China to require ROHS compliance for more EEE products
Beijing, China, 3 November 2025 — The Ministry of Industry and Information Technology (MIIT) has launched a public consultation proposing the addition of new electrical and electronic equipment (EEE) categories to the country’s restrictive hazardous substances framework (“China RoHS”). The proposal aligns with the newly issued mandatory standard GB 26572-2025, and once finalized, both the updated standard and the revised Catalog for Compliance Management of the Restriction of Hazardous Substances in Electrical and Electronic Products (“Catalog”) will form China’s updated RoHS regulatory regime.
Proposed Inclusion of New Product Categories
The draft Catalog would expand the scope of China RoHS to cover a wide range of additional consumer and industrial EEE categories. Newly added product types include:
Industrial washing machinery
Air purifiers
Water dispensers
Dishwashers
Electric and microwave ovens
Electric rice cookers
Manual and robot vacuum cleaners
Household water heaters (gas and electric)
Laser televisions and projectors
Smart speakers and smart locks
Network servers and network switching/routing equipment
Smartwatches and smart bands
Portable power banks
Reading/writing desk lamps
Electronic blood pressure monitors
Blood glucose meters
Hearing aids
The draft Catalog also updates the list of exemptions for specific uses—such as lead in soldering for electrical medical equipment—and aligns with exemptions allowed under international agreements like the Minamata Convention on Mercury.
Existing Requirements Under China RoHS
China has regulated hazardous substances in EEE since 2016 through the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products (“Measures”). The Measures transformed two voluntary standards—GB/T 26572 and SJ/T 11364—into mandatory compliance requirements.
In August 2025, the new GB 26572-2025 standard replaced both standards, resolving longstanding ambiguity regarding their mandatory status.
Under the current regime:
EEE listed in the Catalog must carry specific labels depending on whether the product meets the hazardous substance thresholds.
China regulates ten hazardous substances at thresholds largely aligned with EU RoHS
The substances are:
Lead (Pb), ≤0.1%
Mercury (Hg), ≤0.1%
Hexavalent Chromium [Cr(VI)], ≤0.1%
Polybrominated biphenyls (PBB), ≤0.1%
Polybrominated diphenyl ethers (PBDE), ≤0.1%
Cadmium (Cd), ≤0.01%
Dibutyl phthalate (DBP), ≤0.1%
Diisobutyl phthalate (DIBP), ≤0.1%
Butyl benzyl phthalate (BBP), ≤0.1%
Bis(2-ethylhexyl) phthalate (DEHP), ≤0.1%v
Unlike EU RoHS, these thresholds trigger labeling obligations, not outright product bans.
Products meeting the limits use the green “e” mark. Products exceeding the limits must display the orange circular “10” mark.
To use either mark, companies must complete a declaration or certification process and maintain supporting documentation. Labeling applies only to final products, not to component parts, though disclosures must indicate whether specific components exceed thresholds. This information may be placed on the product, in the manual, or on the company’s website.
New Requirements Under GB 26572-2025
GB 26572-2025 significantly strengthens compliance obligations:
All products listed in the Catalog must now meet both the substance restrictions and the labeling requirements.
Even if a product benefits from a chemical restriction exemption, it must still comply with labeling rules.
Products outside the Catalog must meet labeling requirements and are encouraged (but not mandated) to meet the substance concentration limits.
Information required on labels or product manuals may be provided via QR codes, reducing space constraints.
All compliance testing must follow the GB/T 39560 series, equivalent to the international IEC 62321 standards.
Compliance Timeline
Products already covered in the existing Catalog must comply immediately once the updated Catalog is published (no substantive changes apply to these categories). Newly added exemptions will also take effect immediately.
Starting on 1 August 2027:
All newly added product categories must fully comply with GB 26572-2025.
Any product losing a previous exemption must also comply by this date
Implications for Businesses
Manufacturers, importers, and brand owners of EEE should prepare for expanded compliance obligations, including:
Product testing or material redesign to meet substance limits
Supplier documentation, declarations, or third-party certification to support labeling/ marking claims
Verification of compliance across expanded product categories
Reassessment of product exemptions—particularly for certain medical devices, which may lose (or gain) previously available exemptions
Products already in alignment with EU RoHS and/or tested based on IEC 62321 would enjoy less regulatory burden when entering the China market. Businesses should monitor developments closely, as the final Catalog may further refine product scopes or exemptions.
Public comments on the draft Catalog are open until 2 December 2025.
