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China has taken a critical step toward formalizing the nation's first mandatory RoHS standard. On April 14, 2025, Ministry of Industry and Information Technology (MIIT) released the draft for approval, GB 26572—XXXX Requirements for Restricted Use of Hazardous Substances in Electrical and Electronic Products. The draft standard is now soliciting public opinions until April 21, 2025.
Addressing Regulatory-Standard Mismatches
China’s RoHS control is governed under the legislation framwork of “Administrative Measures on the Restriction of the Use of Certain Hazardous Substances” (China RoHS 2). The enforcement of China RoHS 2 mainly relied on two recommended standards:
However, due to the inconsistency between the recommended nature of these standards and the mandatory nature of the regulations, and the legality of these standards is not explicitly stated in China RoHS 2, companies often fail to understand the mandatory nature assciated with these supporting standards, leading to inconsistent product labeling and non-compliance with substance limits.
Key Updates in GB 26572—XXXX
The darft standard merges GB/T 26572-2011 and SJ/T 11364-2024 into one mandatory standard, aligning with the mandatory nature of China RoHS 2 while also updating technical requirements necessary to adapt to industry development. Major changes include:
Expand the types of restricted hazardous substances from six to ten to align with the EU RoHS Directive (2011/65/EU). The RoHS restricted substances and their corresponding concentration limits are listed below:
| Restricted Substances | Concentration Limit |
| Lead (Pb) | ≤ 0.1% |
| Mercury (Hg) | ≤ 0.1% |
| Hexavalent chromium [Cr(VI)] | ≤ 0.1% |
| Polybrominated biphenyls(PBB) | ≤ 0.1% |
| Polybrominated diphenyl Ethers (PBDE) | ≤ 0.1% |
| Cadmium (Cd) | ≤ 0.01% |
Diisobutyl phthalate (DIBP) | ≤ 0.1% |
Dibutyl phthalate (DBP) | ≤ 0.1% |
Benzyl butyl phthalate (BBP) | ≤ 0.1% |
Bis(2-ethylhexyl) phthalate (DEHP) | ≤ 0.1% |
Adopt phased RoHS implementation strategy depending on the types of electric and electronic products as required under China RoHS 2 as follows:
| Category | Determination | RoHS requirements |
| I | Listed in Catalogue for compliance management of restricteduse of hazardous substances in electrical and electronic products | Comply with RoHS restriction limits of 10 hazardous substances and labeling rules |
| II | Not listed in Catalogue for compliance management of restricteduse of hazardous substances in electrical and electronic products | Comply with labeling rules |
Integrate labeling rules from SJ/T 11364-2024 and elevate them to mandatory status;
Stipulate that GB/T 39560 series shall be the applicable testing standard for determination of hazardous substances in electrical and electronic products;
Transitional Period
Once coming into force, companies will be granted a 2-year transitional period to comply with the mandatory standard. Products manufactured or imported before the effective date must comply from the 13th months following the effective date. This will help reduce compliance costs by allowing time to phase out non-conforming stock.
Stay Ahead of Regulatory Changes in China RoHS
According to MIIT, the existing recommended standards, GB/T 26572-2011(as amended) and SJ/T 11364-2024 is crucial for companies to gain practical experience in preparing for the future transition to mandatory standards.
Companies with existing inventory should leverage the 12-month transitional period to update compliance protocols and supply chain practices. For companies with new products produced or imported into China, they should prioritize the screening of products for Qualification Management Catalogue and prepare testing of hazardous subtance in accordance with GB/T 39560 series.
The GB 26572—XXXX Requirements for Restricted Use of Hazardous Substances in Electrical and Electronic Products (draft for approval) can be accessed here.
