China RoHS Compliance: Requirements, 2026 Updates and What Manufacturers Need to Know

China RoHS regulates the use of hazardous substances in electrical and electronic products placed on the Chinese market. Although it shares some restricted substances with EU RoHS, China RoHS is a separate regulatory framework with its own product catalogue, conformity assessment, marking, information disclosure and implementation requirements.

For manufacturers selling electrical and electronic products in China, understanding the current China RoHS requirements is essential, particularly following the publication of the 2026 revised compliance management catalogue and exemption list.

This guide explains what China RoHS requires, how it differs from EU RoHS, what changed in 2026 and what manufacturers should do to maintain compliance.

What Is China RoHS?

China RoHS is China's regulatory framework for controlling hazardous substances in electrical and electronic products.

The framework is based on China's Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products, issued jointly by the relevant Chinese authorities.

Its purpose is to reduce the use of hazardous substances at source and improve environmental and human-health protection throughout the lifecycle of electrical and electronic products.

China RoHS should not be treated as simply a Chinese version of the EU RoHS Directive.

The two frameworks share important concepts, but their scope, regulatory mechanisms, product catalogues, standards, conformity assessment and information-disclosure requirements differ.

What Changed Under China RoHS in 2026?

China significantly updated its China RoHS compliance framework in 2026.

On 28 May 2026, the Ministry of Industry and Information Technology (MIIT) published:

• The Electrical and Electronic Products Hazardous Substances Restriction Compliance Management Catalogue (2026 Edition)
• The Application Exemption List for the Compliance Management Catalogue (2026 Edition)

The new documents took effect on publication and replaced the previous catalogue and exemption list.

The update expands the number of products subject to the compliance management catalogue and aligns the system with China's evolving hazardous-substance control framework.

This means manufacturers should not continue relying on an old China RoHS product-scope assessment simply because a product was previously outside the catalogue.

Why the 2026 update matters

The revised framework affects three areas manufacturers should review:

1. Product scope
2. Restricted-substance requirements
3. Conformity assessment and information reporting

Companies selling products in China should therefore reassess existing product portfolios against the 2026 catalogue.

Which Substances Are Restricted Under China RoHS?

The 2026 compliance catalogue covers 10 hazardous substances:

• Lead (Pb)
• Mercury (Hg)
• Cadmium (Cd)
• Hexavalent chromium (Cr6+)
• Polybrominated biphenyls (PBBs)
• Polybrominated diphenyl ethers (PBDEs)
• Dibutyl phthalate (DBP)
• Diisobutyl phthalate (DIBP)
• Benzyl butyl phthalate (BBP)
• Bis(2-ethylhexyl) phthalate (DEHP)

The 2026 MIIT policy interpretation confirms that products within the catalogue must meet the applicable hazardous-substance limits under China's mandatory standard GB 26572-2025, subject to applicable exemptions.

This is important for manufacturers already managing EU RoHS because the substance lists now have significant overlap, but the compliance assessment should still be performed against the applicable Chinese requirements.

China RoHS vs EU RoHS

China RoHS and EU RoHS address similar environmental concerns, but they should not be treated as interchangeable.

Therefore, EU RoHS compliance can support a manufacturer's China RoHS assessment, but it should not automatically be treated as a complete China RoHS compliance determination.

For the broader comparison between the two frameworks, see RoHS vs REACH.

Which Products Are Covered by China RoHS?

The 2026 Compliance Management Catalogue significantly expands the number of product categories covered.

Manufacturers should therefore determine whether each product falls within the current catalogue rather than relying only on previous China RoHS assessments.

The 2026 catalogue is organised around electrical and electronic product categories and expands coverage across multiple consumer and industrial product areas. MIIT states that the revised catalogue and exemption list were introduced to broaden the scope and strengthen source control of hazardous substances.

A practical scope assessment

For each product, manufacturers should determine:

1. What is the product category?
2. Is the product included in the 2026 Compliance Management Catalogue?
3. Which hazardous substances are relevant?
4. What limits apply?
5. Does an applicable exemption exist?
6. What conformity assessment route applies?
7. What marking or information-disclosure requirements apply?

This assessment should be documented rather than based solely on the product name.

China RoHS Compliance and GB 26572-2025

A major development for manufacturers is the publication of GB 26572-2025, China's mandatory standard for hazardous-substance restrictions in electrical and electronic products.

The standard was published in 2025 and is scheduled to take effect on 1 August 2027, replacing the previous recommended GB/T 26572-2011 standard.

This creates an important transition period for manufacturers.

Companies selling products in China should use this period to review:

• Product scope
• Restricted-substance data
• Testing methods
• Supplier declarations
• Material information
• Product documentation
• Marking requirements
• Conformity assessment processes

The objective should be to have the necessary evidence and processes ready before the mandatory standard takes effect.

China RoHS Conformity Assessment

China RoHS uses a conformity assessment system for products covered by the applicable compliance management catalogue.

The current framework allows the relevant products to undergo conformity assessment through the applicable voluntary product certification or self-declaration routes.

Manufacturers must then report conformity assessment results through the China RoHS public service platform where required.

MIIT's 2026 policy interpretation confirms that products included in the compliance management catalogue are subject to the conformity assessment system and that manufacturers must upload assessment results to the China RoHS public service platform.

This is an important distinction from simply maintaining a supplier declaration in an internal compliance database.

China RoHS Public Service Platform

The Chinese authorities operate a public service platform for China RoHS conformity assessment information.

According to MIIT's July 2026 update, as of 30 June 2026, the platform contained:

• 1,514 companies
• 21,180 conformity assessment records
• 33,387 products

for products subject to the applicable reporting requirements.

Manufacturers should therefore consider platform reporting as part of their China RoHS compliance workflow where applicable, rather than treating it as a separate administrative task.

China RoHS Marking and Information Disclosure

China RoHS also includes product information and disclosure requirements.

For products within the relevant regulatory framework, manufacturers need to pay attention to:

• Environmental protection use period information
• Hazardous-substance markings
• Hazardous-substance disclosure
• Product information accuracy
• Traceability of supporting information

MIIT's 2026 policy interpretation states that electrical and electronic products covered by the broader China RoHS management framework are subject to relevant marking and hazardous-substance information disclosure requirements, including requirements to ensure that information is truthful, complete and traceable.

This makes documentation and supplier material information an important part of the compliance process.

How Manufacturers Should Manage China RoHS Compliance

A practical China RoHS compliance workflow should connect regulatory requirements to the product and its supply chain.

Step 1: Determine product scope

Check the product against the 2026 Compliance Management Catalogue.

Step 2: Identify relevant materials

Map components and materials that could contain restricted substances.

Step 3: Collect supplier information

Obtain appropriate declarations, material composition information and supporting evidence from suppliers.

Step 4: Validate the information

Check whether the evidence applies to the correct component, material, revision and product.

Step 5: Assess restricted substances

Evaluate the relevant hazardous substances against the applicable Chinese requirements.

Step 6: Check exemptions

Determine whether an exemption in the current China RoHS exemption list applies.

Step 7: Complete conformity assessment

Follow the applicable China RoHS conformity assessment route.

Step 8: Complete reporting and disclosure

Where required, submit conformity assessment information through the China RoHS public service platform and meet applicable product-information requirements.

Step 9: Monitor changes

Reassess compliance when:

• The product changes
• A component changes
• A supplier changes
• Material composition changes
• A regulatory requirement changes
• A new catalogue or exemption list is published

This creates a repeatable compliance process rather than a one-time assessment.

What Manufacturers Should Do About the 2026 China RoHS Changes

Manufacturers should not wait until the new requirements become operationally urgent.

A practical review can begin with the existing product portfolio.

1. Recheck your product scope

Compare current products against the 2026 Compliance Management Catalogue.

2. Review your existing supplier evidence

Identify declarations and material information that may no longer provide sufficient confidence for the current requirements.

3. Review restricted-substance data

Confirm that your component and material data covers the substances relevant to the current Chinese framework.

4. Review exemptions

Do not rely on an old exemption assessment. Check the current 2026 exemption list.

5. Prepare for GB 26572-2025

Although the mandatory standard takes effect in 2027, manufacturers have a transition window to update testing, documentation and supplier-data processes.

6. Review conformity assessment processes

Determine which products require conformity assessment and whether the applicable reporting obligations have been completed.

How Regilient Can Help With China RoHS Compliance

Managing China RoHS becomes more difficult when product portfolios contain thousands of components and supplier relationships.

Regilient can help manufacturers centralise the information needed to manage product material compliance, including:

• BOM and component data
• Supplier declarations
• Material information
• Compliance evidence
• Regulatory requirements
• Product compliance status
• Documentation and reporting workflows

This allows compliance teams to connect supplier evidence to the products and components it supports instead of maintaining separate spreadsheets and email records.

For manufacturers managing multiple regulatory frameworks, the same compliance infrastructure can also support broader material and product compliance programmes.

Explore Regilient Compliance Solutions

China RoHS Compliance Checklist

Before placing a relevant electrical or electronic product on the Chinese market, manufacturers should confirm:

• Product scope has been assessed against the current China RoHS catalogue
  
• Applicable hazardous substances have been identified
  
• Relevant material and component information has been collected
  
• Supplier evidence has been reviewed
  
• Applicable limits have been assessed
  
• Current exemptions have been checked
  
• GB 26572-2025 transition requirements have been considered
  
• Applicable conformity assessment has been completed
  
• Required information has been reported
  
• Product marking and disclosure requirements have been addressed
  
• Supporting evidence is traceable
  
• A process exists for monitoring regulatory and product changes
  

Conclusion

China RoHS should be managed as its own regulatory programme, even when a manufacturer already maintains EU RoHS compliance processes.

The 2026 update makes this particularly important. Manufacturers should reassess product scope against the new Compliance Management Catalogue, review the updated exemption list, strengthen supplier and material evidence, prepare for GB 26572-2025 and confirm applicable conformity assessment and information-reporting requirements.

The key is to move from a one-time China RoHS assessment to a traceable, continuously maintained compliance process.

That approach helps manufacturers respond to regulatory changes without having to rebuild their compliance evidence from scratch.