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China RoHS Directive

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Jun 25, 2025

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China RoHS Directive

China

1. China RoHS Directive 1.0 VS China RoHS Directive 2.0

After the release and implementation of the EU RoHS Directive in 2003, influenced by it, other countries and major economies also introduced similar 'RoHS' directives based on its requirements. China issued the 'Measures for the Control of Pollution from Electronic Information Products' in 2006, commonly known as the China RoHS Directive, also referred to as China RoHS 1.0. In January 2016, the Ministry of Industry and Information Technology, in collaboration with other departments, jointly issued the 'Measures for the Administration of the Restricted Use of the Hazardous Substances Contained in Electrical and Electronic Products,' known as China RoHS 2.0, which came into effect on July 1, 2016.

Unlike the EU RoHS Directive, China's RoHS enforcement model involves: regulatory oversight in the circulation sector + regulatory oversight in the production sector; enforcement is based on the production date of the products.

China RoHS Directive 1.0

China RoHS Directive 2.0

Name

'Measures for the Control of Pollution from Electronic Information Products' (Ministry of Information Industry Order No. 39)

'Measures for the Administration of the Restricted Use of the Hazardous Substances Contained in Electrical and Electronic Products' (Ministry of Industry and Information Technology Order No. 32)

Release Date

February 28, 2006

January 6, 2016

Implementation Date

March 1, 2007

July 1, 2016

Scope of Control

This method applies to the control and reduction of pollution and other public hazards caused by electronic information products during their production, sale, and import within the territory of the People's Republic of China.

This method applies to the production, sale, and import of electrical and electronic products within the territory of the People's Republic of China.

Definition

Electronic Information Products: Products and their accessories manufactured using electronic information technology, including electronic radar products, electronic communication products, computer products, household electronic products, electronic measuring instrument products, electronic component products, electronic application products, electronic material products, etc.

Electrical and electronic products: refer to devices and supporting products that rely on electric current or electromagnetic fields to operate or are designed for generating, transmitting, and measuring electric current and electromagnetic fields, with a rated working voltage not exceeding 1500 volts for direct current and 1000 volts for alternating current. Equipment involved in the production, transmission, and distribution of electrical energy is excluded.

Product scope

（1） Electronic information products produced, sold, and imported within the territory of the People's Republic of China;

（2） Controlled electronic information products (EIP), including electronic radar products;

（3） Electronic communication products, radio and television products;

（4） Some electronic information products will be added to the Key Management Catalog for Pollution Control of Electronic Information Products. Products listed in the catalog must achieve substitution of toxic and hazardous substances or meet the limited substance standards, and then undergo compulsory certification (CCC certification) before entering the market. Products outside the catalog are only required to disclose relevant environmental information (labeling requirements) through self-declaration.

Electrical and electronic products mainly include, but are not limited to, the following 10 categories of equipment types and their supporting products:

（1） Communication equipment;

（2） Radio and television equipment;

（3） Computers and other office equipment;

（4） Household electrical and electronic equipment;

（5） Electronic instruments and meters;

（6） Industrial electrical and electronic equipment;

（7） Power tools;

（8） Medical electronic equipment and devices;

（9） Lighting products;

（10） Electronic cultural, educational, industrial art, sports, and entertainment products.

Note: Some electrical and electronic products will be added to the Catalog for Compliance Management of Harmful Substance Restrictions in Electrical and Electronic Products. Products included in the catalog must comply with the restricted use limits for hazardous substances in electrical and electronic products and be managed according to the compliance assessment system for the restricted use of hazardous substances in electrical and electronic products.

Exemption scope

The following electrical and electronic equipment and their dedicated or custom supporting products are not covered by the 'Measures':

Ø Equipment involving the production, transmission, and distribution of electrical energy, such as power plants, transmission and distribution stations, systems, and equipment used for building power supply and distribution;

Ø Electrical and electronic equipment for military purposes;

Ø Electrical and electronic equipment for special or extreme environments;

Ø Electrical and electronic equipment for export; (Note: Exported electrical and electronic equipment must comply with the regulations of the destination country or region regarding the restriction of hazardous substances)

Ø Temporarily imported products or equipment for inbound repair but not for sale;

Ø Prototypes for scientific research, development, or testing purposes;

Ø Samples or displays for exhibitions or shows, not for sale.

Substance restrictions

Restricted substances and their limits:

l Cadmium: 0.01%;

l Lead: 0.1%;

l Mercury: 0.1%;

l Hexavalent chromium: 0.1%;

l Polybrominated biphenyls (PBB): 0.1%;

l Polybrominated diphenyl ethers (PBDE, except deca-BDE): 0.1%.

Restricted substances and their limits:

l Cadmium and its compounds: 0.01%;

l Lead and its compounds: 0.1%;

l Mercury and its compounds: 0.1%;

l Hexavalent chromium and its compounds: 0.1%;

l Polybrominated biphenyls (PBB): 0.1%;

l Polybrominated diphenyl ethers: 0.1%.

Limit standards and testing standards

Limit standard: SJ/T 11363-2006 'Requirements for Concentration Limits for Certain Hazardous Substances in Electronic Information Products'

Testing standard: SJ/T 11365-2006 'Testing Methods for Hazardous Substances in Electronic Information Products '

Limit standard: GB/T 26572-2011 'Requirements for Concentration Limits for Certain Restricted Substances in Electrical and Electronic Products'

Testing standard: GB/T 26125-2011, IDT IEC 62321:2008 'Electrical and Electronic Products - Determination of Six Regulated Substances (Lead, Mercury, Cadmium, Hexavalent Chromium, Polybrominated Biphenyls and Polybrominated Diphenyl Ethers)';

GB/T 29783-2013 'Determination of chromium(Ⅵ) in Electrical and Electronic Products - Atomic Fluorescence Spectrometry'

Labeling requirements

According to SJ/T 11364-2006 'Marking for Control of Pollution Caused by Electronic Information Products', the following shall be labeled:

l Pollution control mark for electronic information products;

l Names and contents of toxic and hazardous substances or elements;

l Environmental protection use period;

l Recycling and names of packaging materials.

According to SJ/T 11364-2014 'Marking for Restriction of Hazardous Substances in Electrical and Electronic Products', the following shall be labeled:

l Restriction of hazardous substances mark for electrical and electronic products;

l Names and contents of hazardous substances;

l Environmental protection use period;

l Recycling.

As of April 2018, the Ministry of Industry and Information Technology had only announced the first batch of the 'Compliance Management Catalog', which includes 12 categories of products. The 'Compliance Management List' was officially implemented in March 2019 (with a one-year transition period). Together with the 'Compliance Management Catalog', the 'List of Exceptions for Restricted Substances in the Compliance Management Catalog' was also announced, i.e., the exemption list. The restrictions on substances listed in this list can be appropriately relaxed or canceled.

2. Labeling requirements

According to Article 13 of the 'Measures', 'Producers and importers of electrical and electronic products shall, in accordance with the national or industry standards for the marking of restricted use of hazardous substances in electrical and electronic products, label the hazardous substances contained in the electrical and electronic products they release to the market, indicating the names and contents of the hazardous substances, the parts where they are located, and whether the product can be recycled.'

According to Article 14 of the " Measures": "Producers and importers of electrical and electronic products shall, in accordance with national or industry standards for the labeling of restricted hazardous substances in electrical and electronic products, indicate the environmental protection use period on the electrical and electronic products they produce or import."

According to SJ/T 11364-2014 "Marking for Restriction of Use of Hazardous Substances in Electrical and Electronic Product", this mark typically has two styles:

The first, as shown in Figure 1, is generally green, indicating that the electrical and electronic product does not contain hazardous substances and is an environmentally friendly product that can be recycled after disposal and should not be discarded randomly;

The second, as shown in Figure 2, is generally orange, and the overall graphic signifies: the electrical and electronic product contains certain hazardous substances, can be safely used within the environmental protection period, and should enter the recycling system after the environmental protection period expires. The number in the center of the graphic indicates the environmental protection use period of the electrical and electronic product.

Figure 1 Figure 2

Therefore, for electrical and electronic products containing hazardous substances, even those with an orange mark, their producers or importers should disclose the names and contents of the hazardous substances.

3. National Voluntary Certification Model

In May 2019, the State Administration for Market Regulation and the Ministry of Industry and Information Technology jointly issued the "Implementation Arrangement for the Conformity Assessment System for Restricted Hazardous Substances in Electrical and Electronic Products", which announced the official implementation date of the conformity assessment system for electrical and electronic products. Products listed in the "Compliance Management Catalog" must choose either "National Voluntary Certification" or "Supplier’s Declaration of Conformity" to complete the conformity assessment. Regardless of the chosen method, the final conformity assessment information will be aggregated on the public service platform for data sharing.

Overview of Elements of Each Certification Model
Certification Model	Sample Testing			Initial Factory Inspection	Post-Certification Supervision	Applicable Products
Certification Model	Sample Submission	Sampling	Declaration of Conformity	Initial Factory Inspection	Post-Certification Supervision	Applicable Products
Model One	ü(Type Testing)		ü		ü	Component and part products, material products
Mode 2		ü	ü		ü	Parts and Components Products
Mode 3	ü(Optimized Testing)		ü		ü	Complete Machines and Assemblies (Complex Products)
Mode 4		ü	ü	ü	ü	All products within the scope of this rule

Certification Mark: Products under the national voluntary certification scheme shall use the following pattern as the conformity assessment mark.

The formal validity period of certification under the voluntary certification mode is 5 years, renewable after passing the post-expiry supervision review. If any changes occur in the product's critical components or other matters defined in the Certification Implementation Rules after certification, the certification client shall notify the certification body of such changes. Products listed in the Compliance Management Catalog shall use the certification mark as per the Implementation Arrangements. Products not listed in the Compliance Management Catalog shall have their marks selected autonomously by the certification body in accordance with relevant regulations.

Supplier's Declaration of Conformity:

Scope of Application	Products listed in the Compliance Management Catalog
Reporting Entity	Producers and authorized representatives of the supplier
Declaration Content	1. Name and contact information of the supplier; 2. Name, model, and specifications of electrical and electronic products; technical support document number and type; 3. Commitment to the authenticity, completeness, and consistency of the declaration content and related materials; 4. Additional information, including authorized signature, company seal, etc.
Technical Support Documents	Product inspection report or supplier integrated compliance report.

Conformity assessment mark:

Reference document: