On 28 May 2026, China's Ministry of Industry and Information Technology (MIIT) issued Announcement No. 11, introducing the most significant update to the China RoHS framework since its original implementation. The update expands the number of restricted substances from six to ten by adding four phthalates, broadens the scope of regulated Electrical and Electronic Products (EEPs) to 33 categories, and introduces a new China-specific exemption list with updated validity periods.

Mandatory enforcement begins 1 August 2027. Manufacturers, importers, and distributors selling electronic products into the Chinese market have approximately 14 months to update full material declarations, supplier documentation, conformity assessments, and product labeling.

📌 Book a free compliance assessment to evaluate your China RoHS readiness across products and supply chains before the August 2027 enforcement deadline.

Key Takeaways

📌 China RoHS now restricts 10 substances, adding DEHP, BBP, DBP, and DIBP to the original six, aligning phthalate restrictions with EU RoHS.

⚠️ The expanded scope covers 33 EEP categories, significantly increasing the number of products requiring compliance assessment in the Chinese market.

⏳ Mandatory enforcement begins 1 August 2027, giving manufacturers a 14-month preparation window from the May 2026 publication date.

📊 Full material declarations and certificates of compliance must now cover all 10 restricted substances, requiring updated supplier data collection campaigns.

🏭 Consumer electronics, automotive electronics, IT equipment, industrial machinery, and medical devices are directly affected by the expanded scope.

🔗 Multi-tier supply chain data collection must be updated to capture phthalate content data from component and sub-assembly suppliers.

🤖 AI-powered compliance platforms can accelerate the transition by automating substance threshold validation across BOMs and supplier declarations at scale.

What Changed in China RoHS 2026

MIIT Announcement No. 11 introduces three structural changes to the China RoHS framework that affect every company manufacturing, importing, or selling electronic products in China.

Substance Expansion

The restricted substances list grows from six to ten. Four phthalates, DEHP, BBP, DBP, and DIBP, are now restricted at a maximum concentration of 0.1% by weight in homogeneous materials. This aligns China RoHS with the EU RoHS Directive, which added the same four phthalates in 2019.

Scope Expansion

The 2018 product catalog has been repealed and replaced with an expanded list of 33 EEP categories. This significantly broadens the range of products subject to mandatory compliance, capturing product types that were previously outside the regulatory perimeter.

Exemption List Overhaul

The previous exemption list has been replaced with a new China-specific exemption list featuring updated validity periods. Unlike EU RoHS exemptions, which follow a separate review cadence, the China RoHS exemptions now carry their own timelines and conditions. Manufacturers relying on existing exemptions must verify whether those exemptions still apply under the 2026 edition.

For organizations managing materials and environmental compliance across multiple jurisdictions, this update creates a new compliance workstream that runs parallel to, but is not identical with, EU RoHS obligations.

Restricted Substances: Full List of 10 Chemicals and Thresholds

The complete list of restricted substances under China RoHS 2026:

The first six substances remain unchanged from the original China RoHS framework. The four phthalates (DEHP, BBP, DBP, DIBP) are the critical additions that require immediate attention.

⚠️ Many manufacturers already track these phthalates for EU RoHS compliance. However, China RoHS applies its own conformity assessment procedures and labeling requirements, meaning that EU RoHS compliance alone does not satisfy China RoHS obligations.

For a deeper comparison of EU and China RoHS requirements, see Certivo's China GB 26572-2025 RoHS Standard Compliance Guide.

Organizations using BOM substance and threshold management systems should update substance screening rules to include all four phthalates at the 0.1% threshold for China-destined products.

China RoHS 2026 restricted substances expansion from six to ten with phthalates

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Expanded Product Scope: 33 EEP Categories

The 2018 product catalog has been repealed. In its place, MIIT Announcement No. 11 introduces an expanded catalog of 33 Electrical and Electronic Product (EEP) categories subject to mandatory China RoHS compliance.

This expansion means that product lines previously outside the China RoHS perimeter may now fall within scope. Compliance teams must conduct a fresh product classification exercise to determine which products are covered under the new 33-category structure.

Based on currently available regulatory guidance, the expanded categories capture a broader range of electronic and electrical products across consumer, industrial, automotive, and medical applications.

For manufacturers managing compliance across both consumer goods and industrial machinery product lines, this scope expansion requires a comprehensive product-by-product assessment rather than relying on historical classification decisions.

New Exemption List and Validity Periods

The previous China RoHS exemption list has been replaced with a new 2026 edition that introduces:

✓ China-specific exemption conditions that do not mirror EU RoHS exemptions in all cases

✓ Updated validity periods for each exemption, requiring manufacturers to track expiration dates

✓ New review requirements that may differ from EU RoHS exemption renewal timelines

⚠️ Manufacturers currently relying on exemptions under the 2018 framework must verify whether those exemptions are carried forward, modified, or removed under the 2026 edition. Assumptions based on EU RoHS exemption status are not sufficient.

For a broader perspective on RoHS exemption changes, see EU RoHS Lead Exemption Changes: What Manufacturers Must Know.

Organizations with regulatory intelligence and horizon scanning capabilities can track exemption validity periods and receive alerts before exemptions expire, avoiding last-minute compliance gaps.

Key Compliance Dates and Enforcement Timeline

The framework is currently in effect as of May 2026. The 14-month transition period before mandatory enforcement provides time for manufacturers to update documentation, collect supplier data, and complete conformity assessments.

Official Source: MIIT Announcement No. 11 — Catalogue of Restricted Use of Hazardous Substances in Electrical and Electronic Products (2026 Edition)

Industries and Product Categories Affected

The expanded 33-category EEP scope affects a broad cross-section of manufacturing sectors:

🏭 Consumer Electronics — Smartphones, computers, televisions, home appliances, and related products. These represent the largest volume of affected products. Manufacturers in electronics manufacturing must update material declarations across entire product portfolios.

🏭 Information Technology and Telecommunications — Networking equipment, servers, communication devices, and IT infrastructure. Phthalate content in cables, connectors, and enclosures requires specific attention.

🏭 Automotive and Transportation — Electronic control units, sensors, infotainment systems, and vehicle electronics. Automotive manufacturers already managing EU RoHS must now maintain parallel China RoHS conformity documentation.

🏭 Industrial Equipment and Machinery — Electronic components, control systems, industrial automation equipment, and monitoring devices fall within the expanded scope.

🏭 Electrical and Electronic Manufacturing — Components, assemblies, cables, connectors, and electronic subsystems. This category captures the upstream supply chain that feeds into finished goods across all other sectors.

🏭 Medical Devices and Emerging Technologies — Electronic medical equipment and smart devices within the expanded scope. Medical device manufacturers face additional complexity when China RoHS intersects with medical device regulatory requirements.

Compliance Requirements for Manufacturers and Importers

Based on the MIIT Announcement No. 11 requirements, manufacturers and importers must take the following actions before 1 August 2027:

✅ Product Scope Assessment — Determine whether products fall within the expanded 33-category EEP scope. Products previously outside China RoHS may now be covered.

✅ Full Material Declaration Updates — Update FMDs and Certificates of Compliance to cover all 10 restricted substances, including the four newly added phthalates.

✅ Supplier Documentation Review — Collect updated material disclosures from suppliers that confirm compliance with the expanded substance list. Existing supplier declarations covering only six substances are incomplete.

✅ Phthalate Verification — Verify compliance with DEHP, BBP, DBP, and DIBP restrictions across all homogeneous materials in affected products. This is particularly relevant for cables, wire insulation, plastic enclosures, and sealing materials where phthalates are commonly used as plasticizers.

✅ Exemption Assessment — Review the new China-specific exemption list to determine applicability. Do not assume EU RoHS exemptions transfer automatically.

✅ Conformity Assessment and Labeling — Complete required conformity assessments and update product labeling before the August 2027 enforcement date.

📌 Struggling with phthalate data collection across your supply chain? See how Certivo automates this. Book a Demo

Reporting, Documentation, and Supplier Data Challenges

The addition of four phthalates creates a significant supplier data collection burden, particularly for manufacturers that have not previously tracked phthalate content at the component level.

Supplier Data Gaps

Many suppliers, especially those in Asia-Pacific, may not have phthalate content data readily available in their existing material declarations. Legacy IPC-1752 submissions and older material disclosure formats often omit phthalate reporting. Organizations must issue new data requests with explicit phthalate content fields.

For companies already using automated supplier data collection portals, updating questionnaire templates to include the four phthalates is straightforward. For those relying on email and spreadsheets, the data collection effort scales linearly with supplier count.

Multi-Jurisdiction Declaration Management

Manufacturers selling into both the EU and China now face parallel RoHS compliance obligations with differing exemption lists, conformity assessment procedures, and labeling requirements. Managing separate material declarations for EU RoHS and China RoHS across the same product portfolio requires a centralized compliance data backbone that normalizes data across jurisdictions.

BOM-Level Substance Tracking

Phthalates appear in a wide range of materials, including PVC cables, plastic housings, rubber gaskets, adhesives, and coatings. Tracking phthalate content requires BOM-level material mapping that links substance data to specific components and homogeneous materials within each product.

For broader guidance on managing compliance across electronics supply chains, see Electronics Supply Chains in 2026: Automating Multi-Tier Compliance.

China RoHS 2026 compliance preparation workflow for manufacturers and importers

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Compliance Risks and Enforcement Exposure

Failure to comply with the updated China RoHS framework by the August 2027 enforcement date exposes manufacturers and importers to several risk categories:

⚠️ Market Access Denial — Products that do not meet the expanded substance restrictions and labeling requirements may be blocked from import or sale in China.

⚠️ Regulatory Penalties — Non-compliant products are subject to enforcement actions by Chinese authorities, including product recalls, fines, and suspension of import privileges.

⚠️ Customer Audit Findings — OEMs and brand customers sourcing components from China-based supply chains will expect updated China RoHS declarations covering all 10 substances. Incomplete declarations trigger corrective action requests.

⚠️ Supply Chain Disruption — Suppliers unable to provide phthalate compliance data may face deprioritization or removal from approved supplier lists. This risk is particularly acute for smaller suppliers without robust compliance documentation systems.

Organizations maintaining continuous audit-ready documentation are better positioned to respond to customer and regulatory inquiries without operational disruption.

Supply Chain and Operational Impact

Upstream Impact

Component and material suppliers must update their material declarations to include phthalate content data for all four newly restricted substances. This affects:

• Cable and wire harness manufacturers (phthalate plasticizers in PVC insulation)

• Plastic component suppliers (DEHP and DBP in flexible plastics)

• Connector and gasket manufacturers (phthalates in sealing compounds)

• Adhesive and coating suppliers (phthalate-containing formulations)

For companies managing multi-tier supply chain transparency, the phthalate addition requires cascading data requests to Tier 2 and Tier 3 suppliers.

Downstream Impact

• Customer-facing compliance documentation must be updated to reflect 10-substance compliance

• Product labeling must meet the new China RoHS 2026 edition requirements

• Customer trust centers and self-service reporting portals must provide current China RoHS declarations

How AI Automates China RoHS Compliance at Scale

Manual China RoHS compliance management, built on spreadsheets and email-based supplier outreach, cannot scale with the expanded substance list and broadened product scope. AI-native compliance automation addresses the structural challenges this update creates.

Automated Substance Threshold Validation

Certivo's CORA-powered regulatory intelligence enables automated screening of BOMs against all 10 China RoHS restricted substances, flagging any component or material that exceeds concentration thresholds. This eliminates manual substance-by-substance review across product portfolios.

Supplier Data Collection at Scale

Supplier self-service compliance portals allow suppliers to submit updated material declarations directly, with built-in validation that ensures phthalate content data is captured for the four newly restricted substances.

AI Document Parsing

CORA-enabled analysis automates extraction and validation of substance data from supplier certificates, test reports, and material declarations. AI document parsing and certificate validation capabilities identify incomplete submissions and flag data quality issues at intake rather than during audit.

Multi-Jurisdiction RoHS Management

For manufacturers managing both EU RoHS and China RoHS, Certivo provides a centralized platform that normalizes substance data across jurisdictions, tracks differing exemption lists, and maintains separate conformity documentation where required. Explore RoHS and REACH Compliance: Lessons and Action Steps for cross-jurisdictional strategies.

Strategic Compliance Preparation Checklist

Conclusion

MIIT Announcement No. 11 represents a significant expansion of the China RoHS framework. The addition of four phthalates, the broadened 33-category product scope, and the new China-specific exemption list create substantial new compliance obligations for every manufacturer and importer operating in the Chinese market.

The 1 August 2027 enforcement deadline provides a 14-month window for preparation. Organizations that act early, updating supplier declarations, validating phthalate content data, and completing conformity assessments, will maintain uninterrupted market access while avoiding audit findings and enforcement exposure.

For manufacturers managing China RoHS alongside EU RoHS, REACH, and other substance restriction frameworks, investing in AI-native compliance automation and centralized compliance data management is the most effective strategy for absorbing regulatory changes at scale without proportional increases in manual effort.

📌 Book a demo to see how Certivo automates China RoHS compliance across your product portfolio and multi-tier supply chain, or request a compliance risk assessment to evaluate your readiness for the August 2027 enforcement deadline.

FAQs

1. How does the China RoHS 2026 phthalate restriction compare to EU RoHS?

China RoHS 2026 restricts the same four phthalates (DEHP, BBP, DBP, DIBP) at the same 0.1% threshold as EU RoHS. However, the conformity assessment procedures, labeling requirements, and exemption lists differ. EU RoHS compliance alone does not satisfy China RoHS obligations. Certivo's platform manages both frameworks in parallel with jurisdiction-specific documentation.

2. What happens if my products were previously outside China RoHS scope but now fall within the 33 EEP categories?

Products newly within scope must achieve full compliance with all 10 restricted substances before 1 August 2027. This includes collecting supplier material declarations, completing conformity assessments, and applying required product labeling. CORA-driven compliance intelligence can accelerate product classification against the expanded scope.

3. Do existing supplier material declarations need to be re-collected for the phthalate additions?

Yes. Supplier declarations covering only the original six substances are incomplete under the 2026 framework. Updated declarations must explicitly address DEHP, BBP, DBP, and DIBP. Certivo's automated supplier data collection portals streamline re-collection at scale.

4. Which product components are most likely to contain restricted phthalates?

Phthalates are commonly found in PVC cables and wire insulation, flexible plastic enclosures, rubber gaskets and seals, adhesives, and surface coatings. These components require priority attention during compliance data collection. BOM-level compliance intelligence helps identify which specific components within a product require phthalate verification.

5. What is the recommended timeline for preparing for the August 2027 enforcement deadline?

Begin immediately. Product scope assessment and supplier notification should be completed by Q3 2026. Updated material declarations should be collected by Q4 2026, allowing Q1-Q2 2027 for conformity assessment, labeling updates, and final verification before the August 2027 deadline.