Stricter Obligations and Enforcement in Upcoming Changes to China RoHS

This blog was originally posted on 17th February, 2025. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY JOYCE COSTELLO, SENIOR REGULATORY COMPLIANCE SPECIALIST, COMPLIANCE & RISKS

China’s Restriction of Hazardous Substances (RoHS) regulations are set for a major overhaul, with stricter obligations and enhanced enforcement measures on the horizon. These changes include extended substance restrictions, alignment with international testing standards, and a shift to a new compulsory standard.

Electrical and electronic products in scope remain, for the moment, unchanged.

Phthalates Added to Restricted Substances List

Effective January 1, 2026, China RoHS will expand to cover a total of 10 restricted hazardous substances, including four phthalates: bis(2-ethylhexyl) phthalate (DEHP) (0,1%), butyl benzyl phthalate (BBP) (0,1%), dibutyl phthalate (DBP) (0,1%) and diisobutyl phthalate (DIBP) (0,1%) to the list of restricted substances. 

This addition follows the publication of Amendment No. 1 to GB/T 26572-2011 on June 29, 2024, through China National Standard Announcement No. 14.

An 18-month transitional period is underway to allow manufacturers to prepare for the new obligations. Unlike EU RoHS, China RoHS is double-pronged, with two differing sets of obligations applying depending on the type of electrical and electronic product being imported or produced:

Tier 1: Catalogued electrical and electronic products 

Catalogued electrical and electronic products must not contain any of the 10 hazardous substances at levels exceeding the maximum threshold. The product list includes refrigerators, air conditioners, washing machines, electric water heaters, printers, copiers, fax machines, televisions, monitors, microcomputers, mobile communication devices, and telephones. Compliance may also be achieved through the application of an exemption.

Tier 2: Non-catalogued electrical and electronic products

Manufacturers/importers of all other electrical and electronic products within the scope of the Administrative Measures (Order No. 32, 2016) are not required to limit substances in their products below the threshold and so these may still be legally placed on the market, subject to complying with labeling provisions.

RoHS Labeling

Both Tier 1 (including those in respect of which an exemption is claimed) and Tier 2 products must be labeled in accordance with the provisions of SJ/T 11364, recently revised as SJ/T 11364-2024 to include references to phthalates. Compliance with SJ/T 11364 entails indicating the presence of hazardous substances through the provision of a hazardous substance content table, and also labeling the product with the environmentally-friendly use period (‘EFUP’).

Enterprises are being advised to make full preparations in order to implement both Amendment No. 1 to RoHS Standard GB/T 26572-2011 and ST/J 11364-2024 simultaneously by 1 January 2026, at the latest.

Testing

China’s National Certification and Accreditation Administration (CNCA) has also changed the applicable conformity assessment system testing methods. Effective March 1, 2024, the GB/T 26125 series has been replaced with the GB/T 39560 series (corresponding to the IEC 62321 series) for determining hazardous substances in electronic products.

Conformity assessment is mandatory only for electrical and electronic products listed in the Catalogue, and which are manufactured or imported after 1 November 2019. This can be achieved through two approaches, either voluntary certification or self-declaration, at the discretion of manufacturers/suppliers.

New Mandatory RoHS Standard in Development

Work on the development of a mandatory standard for hazardous substances restriction and labeling, effectively combining existing Standards SJ/T 11364 and GB/T 26572 (as revised), is ongoing.

The Ministry of Industry and Information Technology is drawing the contents of the two standards together to create one mandatory standard, to be officially titled 电器电子产品有害物质限制使用要求 / Requirements for certain restricted substances in electrical and electronic products. The foreseen single standard would apply to electrical and electronic products sold within the territory of the People’s Republic of China, and specify the labeling requirements that such products should meet, along with the requirements for the maximum allowable content of harmful substances in electrical and electronic products included in the Catalogue. 

The standard will also stipulate the compliance evaluation rules for electrical and electronic products.

The latest iteration of the proposal was circulated on 19 November 2024. Labeling will still be mandatory for both Tier 1 and 2 products, but it explicitly allows for the placement of the EFUP table on the manufacturer’s website. Test reports must be produced for “high-risk components” of products listed in the Catalogue, which it is thought will enhance the ‘credibility’ of self-declaration results. 

Why a Mandatory Standard?

Since the key standards GB/T 26572 and SJ/T 11364 are of themselves recommended or voluntary, some companies are failing to appreciate the mandatory quality accorded to them by the Administrative Measures (Order No. 32, 2016).

In practice therefore they are often questioned by enterprises in the process of market supervision, who are of the view that the recommended standards cannot be enforced.

The Ministry believes that integration of the above two supporting standards, and designating them as unambiguously mandatory, will provide a more solid basis for law enforcement by industry authorities, customs and other departments, and consequently will strengthen the supervision of and implementation of China RoHS.

Preparing for Change

According to the Ministry, since GB/T 26572 and SJ/T 11364 have been implemented by industry for many years already, their integration and the addition of technical content can feasibly be implemented within 1 year, thus the recommendation that this new standard be implemented 1 year after its release.

It is furthermore believed that by first implementing the revised versions of GB/T 26572 and SJ/T 11364, industry will gain the necessary practical experience for the future transition to the mandatory standard. Voluntarily engaging with the changes in advance will alleviate the pressure on enterprises to implement the RoHS standard when it becomes compulsory, so the rationale goes.

Another reason cited for the transition period selected is that export businesses have already begun to comply with the requirements of the EU RoHS Directive to control the ten major categories of hazardous substances in product design, material selection and manufacturing processes. In addition, the relevant testing agencies have also basically met the requirements in the configuration of testing instruments and equipment.

The new standard, ultimately replacing both GB/T 26572-2011 (including Amendment No. 1) and ST/J 11364-2024 should be enacted around April 2025, but will not be fully implemented until sometime around 2027, according to current timelines.

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