(Last updated on July 26, 2019)
What's China RoHS?
China first introduced the RoHS-like regulation in 2006 titled “Administrative Measures on the Control of Pollution Caused by Electronic Information Products”, aiming at controlling and reducing the environmental pollution caused by waste electronic products and promoting the production and sale of greener products. The regulation was revised and promulgated on Jan 6, 2016 with a new title “Administrative Measures on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Products” (a.k.a. China RoHS 2) indicating an expansion of the regulated scope.
The restricted hazardous substances are namely:
1. Lead (Pb) and its compounds
2. Mercury (Hg) and its compounds
3. Cadmium (Cd) and its compounds
4. Hexavalent chromium (chromium VI) and its compounds
5. Polybrominated biphenyls (PBB);
6. Polybrominated Diphenyl ethers (PBDE);
7. Other hazardous substances specified by the state (pending)
The term “China RoHS” may refer to the regulation mentioned above (find more details in Chapter 3~5) or China’s national voluntary certification of pollution control over electronic information products (see Chapter 6).
Fig. 1 - Milestones in China RoHS legislation
2006-02-18 China RoHS: Administrative Measures on the Control of Pollution Caused by Electronic Information Products (MIIT Order 39) was promulgated and scheduled to take effect as of May 1, 2007.
2010-07-16 First draft revision to China RoHS: Measures for the Administration of Pollution Control on Electronic and Electrical Products (2010 Consultation Draft) was issued;
2011-8-25 Implementation Rules for the National Voluntary Certification of Pollution Control over Electronic Information Products was issued and scheduled to take effect on Nov 1, 2011; On the same date, Catalogue of Electronic Information Products Subject to China’s National Voluntary Certification of Pollution Control (1st Batch) was published;
2012-06-04 Second draft revision to China RoHS: Measures for the Administration of Pollution Control on Electronic and Electrical Products (2012 Consultation Draft) was issued;
2015-05-18 Third draft revision to China RoHS: Administrative Measures on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Products (2015 Consultation Draft) was issued.
2016-01-06 China RoHS 2: Administrative Measures on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Products was promulgated and scheduled to take effect as of Jul 1, 2016.
2016-05-16 China RoHS 2 FAQ: Answers to Frequently Asked Questions for Implementation of “Administrative Measures on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Products”
2017-6-29 China RoHS 2: Chinese MIIT published the draft version of the first batch of the Qualification Management Catalogue and the Exemption List of the Administrative Measures on China RoHS 2.
2017-12 China RoHS2: Chinese MIIT has notified WTO of RoHS2 documents, including the standard management catalogue (notification No. G/TBT/N/CHN/1219) and exemption list (notification NO.G/TBT/N/CHN/1220).
2018-3-15 China’s MIIT officially released the Qualification Management Catalogue (first batch) of the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products and Exemption List of the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products.
2019-3-12 The Qualification Management Catalogue and Exempltion List went into effect.
2019-5-16 The SAMR and the MIIT released China RoHS 2: Implementation Arrangements for Compliance Assessment System . Products in the Catalogue that are manufactured and imported after 1st November, 2019 shall meet the requirements of the Implementation Arrangement to complete compliance assessment.
The leading authority of China RoHS implementation is the Ministry of Industry and Information Technology (MIIT). Other authorities involved in rule making and law enforcement include the National Development and Reform Commission (NDRC), the Ministry of Science and Technology (MOST), the Ministry of Finance (MOF), the Ministry of Environmental Protection (MEP), the Ministry of Commerce (MOFCOM), the General Administration of Customs (GAC), and the General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ).
It’s worth mentioning that MIIT will cooperate with the Ministry of Finance (MOF) to work out a mechanism to allow certification results as admissible evidence in the social credit system, which means enterprises pioneering implementation of the certification scheme may be eligible for financial rewards.
As indicated by the change in the regulation’s title, the regulated product types have been expanded from electronic information products (EIPs) to all electrical and electronic products (EEPs) manufactured in or imported to China. EEPs refer to devices and accessories with a nominal working voltage under 1500 V DC, or 1000 V AC, including all the EIPs listed in MIIT’s Clarification on Electronic Information Product Categories. Accessories are subassemblies/spare parts, components and materials of EEPs.
Fig. 2 - China RoHS 2 Decision Tree
1. Equipment for power generation, transmission and distribution
2. EEPs for military use
3. EEPs for use in special or extreme environment
4. EEPs for export solely (Note: EEPs for export only shall comply with provisions concerning the restriction of the use of certain hazardous substances in export country/ region)
5. Temporarily imported EEPs or EEPs inbound for maintenance not for sale
6. Prototypes used for scientific research, R&D or testing
7. Samples, exhibits and so on used for exhibition not for sale
In accordance with the FAQs published by MIIT on May 16, 2016, China will not issue a catalogue to enumerate products falling within the regulated scope of China RoHS. You may follow the decision logic shown in Fig. 2 or refer to the 10 EEP categories specified in Chapter 2 of the FAQs.
China adopts a 2-step strategy to achieve the goal of substituting or minimizing hazardous substances in EEPs:
Step 1: Self-declaration of manufacturers/suppliers
Companies should analyze the quantity of the hazardous substances in EEPs according to GB/T 26125-2011. Based on the testing outcome, companies should label or mark the products with information such as the names and amounts of hazardous substances in the product, environment-friendly use period (EFUP), recycle of the packaging materials according to GB/T 26572-2011 and SJ/T 11364-2014. These requirements become mandatory as of Jul 1, 2016.
Fig.3 Marks in accordance with SJ/T 11364-2014
(The “e” mark (left) indicates the EEP does not contain any hazardous substance and is environmentally friendly. The product can be recycled and should not be discarded casually. The EFUP mark (right) indicates the EEP contains some hazardous substances. Safe use is no longer ensured and the product should be recycled in 10 years (the number can be changed in accordance with the actual EFUP determined by the manufacturer).
Step 2: EEP qualification management regime (pending)
All products listed in the “Qualification Management Catalogue for Restriction of Hazardous Substances in EEPs” (hereinafter referred to as “Qualification Management Catalogue”) must comply with the concentration limits of hazardous substances as specified in the GB/T 26572-2011 and pass related qualification and certification program established by Certification and Accreditation Administration of China (CNCA). After the specified compliance deadline, it is prohibited to continue manufacturing or supplying any EEP that is in the Qualification Management Catalogue but fails to pass the certification or meet the relevant management requirements.
Fig. 4 - General process to comply with China RoHS 2
The Qualification Management Catalogue will be jointly published by the competent authorities and may be adjusted when necessary.
Before the EEP qualification management regime was put forward in China RoHS, a voluntary certification program for EIPs had been established since 2011. Find more details in the next chapter “China-RoHS Voluntary Certification”.
The general procedures and key dates to comply with China RoHS 2 are summarized in the flow chart of Fig. 4.
In addition, EEP designers and manufacturers should strive to use non-hazardous, readily degradable and easy-recycling packaging materials. Marking or labeling of EEP packaging materials is excluded from the scope of China RoHS 2.
Table 1 – China RoHS standards
Restriction of certain hazardous substances
GB/T 26572-2011 Requirements of concentration limits for certain restricted substances in electrical and electronic products
SJ/T 11364-2014 Marking for the Restriction of Hazardous Substances in Electrical and Electronic Products
GB/T 26125-2011 Electrical and electronic products- Determination of six regulated substances (lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, polybrominated diphenyl ethers)
GB/T 29783-2013 Determination of chromium(VI) in electrical and electronic products - Atomic fluorescence spectrometry
Effective from Feb 1, 2014
GB/T 29784-2013 Determination of polycyclic aromatic hydrocarbons in electrical and electronic products
Effective from Feb 1, 2014
GB/T 29785-2013 Determination of hexabromocyclododecane in electrical and electronic products - Gas chromatography-mass spectrometry
Effective from Feb 1, 2014
GB/T 29786-2013 Determination of phthalates in electrical and electronic equipments - Gas chromatography-mass spectrometry
Effective from Feb 1, 2014
Conformity Assessment System
On 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 China RoHS 2: Exemption List are required to perform conformity assessments in this way.
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.
Fig. 5 - Voluntary Certification Logo
Table 2 – Different certification models for different products
Initial factory inspection
√ (Type testing)
√ (Optimized testing)
Assembled equipment and subassemblies (Complex products)
All products subject to the certification
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 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.6 - 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.
The format of the self-declaration and more details can be found in the Rules for Self-declaration.
2016-05-20 China RoHS 2 FAQs Published