China RoHS Certification Overview
Core Requirements of China RoHS
- Scope of Controlled Products
Primarily covers electronic information products, including but not limited to: End products such as computers, mobile phones, televisions, and communication equipment;
Supporting products such as electronic components, integrated circuits, and batteries;
Materials and parts used in electronic information products.
- Restricted Hazardous Substances
Similar to EU RoHS, China RoHS restricts the following six hazardous substances (as updated in 2016): Lead (Pb)
Mercury (Hg)
Cadmium (Cd)
Hexavalent chromium (Cr⁶⁺)
Polybrominated biphenyls (PBBs)
Polybrominated diphenyl ethers (PBDEs)
The threshold limit for each substance is 0.1% (0.01% for cadmium); exemptions may be applied for under special circumstances.- Key Compliance Obligations
Labeling Requirements: Electronic information products must indicate the names and concentrations of hazardous substances on the product label or in the user manual, in a format compliant with national standards (e.g., GB/T 26572).
Testing and Reporting: Enterprises must test products for hazardous substances or provide a compliant self-declaration; imported products require the importer to assume compliance responsibility.
Market Surveillance: Regulatory authorities conduct random inspections of products on the market; non-compliant products may be subject to corrective actions, suspension of sales, or even recall.
Differences Between China RoHS and EU RoHS
| Comparison Item | China RoHS | EU RoHS |
|---|---|---|
| Legal Basis | Administrative Measures on the Control of Pollution Caused by Electronic Information Products | EU Directives (e.g., 2011/65/EU and amendments) |
| Scope of Application | Electronic information products only | Virtually all electrical and electronic equipment (11 categories) |
| Controlled Substances | 6 substances (same as EU base substances) | 6 base substances + 4 additional phthalates (for certain products) |
| Implementation Approach | Self-declaration + labeling; no mandatory certification | Must meet requirements before affixing the CE mark; strict market surveillance |
| Penalties | Administrative penalties (fines, sales bans, etc.) | Market exclusion from the EU; substantial fines |
Steps for Enterprises to Comply with China RoHS
Product Classification: Determine whether the product falls within the scope of electronic information products.
Material Analysis: Inventory raw materials and components of the product to identify potentially present hazardous substances.
Testing or Declaration: Engage an accredited laboratory for testing, or issue a self-declaration based on supply chain data.
Labeling and Marking: Apply the relevant information on the product or in the user manual as required by GB/T 26572.
Document Retention: Retain testing reports, self-declarations, and other documentation for regulatory inspections.
Relevant Standards and References
GB/T 26572: Requirements on concentration limits for hazardous substances in electronic information products.
GB/T 19472.1: Methods for determining restricted substances in electrical and electronic products.
The MIIT official website (www.miit.gov.cn) provides access to the latest policies and exemption lists.