China Rohs Compliance Services

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

China RoHS compliance services should deliver a traceable launch file—not merely a laboratory report. Work is organised by product model, actual China-market configuration, production/import date and the specific category definition in the 2026 compliance-management catalogue.

The 2026 catalogue and exemption list replaced the 2018 versions on 28 May 2026. It consolidates the previous 12 groups into 10 and adds 23 groups. Existing covered scope continues; newly added products and newly covered extensions of earlier groups reach their catalogue obligations on 1 August 2027. The mandatory GB 26572-2025 also takes effect on 1 August 2027. Do not treat the 2027 transition as an exemption from current marking duties.

Decide the route before ordering tests

The first output is a signed model-by-model applicability sheet. The 2016 management measures cover electrical and electronic products within their legal definition, while catalogue entry controls the additional substance-limit and conformity-assessment track. Check annex definitions and implementation dates, not product names alone.

At the first gate, apply the legal definition before checking the catalogue: the 2016 measures define electrical and electronic products as equipment and supporting products operating using current/electromagnetic fields, or made to generate, transmit or measure them, with rated voltage not above 1,500 V DC or 1,000 V AC; equipment involving electric-power generation, transmission or distribution is excluded. Record rated AC/DC voltage, primary function and whether that exclusion applies. A power-sector label or an electrical component name alone does not settle classification; verify the actual product and the catalogue annex.

Observed position	Working requirement	Execution output
EEE outside the 2026 catalogue	Apply applicable China RoHS substance-information and environmental-friendly-use-period (EFUP) marking; do not automatically file catalogue conformity assessment.	Document the exclusion rationale and approve the label/instruction artwork.
One of the 10 continuing catalogue groups, within its current definition	Check current substance limits and exemptions; complete conformity assessment by one of the prescribed tracks and applicable public-platform reporting.	Category citation, testing/evidence matrix, certification or supplier-declaration package and platform record.
One of 23 new groups or newly covered parts of an existing group	Prepare now for the 1 August 2027 catalogue compliance date; retain applicable marking obligations already in force. Confirm the exact annex scope.	Gap plan, revised ten-substance evidence, artwork migration and dated release milestone.

Transition register: assessment conversion and legacy inventory

Catalogue entry dates and conformity-assessment standard dates are separate decisions. For each SKU, log its manufacture/import date, planned China-market placement, catalogue classification, assessment standard/version and record owner. SAMR/MIIT Announcement No. 44/2025 sets the assessment transition; the 2025 mandatory standard and the 2016 management measures have distinct roles.

Date / trigger	Verified requirement or distinction	Practical checkpoint
1 January 2026–31 July 2027	For China RoHS conformity assessment, use either GB/T 26572-2011 with Amendment No. 1 or GB 26572-2025. The corresponding parts of GB/T 39560 govern testing methods. If relying on an older six-substance assessment, track its separate conversion deadline rather than assuming indefinite validity.	Record the chosen edition, ten-substance evidence and sample/BOM revision in the assessment register.
Before 1 January 2027	Products previously assessed under unamended GB/T 26572-2011 and still being manufactured or imported must complete the assessment conversion to the amended standard or GB 26572-2025.	Check legacy certificates/declarations, assign the conversion owner and retain updated assessment proof.
From 1 August 2027	Use GB 26572-2025 for conformity-assessment activities; newly catalogued categories and newly expanded scope start their catalogue obligations. For products assessed under amended GB/T 26572-2011 and still manufactured/imported, Announcement No. 44/2025 permits conversion to the new standard through natural events such as certificate renewal or product change.	Distinguish the mandatory standard’s effective date from the expressly allowed assessment-document conversion mechanism; validate the exact SKU route.
Stock made or imported before 1 August 2027	MIIT explains a one-year sell-through window under GB 26572-2025: such existing stock may continue to be sold before 1 August 2028. This is not a blanket waiver of prior substance limits, marking rules or catalogue-conformity duties.	Keep dated production/import evidence and a stock-by-model register; do not use stock relief to clear noncompliant units.

For marking artwork, check the in-force industry standard SJ/T 11364-2024 (effective 1 April 2025). The 2016 measures impose the legal marking duty; an industry standard and a regulator’s implementation notice are not themselves interchangeable with legislation. These are compliance checkpoints, not a promise that a named product will qualify.

Intake package and accountable handoffs

A service coordinator cannot classify a vague product family reliably. Intake must identify both the physical build and the market transaction.

Model/SKU list, intended function, rated voltage, variants, kits and independently sold accessories.
Photographs, product descriptions and bill of materials (BOM), including cables, coatings, solders, plasticisers and replacement parts.
China manufacturing or import path, relevant dates, supplier/importer identity and the party authorised to sign a supplier declaration.
Existing EU RoHS or other reports, their methods, tested materials, versions and dates; foreign reports are inputs, not automatic China approvals.
Supplier material declarations, evidence of changed components, known nonconformities and proposed exemption claims.
Artwork, manuals, packaging and EFUP decision record; target launch and future engineering change calendar.

Handoff: the product owner confirms scope and models; engineering owns the BOM; suppliers provide traceable material evidence; the responsible supplier/importer authorises the route and declarations.

Build and test the substance-evidence file

Use a component-to-homogeneous-material evidence map before selecting laboratory samples. Link each restricted substance to the relevant material, version, supplier declaration or test and applicable exemption. The 2026 catalogue identifies ten substances: Pb, Hg, Cd, Cr(VI), PBB, PBDE, DEHP, BBP, DBP and DIBP. The legal limit and test method must be taken from the standard applicable to the particular date; GB 26572-2025 becomes mandatory on 1 August 2027.

Freeze the BOM and identify high-risk materials (for example flexible PVC, coatings, solders and electronic assemblies).
Match supplier declarations and past analytical reports to each actual material and revision; flag missing traceability.
Write a risk-based sampling plan with the laboratory, covering applicable GB/T 39560 methods where appropriate; screen selectively and confirm borderline results using suitable methods.
Check any claimed exemption against the 2026 exemption-list entry, technical application, conditions and relevant date; an EU exemption is not proof of a Chinese exemption.
On failure, quarantine the affected revision, request substitution or redesign, retest the affected evidence and update the BOM before sign-off.

A report proves what the laboratory actually sampled and measured; it does not by itself establish catalogue scope, approve an exemption, generate a complete product declaration or settle other market-access regimes.

Conformity assessment and platform reporting

For catalogue-covered products, SAMR/MIIT Announcement No. 23/2019 provides two options: state-promoted voluntary product certification or supplier declaration of conformity. The second is not a universal self-certification shortcut: the responsible supplier must have a defensible conformity assessment and supporting documents.

Gate / owner	Minimum release evidence	Hold if…
1. Scope / product owner	Catalogue category, annex definition, effective date, SKU boundaries.	A new accessory or hybrid device cannot be mapped to a category.
2. Evidence / engineering + laboratory	BOM-revision matrix, material evidence, justified testing, exception assessment.	A sampled revision differs from the sold product or a claimed exception has no matching conditions.
3. Route / responsible supplier + certification body when selected	Supplier declaration and supporting dossier OR voluntary certification decision and certificate.	The signatory, certificate coverage or conformity conclusion is unresolved.
4. Launch / importer + artwork owner	Applicable markings, final instructions, dispatch/import release, assigned platform-reporting task and record.	Artwork, model references or public reporting responsibility conflict.

Under the 2019 implementation arrangement, the supplier on the self-declaration track submits conformity information to the China RoHS public service platform within 30 days after placement on the market. On the voluntary-certification track, the certification body reports certificate information within five working days of issuing the certificate. These are different reporting actors and clocks; the self-declaration reporting window does not permit marketing a nonconforming product. Keep upload confirmation and public entry with the model file.

China-facing marking and document release

The 2016 measures require applicable hazardous-substance disclosure and EFUP marking for covered electrical/electronic products, including those outside the catalogue. If size, shape, surface or function prevents an on-product mark, the measures permit corresponding information in the instructions. The producer or importer determines EFUP; it is not a test-laboratory-issued warranty period.

Approve the restricted-substance information, affected-part identification and EFUP symbol or explanation against the applicable marking edition.
Check that packaging, product and Chinese-facing instructions use consistent model identifiers and reflect the sold accessory bundle.
For catalogue conformity assessment, distinguish the applicable conformity mark for supplier declaration from that for voluntary certification; it is separate from general substance/EFUP information.

GB 26572-2025 consolidates limit, marking and testing requirements when it starts on 1 August 2027. Plan label revision control instead of applying its future effective date to every 2026 shipment.

Launch gate: deliverables and stop conditions

A practical engagement closes with a versioned China RoHS release pack: (1) signed scope/date memo; (2) approved BOM/material-risk matrix; (3) declarations, analytical reports and exemption register; (4) chosen conformity-assessment output, if required; (5) platform proof or named post-placement submission owner; (6) approved Chinese-market marking and manuals; and (7) unresolved-issue register with release decision.

GO only when scope and transition dates are evidenced for every marketed SKU.
GO only when tests and supplier evidence match the production revision and exemptions are justified.
GO only when required marks and assessment route are approved and platform tasks have a named owner.
NO-GO when a failed material, unsupported exclusion, expired supplier evidence or mismatch remains material to compliance.

Changes that reopen the compliance file

After launch, treat these events as new review gates rather than assuming one report covers the entire product lifecycle:

New plastic resin, cable, plating, solder, coating or substitute supplier.
Hardware revision, bundled charger/accessory or new SKU marketed under an old model identifier.
New catalogue classification, revised exemption, or arrival of the 1 August 2027 obligations.
New manufacturing site or changes to the party making the declaration or handling platform reporting.
Failed surveillance sample, customer complaint or laboratory result conflicting with the original dossier.

Change-control output: affected-SKU list, refreshed exposure analysis, evidence/retest decision, revised artwork or declaration as needed, plus a dated approval trail.

This page owns execution, evidence flow, filing and release control. For strategic applicability disputes use the China RoHS compliance consultant page. China RoHS is not a substitute for China CCC certification services; check any parallel obligations via product compliance and market access services in China.

China RoHS execution FAQs

Is a product outside the 2026 catalogue exempt from China RoHS?: No general exemption follows. The 2016 measures may still require substance disclosure and EFUP marking. Record the exact out-of-catalogue reason; conformity assessment is a separate catalogue question.
Do power banks or smart watches need platform filings already in October 2026?: They are among the newly added 2026 catalogue groups; the new catalogue conformity-assessment duties generally start on 1 August 2027. Verify the annex definition and any existing/expanded-category exception; maintain present marking obligations.
Can an EU RoHS report replace the China declaration?: Not automatically. Match materials, revision, ten-substance coverage when applicable, Chinese method and exemption position, then assemble the China-specific supplier declaration or certification package.
Must self-declaration data be uploaded before the goods enter the market?: The 2019 arrangement specifies platform reporting within 30 days after market placement for self-declaration. Substantive conformity is not deferred; appoint the reporter before release and retain a dated upload confirmation.
What if a solder or plastic component changes after submission?: Identify all affected models, update the BOM and material evidence, assess the need for new tests, and correct marking, declaration or platform record where required. Do not rely on a report for the superseded revision.
Can we continue manufacturing refrigerators in 2027 with only an unamended six-substance 2011 assessment?: Not on that assessment alone. For continued manufacture/import, Announcement No. 44/2025 calls for conversion to GB/T 26572-2011 with Amendment No. 1 or GB 26572-2025 before 1 January 2027. From August 2027, assessments use GB 26572-2025; the notice separately allows natural conversion of assessments made under the amended GB/T. Check the SKU, declaration, evidence and platform record.

Official sources

Primary official texts control; verify current annexes and standard editions for the specific SKU and market date.