products, “electrical and electronic products” refer to “devices and their accessory products that rely on electric currents or electromagnetic fields to operate, or are designed to generate, transmit, or measure such currents and fields, with a rated operating voltage not exceeding 1500 Volts DC and 1000 Volts AC. This excludes equipment involved in the generation, transmission, and distribution of electrical power.” For the sake of simplicity, such products are collectively referred to as “electrical products” in this newsletter.}

^{2 GB 26572-2025 adopts the GB/T 39560 series of national standards as the methods for testing hazardous substances.}

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.