Home » The Biweekly Pulse: 17th – 28th November – China RoHS, German WEEE Act, EU RoHS Exemptions Updates
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The Biweekly Pulse: 17th – 28th November – China RoHS, German WEEE Act, EU RoHS Exemptions Updates

Dec 03, 2025 The Biweekly Pulse: 17th – 28th November – China RoHS, German WEEE Act, EU RoHS Exemptions Updates

The Pulse was originally posted on 3rd December, 2025. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

Check out the latest 2025 Regulatory Compliance Updates with The Pulse, your biweekly source for global regulatory insights!

  1. EU: Guidelines on the Application of the General Product Safety Legislative Framework, Notice, November 2025
  2. OECD: Understanding Fluoropolymers and their Life Cycle, Report, November 2025
  3. EU: 2030 Consumer Agenda, Communication, November 2025

What is Our Content Team Talking About?

China CESI Issues Comprehensive FAQs on Mandatory RoHS Standard GB 26572-2025

by Joyce Costello, Senior Regulatory Compliance Specialist

To ensure its proper implementation, CESI has published Frequently Asked Questions about the implementation of China’s RoHS Mandato….

These FAQs will prove very useful for all parties obligated by the provisions of GB 26572-2025. Various questions regarding product scope, implementation date and transition period of the standards, restriction and labeling requirements are covered off in this document. Compliance & Risks has selected a limited number of these and reproduced them below, but we advise consulting the full set for a thorough understanding of your obligations under this important standard.

I. Product Scope

Q2. Do prototypes, models, samples, exhibits, returned products, and temporarily imported electrical and electronic products used for research and development and testing need to be labeled with information on the restriction of hazardous substances?

A: Prototypes, models, samples, exhibits, returned products, and temporarily imported electrical and electronic products used for research and development and testing do not involve sales or “marketing,” so they do not need to be labeled with information on the restriction of hazardous substances.

Q3. Are electrical and electronic products intended for installation in products outside the scope of this standard still within the scope of this standard?

A: Electrical and electronic products intended for installation in products outside the scope of this standard are not within the scope of this standard. Examples include displays, refrigerators, air purifiers, and navigation devices intended for installation in automobiles or aircraft. However, if these products are sold separately on the market without a clearly defined end use, they fall within the scope of this standard.

Q5. After the implementation of this standard, will overseas parent companies need to meet the requirements of this standard when reselling electrical and electronic products to their subsidiaries in China?

A: If an overseas parent company resells products to its Chinese subsidiaries with different independent legal person status, then it should meet the requirements of this standard. If an overseas parent company resells products to its Chinese branch with the same legal person status, this is considered an internal transfer of company assets and does not constitute “putting products on the market,” therefore it is not subject to this standard.

Q6. What are the exceptions to the labeling requirements after this standard comes into effect?

A: For products within the scope of this standard, except for the excluded situations, all electrical and electronic products placed on the Chinese mainland market must be labeled with information on the restriction of hazardous substances.

II. Issues Concerning the Implementation Date and Transition Period of the Standards

Q7. How is the period for products to meet the requirements of this standard determined for products within its scope?

A: After the release of this standard, the industry will be given a “2+1” transition period. That is, for products within the scope of this standard, those manufactured or imported on or after 1 August 2027, should comply with the requirements of this standard; for products manufactured or imported before 31 July 2027, a one-year period will be given for inventory disposal, meaning the requirements of this standard will be implemented from 1 August 2028.

Q8. How do the implementation dates of this standard correspond to those of the previous supporting standards SJ/T 11364-2024 and GB/T 26572-2011 and their first amendment, as stipulated in the “Management Measures”?

A: The first amendment to SJ/T 11364-2024 and GB/T 26572-2011 will be implemented concurrently on 1 January 2026. This standard will replace SJ/T 11364-2024 and GB/T 26572-2011 and their first amendment, effective from 1 August 2027 (inclusive).

Q10. The start date of the environmentally friendly usage period is the production date. What is the definition of the production date?

A: The production date refers to the date and time when a product completes all processes on the production line, passes inspection, and is packaged into a finished product that can be sold on the market.

Q11. Can the remaining original information sheet materials continue to be used, or can they be used as inserts as errata for the original forms?

A: Generally, after a standard is officially implemented, existing “Hazardous Substance Content Information Tables” that do not meet the requirements of this standard cannot continue to be used. If the table is part of the product instruction manual, the manual can continue to be used. Companies can use inserts to create new Hazardous Substance Content Information Tables that comply with this standard, and include explanations replacing the original Hazardous Substance Content Information Table in the instruction manual.

III. Issues Regarding Limitation Requirements

Q12. Currently, the “Management Measures” control 6 types of hazardous substances, while this standard controls 10 types. How should enterprises implement this?

A: After the implementation of this standard, enterprises should control 10 types of hazardous substances according to the requirements of this standard.

Q16. Are there any specified testing methods for the 10 hazardous substances?

A: The testing methods for the 10 hazardous substances in this standard adopt the GB/T 39560 series standards. If a certain substance has multiple applicable methods, the enterprise or testing institution can choose according to its own instruments, equipment, and testing capabilities.

IV. Issues Regarding Labeling Requirements

Q19. In procurement activities supporting production, how should upstream and downstream companies in the supply chain communicate and label information on hazardous substances?

A: For electrical and electronic products procured for production support, suppliers are not required to label the products they provide, but they must provide the purchaser with all the information necessary for labeling.

Labeling may appear only on the final product, but the labeling information must cover all components of the product; upstream suppliers have the responsibility and obligation to provide downstream customers with all the information necessary for labeling.

Among these, electrical and electronic products procured for production support generally refer to components or materials purchased by the manufacturing company from its suppliers for the production of a specific product; these components or materials are not directly sold to consumers.

Q21. Under what circumstances can information on the restriction of hazardous substances be labeled solely through a website?

A: Products that can be labeled solely through a website include “electrical and electronic products purchased for production support,” “spare parts used for after-sales services such as repair, return, and replacement of sold electrical and electronic products,” and products that meet any of the conditions in Clause 6.4.2 of this standard.

Q24. Under what circumstances can an enterprise place the hazardous substance restriction label only in the electronic instruction manual such as a CD/DVD?

A: If any one of the provisions of clauses a), b), c), or d) of Article 6.4.2 is met, the label may be included in the product instruction manual, which may be in paper form or in electronic instruction manual such as a CD/DVD.

Q25. Can the hazardous substance content information sheet be embedded in the product in digital format?

A: Products with image display capabilities can choose digital format for labeling according to the provisions of Section 6.4.5. The “Hazardous Substance Content Information Sheet” can also be labeled solely in digital format. During product operation, users can view the digital logo and text in the information sheet through the user interface. The digital information is factory-set to read-only data and cannot be arbitrarily changed.

What Are Our Knowledge Partners Talking About?

The EU Makes it Official: Key RoHS Exemptions Published in the Official Journal

by RINA

On 21 November 2025, the RoHS delegated directives123 concerning several widely used exemptions – 6a, 6b, 6c, 7a, 7c-I, and 7c-II – which amend Annex III of the RoHS Directive (2011/65/EU), were published in the EU’s Official Journal. These delegated directives will enter into force on 11 December 2025.

What Does This Mean for Manufacturers?

The entry-into-force date of 11 December 2025 will trigger the start of the 12 or 18 month transition periods for revoked exemptions. Additionally, the dates of expiry for renewed exemptions remain the same as announced previously on 8 September 2025 in the European Commission’s adoption notices.

The key dates are summarized as follows:

Exemption 6a (Lead as an alloying element in steel)

  • 6a: Not renewed; expires 12 months after the directive enters into force (EiF), by 11 December 2026
  • 6a-I is split into two exemptions expiring 30 June 2027 for all categories:
    • 6a-I: Renewed for machining purposes, containing up to 0.35% lead by weight
    • 6a-II: New exemption for batch hot-dip galvanized steel, notably decreased from 0.35% to 0.2% lead by weight

Exemption 6b (Lead as an alloying element in aluminium)

  • 6b: Not renewed; expires 18 months after EiF, by 11 June 2027
  • 6b-I (Lead due to scrap) & 6b-II (Lead for machining purposes):
    • Not renewed for categories 1–7 and 10, expires respectively 12 months and 18 months after EiF, by 11 December 2026 and 11 June 2027
    • Both retained for categories 9 industrial and 11 until 30 June 2027
  • 6b-III:
    • A continuation of the exemption for casting alloys, now limited to 0.3% lead by weight stemming only from recycled aluminium scrap; expires 30 June 2027 for categories 1 to 8, 9 other than industrial, and 10 (note: Category 11 is omitted)

Exemption 6c (Lead in copper alloy)

  • 6c: Renewed; lead content remains at 4%, and expires 30 June 2027 for all categories

Exemption 7a (Lead in High-Temperature Solders) excluding applications covered by 24

  • 7a: Renewed; expires 30 June 2027 for all categories
  • 7a-I to 7a-VII: New sub-exemptions for specific applications (e.g., die attach, hermetic sealing, audio transducers); expires 31 December 2027 for all categories

Exemption 7c-I (Lead in Glass/Ceramic Components)

  • Renewed; expires 30 June 2027 for all categories
  • 7c-V & 7c-VI: New sub-exemptions for specialized glass and ceramic applications; expires 31 December 2027 for all categories

Exemption 7c-II (Lead in Dielectric Ceramic Capacitors) excluding applications covered by 7c-I or 7c-IV

  • Renewed; expires 31 December 2027 for all categories

As such, the timeframe to submit renewals has not changed and is fast approaching as they must be submitted 18 months prior to expiry to benefit from continued validity while the exemptions are under review. Manufacturers wishing to make renewal applications should note the following deadlines:

  • For exemptions expiring 30 June 2027: Applications are due by 31 December 2025
  • For exemptions expiring 31 December 2027: Applications are due by 30 June 2026
  1. Commission Delegated Directive (EU) 2025/2364 of 8 September 2025 amending Dire… ↩︎
  2. Commission Delegated Directive (EU) 2025/1802 of 8 September 2025 amending Dire… ↩︎
  3. Commission Delegated Directive (EU) 2025/2363 of 8 September 2025 amending Dire… ↩︎

What Are Our Clients Asking About?

What Are the Main Changes Under the New Amendment of the German WEEE Act for Manufacturers and Distributors?

Answered by Hannah Janknecht, Regulatory Compliance Specialist

One of the key new aspects of the German WEEE law is the requirement to inform consumers about the possibility of returning WEEE.

Who Must Comply?

The new information requirements set out in the new Article 18a apply to everyone that is required to take back WEEE. Based on Article 16 and 17 of the WEEE Act, both manufacturers and distributors, including online distributors, are required to provide take-back facilities.

What are Manufacturers and Distributors Required to Do?

Based on the new Article 18a (1), manufacturers (or their authorized representative) and distributors are required to use a specific symbol for marking collection and return points at physical locations and on digital sales platforms. The specific symbol is set out in Annex 3a of the Act, and it is also available in C2P.

Annex 3a also entails a detailed description of the size and colors that can be used:

a) The logo must be reproduced in four colors on a white background. The distance between the content and the edge of the file is 1.5 times the thickness of the arrow. The letters must be reproduced in gray and the symbol in green. The following applies to color applications: Four colors according to Euroscale (4c): Green component (cyan = 91%, magenta = 18%, yellow = 100%, black = 4%). Black component (black = 80%). Pantone (pant): Green component (Pantone 3298). Black component (black = 80%). HKS (hks): Green component (HKS 58 E). Black component (black = 80%).

b) When using the logo in a single color, the letters and the green component are displayed in 100% black.

Additional Requirements for Distributors

In addition to the marking requirements above, distributors are also required to:

  • Place the specified symbol (Annex 3a) in color, clearly visible and readable, at least A4 size, at the entrance area of their physical stores within the customer’s view.
  • Provide information in-store on how the return process works (unfortunately this is not further clarified in the text).
  • Display the symbol near the sales area of electronic devices to clearly indicate that old electronic devices must be disposed of separately from unsorted household waste.
  • For online distributors selling electrical devices via remote communication means, the symbol must appear clearly and legibly on product pages or at the order stage, along with information on how pickup and return occur.

Deadline

The amendment of the WEEE Act comes into force on 1 January 2026, which means that the requirement to attach the mark at takeback points for manufacturers and distributors based on Article 18 (1) will become applicable on 1 January 2026.

There is a transitional period for the other requirements applicable to distributors (Article 18 (2) – (4), or described above under ‘additional requirements for distributors). Distributors have to comply with these by 30 June 2026.

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