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In November 2025, the China Electronics Standardization Institute (CESI) released a comprehensive Q&A document to support the implementation of the new mandatory national standard "Requirements for Restriction of Hazardous Substances in Electrical and Electronic Products" (GB 26572-2025).
This standard, which will take effect on August 1, 2027, serves as a critical technical foundation for the enforcement of China's "Administrative Measures for the Restriction of Hazardous Substances in Electrical and Electronic Products" (commonly referred to as China RoHS).
The Q&A addresses frequent questions from industry stakeholders regarding product scope, transition timelines, substance restrictions, labeling requirements, and more.
Here are some highlights of the Q&A:
Questions on Product Scope
Q: Are electrical and electronic products intended solely for installation into products outside the scopeof this standard also excluded from this standard?
A: Electrical and electronic products intended exclusively for installation into products outside the scopeof this standard—such as displays, refrigerators, air purifiers, and navigation devices installed in automobilesoraircraft—are not subject to this standard. However, if such products are sold separately on the market without a clearly defined final use, they fall within the scope of this standard.
Questions on Implementation Date
Q. How should enterprises determine the deadline for compliance with this standard?
A: A “2+1” transition period is provided. Products within the scope of this standard that are manufacturedor imported on or after August 1, 2027, must comply with the standard. Products manufactured or importedonorbefore July 31, 2027, may be sold during a one-year inventory clearance period, meaning full complianceisrequired starting August 1, 2028.
Questions on Substance Limits
Q. The Administrative Measures currently control 6 hazardous substances, while this standard controls 10 hazardous substances. How should enterprises comply?
A: After the implementation of this standard, enterprises must comply with the requirements for all 10 controlled substances.
Questions on Labeling Requirements
Q. How should upstream and downstream enterprises in the supply chain communicate and label hazardous substance information for components procured for production?
A: Suppliers may omit physical labeling on components procured for production but must provide all necessary information to the buyer for final product labeling. The final product must carry a complete label covering all components. Upstream suppliers are obligated to provide full hazardous substance informationtodownstream customers. Electrical and electronic products purchased for production support are generallycomponents or materials that manufacturers purchase from their suppliers for the production of a certainproduct. Such components are typically not sold directly to consumers.
Q. Non-electronic accessories sold with a product—must they be labeled and included in the table?
A: If the accessory is non-electronic but sold in the same package, it must be labeled and included in thehazardous substance content table. Otherwise, it is exempt.
Q. The standard requires substance content to be listed by component. How should components be defined?Must components without hazardous substances be listed?
A: Component division is not prescribed due to product diversity. Enterprises should define components toreflect major functional units (e.g., for a computer: casing, motherboard, CPU, hard drive, memory, power supply, etc.). Grouping as “main unit, keyboard, monitor” is discouraged.
To access the entire FQA document, you can click here to download for free.
To know more about how China RoHS works and its core obligations, please click here for our Chempedia on China RoHS for more.
