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The complete guide is here! Detailed interpretation of the mandatory national standard compliance points and common problems of China RoHS

Time：

2025-12-02

The first mandatory national standard for RoHS in China, GB 26572-2025 "Requirements for the Restriction of Hazardous Substances in Electrical and Electronic Products", will be officially implemented on August 1, 2027. Jiayu Testing provides a detailed interpretation of the key compliance points and common issues of China's mandatory RoHS national standard. Super comprehensive guide recommended for collection!

The first mandatory national standard for RoHS in China, GB 26572-2025 "Requirements for the Restriction of Hazardous Substances in Electrical and Electronic Products", will be officially implemented on August 1, 2027. It is recommended that relevant enterprises initiate supply chain review, product design, and material replacement work as soon as possible to ensure that products meet the requirements of the new regulations.

Jiayu Testing has CMA and CNAS dual qualifications for China RoHS supporting testing methods GB/T 39560 series standards, providing one-stop China RoHS qualification assessment services for enterprises. Welcome to contact us. Next, we will provide a detailed interpretation of the compliance points and common issues of China's mandatory RoHS national standards.

Part 01 Current RoHS Requirements in China

Products included in the standard catalog must meet both the limit requirements and labeling requirements, and complete the qualification assessment (voluntary certification or self declaration).
Products outside the standard catalog: Although they do not require qualification assessment, they must meet the labeling requirements.

Part 02 China RoHS Compliant Catalog Products

Current standard catalog (12 categories of products): refrigerators, air conditioners, washing machines, electric water heaters, printers, copiers, fax machines, televisions, monitors, microcomputers, mobile communication handheld devices, and standalone telephones.

Preparation for expanding the standard catalog (planned to expand to 33 categories of products):

The new standard directory has undergone extensive expansion, with plans to expand from the original 12 products to 33. Optimize and integrate the first batch of 12 products into 10 (merge the existing printers, copiers, and fax machines into printing, copying, scanning, fax, and multifunctional all-in-one machines based on technological development), and add 23 products with more mature control conditions. After adjustment, the 'Standard Management Catalog' includes a total of 33 products.

We plan to add 23 new products, including industrial washing machinery, air purifiers, water dispensers, dishwashers, electric ovens, microwaves, rice cookers, vacuum cleaners, robotic vacuum cleaners, household gas fast water heaters, projectors, smart speakers, electronic smart locks, servers, network switch routing devices, smart watches and bracelets, headphones, portable power banks, reading and writing desk lamps, electric toys, electronic blood pressure monitors, blood glucose meters, and hearing aids.

According to the Management Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products, China's ROHS fully implements a control system of "compliance management catalog+qualification assessment+post supervision". Electrical and electronic products that enter the standard management directory must meet the requirements of harmful substance limit, undergo qualification assessment through voluntary certification or self declaration by the national government, and upload the qualification assessment results to the China ROHS public service platform for supervision by all sectors of society. Industry and information technology, market supervision and management, customs and other departments should strengthen supervision after product launch.

Part 03 China RoHS Hazardous Substance Limit Requirements

How to determine the content of harmful substances in products?

The content of harmful substances in electrical and electronic products is detected according to the corresponding methods in the national standard "Determination of Certain Substances in Electronic and Electrical Products" (GB/T 39560 series). This series of standards is equivalent to the IEC62321 series standards and is in line with international standards. Jiayu Testing has dual qualifications of CMA and CNAS according to the GB/T 39560 series standards, providing enterprises with a one-stop solution for China RoHS.

Part 04 China RoHS Labeling Requirements

Part 05 China RoHS Transition Period Arrangement

The mandatory national standard GB 26572-2025 "Requirements for the Restriction of Hazardous Substances in Electrical and Electronic Products" will be officially implemented on August 1, 2027. Enterprises need to pay special attention to the following key time points and requirements for China's RoHS transition.

Time Period	The standards that should be used for qualification assessment	Transition Explanation
Before December 31, 2025	GB/T 26572-2011 or GB/T 26572-2011+Amendment No.1 or GB 26572-2025	New and old standards can be used in parallel, and enterprises can freely choose.
From January 1, 2026 to July 31, 2027	GB/T 26572-2011+Amendment No.1 or GB 26572-2025	The GB/T 26572-2011 standard will no longer be applicable.
Starting from August 1st, 2027	GB 26572-2025 (mandatory requirement)	Fully switch to the new mandatory national standards.

Inventory product conversion: For products that have completed qualification assessment according to GB/T 26572-2011 standard and continue to be manufactured or imported before January 1, 2026, enterprises must complete the conversion of qualification assessment according to GB/T 26572-2011 and its No.1 amendment or GB 26572-2025 before January 1, 2027.
Natural transition: Starting from August 1, 2027, for products that have been evaluated according to GB/T 26572-2011 and its No.1 amendment and continue to be produced or imported, enterprises can complete the qualification assessment conversion according to GB 26572-2025 standard through natural transition methods such as expiration certificate renewal and product change.

Part 06 Frequently Asked Questions about RoHS Implementation in China

1、 Questions about product scope

Q: What are the exceptions to the labeling requirements after this standard comes into effect?

Answer: For products within the scope of application of this standard, except for the inapplicable cases listed below, all electrical and electronic products put on the market in Chinese Mainland should be marked with information on the restriction of use of hazardous substances.

1) Equipment related to the production, transmission, and distribution of electrical energy, such as power plants, transmission and distribution stations, and systems and equipment used for building power supply and distribution;

2) Electrical and electronic equipment used for military purposes;

3) Electrical and electronic devices used in special or extreme environments;

4) Electrical and electronic equipment for export;

5) Electrical and electronic equipment temporarily imported or imported for maintenance, but not for sale;

6) Prototype used for scientific research/development, testing purposes;

7) Samples, displays, etc. used for exhibitions, trade shows, and other purposes, but not for sale.

2、 Issues related to the implementation date and transition period of standards

Q: What is the environmental protection usage period of electrical and electronic products? Is the environmentally friendly usage period equivalent to the safe usage period? How to determine the environmental protection period of a product? Does the environmental protection usage period require government approval?

The environmental protection use period of electrical and electronic products specifically refers to the period of environmental quality and safety, which only refers to the period during which harmful substances contained in electrical and electronic products will not leak or mutate, causing pollution to the environment or serious damage to people and property when users use them normally according to the product instructions. The safe use period and the environmentally friendly use period are completely different concepts. The environmentally friendly use period does not include the use period limited by factors such as electrical performance safety and electromagnetic safety. However, in many cases, safety issues are often accompanied by the leakage of harmful substances.

Enterprises can independently formulate or refer to the methods in the "General Principles for Environmental Protection Use Periods of Electronic Information Products" (SJ/Z 11388-2009) to determine the environmental protection use period of products. In addition, the government encourages industry associations to develop guidance on the environmental protection usage period of products in their respective industries. The determination of the environmental protection usage period does not require government approval.

Q: What is the definition of the production date, which is the starting date of the environmental protection usage period?

The production date refers to the date and time when the product completes all processes on the production line, undergoes inspection, and is packaged into a finished product that can be sold in the market.

Q: Due to cost considerations for the enterprise, can the remaining original information sheet materials continue to be used after the implementation date, or can they be corrected in the form of inserts for the original form?

Normally, after the standard is officially implemented, the original "Hazardous Substance Content Information Table" cannot continue to be used if it does not meet the requirements of this standard. If the table is part of the product manual, the manual can continue to be used, and the enterprise can use an insert to prepare a new hazardous substance content information table that meets the requirements of this standard, and label the replacement of the original hazardous substance content information table in the manual.

3、 Regarding the issue of limited quantity requirements

Q: The abbreviation for polybrominated biphenyls in this standard is PBBs, while in some standards it is PBB. What is the difference between the two?

Polybrominated biphenyls include multiple substances, including monobromobiphenyl, dibromobiphenyl There are 209 homologous compounds, including decabromobiphenyl. In this standard, PBBs refer to substances such as polybrominated biphenyls, and PBB refers to a certain type of polybrominated biphenyl. The abbreviation for polybrominated diphenyl ethers in this standard is PBDEs, with the same meaning as above.

Q: Does the Chinese name of hazardous substance identification for enterprises need to be consistent with the one in this standard?

According to the Chinese naming convention for chemical substances, certain organic substances usually use multiple Chinese names, such as "butyl benzyl phthalate" and "butyl benzyl phthalate", which are the same substance. For the uniformity of standard implementation, the Chinese name "Butyl benzyl phthalate" in this standard should be used.

Q: What are the limit values for polybrominated biphenyls and polybrominated diphenyl ethers in relation to the total amount of these substances?

The limit requirements for polybrominated biphenyls and polybrominated diphenyl ethers in Appendix A of this standard refer to the total limit of substance content from monobromobiphenyl to decabromobiphenyl and from monobromodiphenyl ether to decabromodiphenyl ether in the product, respectively.

4、 Issues related to identification requirements

Q: The content of harmful substances in the product does not exceed the limit requirements. Can the "e" symbol shown in Figure 1 be labeled according to the labeling requirements?

If the harmful substance content of all materials in the product meets the limit requirements of Appendix A of this standard, the "e" symbol shown in Figure 1 can be marked. Products marked with the "e" symbol do not include application exceptions, that is, if the product contains materials or components listed in the applicable application exception list, its harmful substance content also needs to meet the limit requirements of Appendix A of this standard.

Q: Can the hazardous substance content information table be built into the product in digital format?

Products with image display function can be labeled in digital format according to the provisions of Article 6.4.5, and the "Hazardous Substance Content Information Table" can also be labeled only in digital format. During product operation, users can view the digital logo and information table through the user interface, and the text displayed is clear and distinguishable. At the same time, the digital information is set as read-only data by the factory and cannot be changed arbitrarily.

Q: If the product description and packaging are integrated, can the logo and information sheet be labeled only on the packaging?

According to Article 6.4.4, the carrier of product instructions can be packaging material. If the product meets the condition of only including the logo and "Hazardous Substance Content Information Table" in the product description (any of the conditions in clause 6.4.2 of this standard), it may be labeled only on the packaging.

Q: Is it necessary to choose the green and orange labels specified in the labeling requirements section? How should companies handle products with similar colors and logos during execution?

This standard does not impose mandatory regulations on the color of hazardous substance restriction signs, except for prohibiting the use of green for sign II. Green and orange are recommended colors for corresponding signs I and II. Producers or importers may choose other colors for identification according to the size specifications required by the standard based on the actual situation, but they should meet the requirements of standard 6.2.

Q: What font is the "e" in the logo? What is the proportion?

The "e" in the logo is an artistic design font, and the font and composition ratio are executed according to the logo I vector diagram in Appendix B. The electronic version of the logo vector diagram can be obtained on the China RoHS website at the following website:

https://www.cesi.cn/rohs/page/fgptbz.jsp?catalog=/001/001 -008/001-008-001/001-008-001-002

Q: The labeling requirements stipulate that the information on the name and content of hazardous substances should be applied to the components. How should the components of the product be classified? Do components that do not contain harmful substances need to be labeled?

There are many types of electrical and electronic products, and it is impossible to list each component of the product one by one. The specific component classification method is determined by the enterprise itself, but it should include the main functional components of the product as much as possible to comprehensively reflect the content of harmful substances in the product.

Due to the fact that materials may be used in multiple components of a product, the method of material classification cannot effectively trace the actual components containing limited substances, and therefore should not be classified according to the method of material classification.

Enterprises that do not contain hazardous substances can choose whether to label them in the hazardous substance content information table.

Q: Can "Other" be used as the component name in the information table to indicate parts that are difficult to classify?

One of the main purposes of identifying the names and contents of hazardous substances based on their components is to enable recycling companies to better understand product composition information and classify them for recycling. Using "other" instead of specific and specific component names is clearly not effective and therefore not allowed.

Q: Nowadays, many electronic products have non removable batteries. In this case, does the product only need to be labeled with one label when connected to the battery? The lifespan of general batteries and products may not be consistent, but due to their non removable nature, the environmental protection lifespan can only be based on the shorter one?

For electrical and electronic products with non removable batteries, the hazardous substance restriction mark can only be marked once on the product body, but its connotation should include all product units including the battery, and the corresponding hazardous substance content table should include all component units that need to be marked in the product, including the battery. In general, the environmental protection period of a product should be based on the environmental protection period value of the worst unit (component).

Q: For detachable product accessories, when they themselves belong to electronic products, should the environmental protection usage period be marked separately or together with the product?

Removable product accessories can be labeled together with the product. If you choose to label together, please refer to the answer to the previous question for the connotation of the symbol and the corresponding hazardous substance content information table requirements; If you choose to label the environmental protection usage period separately from the product, the hazardous substance content information table of the product can also be labeled separately.

Part 07 China RoHS Compliance Recommendations

GB 26572-2025 is the first mandatory national standard in the field of hazardous substance control for electrical and electronic products in China. Clearly control the restrictions on the use of four heavy metals, including lead, mercury, cadmium, and hexavalent chromium, as well as ten harmful substances, including polybrominated biphenyls, polybrominated diphenyl ethers, and four phthalates, that may exist in electrical and electronic products, and the requirements for product labeling and identification. It is recommended that relevant enterprises initiate supply chain review, product design, and material replacement work as soon as possible to ensure a smooth transition.

As a professional third-party testing and certification service organization, Jiayu Testing has CMA, CNAS and other qualifications, a professional testing technology team, advanced instruments and equipment, proficiency in various regulatory standards, and CMA and CNAS dual qualifications for China RoHS supporting testing methods GB/T 39560 series standards. We provide one-stop China RoHS qualification assessment services for enterprises, safeguarding your products. If you want to learn more about China RoHS compliance issues, please contact us at 400-9269-886!