China RoHS – Administrative Measures on the Restriction of the Use of Certain Hazardous Substances

From August 1, 2027, all companies must comply with one single, mandatory standard for both substance limits and labeling.

RoHS Marking

Manufacturers or importers of EEPs must label information regarding hazardous substance content in their products. There are two primary marking methods:

• Marking I: Used when the hazardous substance content in the product complies with the restriction limits. This mark indicates that the product's hazardous substance content meets the standard.

• Marking II: Used when the hazardous substance content in the product does not comply with the restriction limits. This mark must include the environmental friendly use period (EFUP) of the product and cannot be green. If a specific material or component in the product falls under an exemption but its hazardous substance content still does not meet the requirements, this mark should also be used. (The determination of EFUP can be determined in reference with SJ/Z 11388-2009).

RoHS Testing

According to the China's National Certification and Accreditation Administration, starting from March 1, 2024, the applicable testing methods for conformity assesment is changed from GB/T 26125-2011 to GB/T 39560 series.  In case the products have been manufactured or imported before March 1, 2024, the new standards shall not apply. 

The following is a summary of the existing RoHS standards in China. 

Table 3 – China RoHS standards

Conformity Assessment 

On 16th May, 2019, China State Administration for Market Regulation (SAMR) and Ministry of Industry and Information Technology (MIIT) released China RoHS 2: Implementation Arrangements for Conformity Assessment System. Conformity assessment is only mandatory for EEPs listed under the Qualification Management Catalogue .

#English Translations

Implementation Arrangements for Conformity Assessment SystemOn 16th May, China State Administration for Market Regulation (SAMR) and Ministry of Industry and Information Technology (MIIT) released China RoHS 2: Implementation Arrangements for Conformity Assessment System. The Implementation Arrangements were formulated to strengthen the management of the Qualification Management Catalogue (First Batch) for China RoHS 2. China RoHS 2 normally refers to Administrative Measures on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Products, which was released on 1st July 2016. Following on from this a series of regulations have been formulated based on it. Products in the Catalogue that are manufactured and imported after 1st November 2019 shall meet the requirements of the Implementation Arrangement to complete conformity assessment.

Two methods of conformity assessment are recognized in the Implementation Arrangements. The supplier (including producers, authorized representatives, etc.) can select the voluntary certification promoted by the state, or the compliance self-declaration to complete the conformity assessment of products in the Catalogue. For the voluntary certification, the enterprise should submit an application for conformity assessment to an official certification body established according to law. The whole process is implemented and standardized by the state. For the self-declaration, suppliers can autonomously adopt a reasonable way to complete the conformity assessment and then provide the government with corresponding technical support documents to get reviewed.

It is worth noting that the implementation arrangements do not mention that the products in the Exemption List are required to perform conformity assessments in this way.

Voluntary Certification

The certification scheme is applicable to the assembled equipment, subassemblies, component parts and materials though the certification models differ. The conformity assessment mark for products undergo voluntary certification is as Fig.5 showing.

Figure. 4 - Voluntary Certification Logo

Table 4 – Different certification models for different products

The requirements of concentration limits for certain restricted substances and the dismantling of electrical and electronic products are according to GB/T 26572. Tests are carried out in accordance with GB/T 39650 Series on determination of certain substances in electrical and electronic products. The supplier's declaration of conformity to the certification model shall comply with the requirements of GB/T 27050.1 "Conformity assessment―Supplier's declaration of conformity―part 1: General requirements".

More details can be found in the Implementation Rules for Voluntary Certification.

Self-declaration

Self-declaration is another method of conformity assessment which is initially recognized in the 2019 Implementation Arrangements. It is applicable to products listed in the Qualification Management Catalogue (First Batch) for China RoHS 2. The conformity assessment mark for products undergo self-declaration is as Fig.6 showing.

Fig.5 - Self-declaration Logo

The content of self-declaration includes the certification that the product meets the requirements for the limit of hazardous substances, and related technical support documents. The self-declaration shall at least include:

• The name and contact information of the supplier;

• Electrical and electronic product name, specification and model, technical support document number, and technical support file type;

• Commitment to the truthfulness, completeness and consistency of the contents of the statement and related declaration materials;

• Additional information, including signature of the authorized person, company seal, etc.

Suppliers of electrical and electronic products shall upload conformity reports as technical support documents through the public service platform, which is newly set up under the requirement of the Implementation Arrangements. The report should be able to prove that the product meets the requirements for the limit of hazardous substances in the products. The following two methods are available:

• The supplier can commission an inspection and testing agency to test the harmful substances in the product according to relevant standards, and develop a product testing report. The inspection and testing agency can be a laboratory which is owned by a producer or a production enterprise and has corresponding technical capabilities, or a qualified third-party inspection and testing agency.

• The supplier can develop a conformity report based on the determination of hazardous substances in all components, parts and raw materials.