China Rohs Compliance Consultant

Scope and evidence must be confirmed before any paid tests or filings.

A China RoHS compliance consultant should first decide what a particular product must do, by when, and who will substantiate the claim—not simply quote a laboratory test. The governing 2016 Measures apply broadly to electrical and electronic products (EEE) produced, sold or imported in China. Catalogue status then determines the additional substance-limit and conformity-assessment pathway. A written decision for each model is more valuable than a generic ‘China RoHS certificate’ request.

China RoHS scope: the EEE definition and 2026 Catalogue

Build a product-by-product classification file before buying testing or labels. The legal EEE definition concerns equipment and related products dependent on electric currents or electromagnetic fields, within rated limits of 1,500 V DC / 1,000 V AC; equipment for electricity generation, transmission and distribution is excluded from that definition. Resolve these facts, not just the marketing category:

Model, functions, rated input, how supplied, and whether it is a finished standalone product, an accessory, or a component incorporated into another product.
Precise 2026 Catalogue name, definition, scope notes and any newly extended coverage; a similar commercial name is not sufficient proof of inclusion.
Relevant manufacture/import and Chinese market-placement dates; distinguish previously covered categories from new or newly covered variants.
Producer, China importer, authorized representative where applicable, contract manufacturer and owner of the technical evidence and market statements.

2026–2027 China RoHS decision matrix: obligations by product and date

The 2026 Catalogue and exemption list replaced the 2018 versions on 28 May 2026. The Catalogue consolidates the previous 12 groups into 10 and adds 23, for 33 listed categories. Importantly, the timetable is not the same for every covered product:

Classification finding	Current or future route	Decision to document
Outside the 2016 EEE definition	Do not automatically apply China RoHS as though it were an in-scope EEE product.	Record voltage/function/exclusion reasoning; check other applicable China rules.
EEE but outside the compliance-management Catalogue	General China RoHS hazardous-substance disclosure and environmental-friendly-use-period marking obligations still need assessment; Catalogue conformity assessment is not automatically required.	Approve the product-specific marking/disclosure logic and record why no Catalogue entry applies.
Within the original coverage, now consolidated into 10 categories	Current substance-limit and conformity-assessment pathway continues; the revised 2026 exemption list already applies.	Validate precise scope, ten-substance evidence, current assessment record and platform status.
One of 23 added categories or a newly covered portion of an existing category	New Catalogue substance-limit / conformity-assessment application begins 1 August 2027; baseline in-scope marking obligations should not be postponed.	Set a dated conversion plan; verify the Catalogue scope note and applicable exception rather than assuming all legacy variants share one date.

The 2026 Catalogue's product definitions and scope notes—not this illustrative matrix—control individual borderline cases. Examples of newly added groups include power banks, smart watches, smart locks, routers, some medical home-use electronics and electronic toys. A component or separately sold accessory may require a different outcome depending on the Catalogue's exact scope wording and end use. Do not infer an exemption from industrial branding or an HS code alone.

Industrial branding is not an exemption. The 2026 Catalogue lists network switching/routing equipment without a consumer-only qualifier, while its microcomputer entry expressly excludes computers designed specifically for industrial control. Check the actual device against each entry and its phase-in note; a general statement that “industrial products are exempt” could select the wrong route.

China RoHS route choice: self-declaration or state-promoted certification

For Catalogue products, the 2019 SAMR/MIIT arrangement provides two conformity-assessment routes. The supplier selects either state-promoted voluntary certification by an approved certification body, or a supplier's self-declaration supported by conformity evidence and reported to the China RoHS public platform. ‘Voluntary’ describes the certification option—not the underlying duty to complete one of the two routes when required.

Select self-declaration when the responsible supplier can credibly control component evidence, product variants, an auditable technical file and corrective actions. It is not a substitute for testing or an automatic waiver of substance limits.
Consider state-promoted voluntary certification where third-party attestation, customer procurement demands or the supplier’s assurance model justify its certification and surveillance burden. Compare actual certification scope and variant coverage.
For self-declaration, the 2019 arrangement sets platform information reporting within 30 days after product placement on the market. This is a reporting deadline, not permission to sell an unassessed or noncompliant product for 30 days. Assign the filing owner before launch.

Review the current technical baseline separately: the first amendment to GB/T 26572-2011 took effect on 1 January 2026, bringing the restricted-substance framework to ten substances (including DEHP, BBP, DBP and DIBP). The new mandatory GB 26572-2025 is published but takes effect on 1 August 2027. Do not describe that future standard as already in force in October 2026; plan the transition now, including revised marking, disclosure and supporting-document requirements.

The platform responsibilities differ by route: under the 2019 implementation arrangement, the certification body reports an issued voluntary certificate within five working days, whereas the self-declaring supplier reports its conformity information within 30 days after market placement. Neither reporting period changes the duty to substantiate conformity before release.

Distinguish the legal duty from the technical document: GB/T 26572-2011 is a recommended national standard, but the 2016 Measures and the applicable Catalogue create enforceable substance-limit and assessment duties for covered categories. The mandatory GB 26572-2025 has a separate start date of 1 August 2027. For EEE outside the Catalogue, do not automatically impose the Catalogue assessment route, but do not ignore general marking and disclosure.

Before assigning a filing, identify the legal person acting as “supplier” under the 2019 arrangement (which can include a producer or authorised representative), separately from the producer/importer marking duties under the 2016 Measures. A paid consultant or test laboratory does not automatically become the responsible supplier. Record who signs, retains technical evidence, submits data and manages changes.

China RoHS evidence reuse: ten-substance gap-analysis matrix

Reuse EU RoHS and supplier evidence only after mapping it to the Chinese product, applicable Chinese technical specifications and version of the regime. Evidence reuse is an engineering decision, not automatic legal recognition. Use the following triage before ordering a complete retest:

Available evidence	Consultant’s acceptance test	Next action if it fails
EU RoHS declaration or old six-substance file	Does it identify this model, revision, materials and all ten substances under the applicable China requirements?	Request supporting bill of materials and phthalate coverage; do not treat CE marking as a China RoHS filing.
Bill of materials and supplier declarations	Can high-risk homogeneous materials, coatings, cables and alternate suppliers be traced to the shipped configuration?	Prioritise targeted verification for missing composition, inconsistent supplier versions or changed components.
Laboratory reports	Are sample identity, analytical method, report date, substance scope and tested material comparable to the commercial product and applicable GB/T 39560 methods?	Order narrowly scoped supplemental tests where justification is incomplete; avoid reflexive full-product retesting.
Exemption and mark/disclosure dossier	Is any exemption matched to the precise application, restrictions and 2026 list; are the China-specific hazardous-substance table, mark and environmental-use-period rationale coherent?	Recheck exemption conditions, redesign if needed, then revise China-facing disclosures before assessment.

A risk register should mark each item ACCEPT / REPAIR / TEST / CLASSIFICATION PENDING and name the evidence owner. The 2026 exemption list took immediate effect on 28 May 2026: neither an older exemption spreadsheet nor an EU exemption number alone establishes a Chinese exception.

Five gates before China RoHS testing or filing

The advisory deliverable is a defensible decision record and staged plan, not a promise of instant approval. A practical order is:

Freeze the product and market scenario: SKU families, configurations, China channels, supply-chain roles and target sale dates.
Write a classification memo citing the 2016 EEE definition and the exact 2026 Catalogue line, its scope notes and application date.
Compare the ten-substance and marking evidence against today’s applicable requirements, then prepare a separate 1 August 2027 transition delta.
Clear high-risk material/exemption gaps, confirm the responsible supplier, and make a reasoned self-declaration-versus-certification choice.
Only then commission missing tests or execution; set filing and change-control triggers for a new supplier, material, model revision or altered Catalogue scope.

China RoHS versus CCC and other China market approvals

After the route decision, use the dedicated page for China RoHS compliance execution. Broader approval mapping belongs to China product market access; separate safety/CCC and GB technical-standard questions belong to CCC certification advice and GB standards testing advice. A China RoHS result alone does not prove CCC, electrical safety or radio compliance.

The next useful step is a short classification-and-gap brief for actual models and dates. Without their functions, material evidence, sales form and applicable Catalogue definitions, no consultant can responsibly conclude that certification, a declaration or no Catalogue assessment is the correct route.

Official China RoHS legal and technical sources

China RoHS consulting: classification and route questions

Does a product added in the 2026 Catalogue need a China RoHS filing today?

Not simply because it appears in the new list. Newly added categories and newly covered parts of old categories enter the Catalogue conformity-assessment pathway on 1 August 2027; current general EEE marking/disclosure still needs consideration. Check the precise Catalogue note.

Can an EU RoHS report replace a China self-declaration?

No. It may contribute to the evidence file if the model, materials, substances, methods and Chinese requirements align, but it does not replace China-specific disclosure, route selection or platform reporting.

What if a power adapter is sold both in a kit and on its own?

Classify the kit and the separately sold SKU against the actual Catalogue scope notes. The Ministry of Commerce’s 2026 technical-trade explanation distinguishes accessories in the host product’s minimum retail package, which are assessed with that product, from standalone accessories. It identifies separately sold mobile-phone and microcomputer power adapters among the newly expanded cases starting on 1 August 2027. Do not extend that date to every adapter: check its host category, sale form and the exact entry. General in-scope marking still needs review.

Is choosing self-declaration the same as avoiding testing?

No. The supplier remains responsible for truthful, complete, consistent technical support and must use a reasonable conformity assessment. Test only those evidence gaps that require it.

Can a legacy exemption be carried into a 2027 launch?

Only after checking the immediately effective 2026 Chinese exemption list against the exact substance, application and conditions. An old EU or 2018 China list reference is not sufficient.

Does an industrial router escape the 2027 China RoHS expansion?

Not merely because it is used in a factory. The 2026 Catalogue expressly lists network switching/routing equipment for implementation from 1 August 2027; its scope notes do not limit it to consumer use. By contrast, the microcomputer entry excludes computers specifically designed for industrial control. Classify the actual hardware against the relevant entry, document its intended function and apply the general EEE marking rules in the meantime.