Manufacturers selling electronics into both Europe and China routinely ask the same question: are EU RoHS and China RoHS the same regulation, and do I have to meet both? The short answer is that they are two separate legal regimes enforced by different authorities. If you place electrical and electronic equipment on the EU market and also sell or import into China, you must comply with both independently. Since the publication of China's mandatory standard GB 26572-2025, the two restricted-substance lists now align closely, but the documentation, marking, testing references, and enforcement mechanisms remain different.

This guide explains what each regulation requires, where they diverge, which deadlines matter, and how to manage dual RoHS compliance across a global bill of materials without duplicating work.

Not sure where your products stand across both regimes? Book a compliance risk assessment to map your RoHS exposure across markets and suppliers.

Key Takeaways

📌 EU RoHS (Directive 2011/65/EU) and China RoHS (Administrative Measures plus GB 26572-2025) are distinct legal frameworks with separate compliance paths.

📊 Both now restrict the same 10 substances at the same concentration limits: 0.1% by weight in homogeneous material, except cadmium at 0.01%.

⏳ China's GB 26572-2025 becomes mandatory on 1 August 2027, expanding the list from six substances to ten by adding four phthalates.

📄 EU RoHS relies on CE marking and an EU Declaration of Conformity; China RoHS relies on substance disclosure tables, EFUP marking, and conformity assessment for catalogue products.

🔗 Dual compliance breaks down at the supplier and BOM level, where the same material data must satisfy two different reporting formats.

🤖 The underlying evidence problem is identical for both regimes, which is why centralized material data and AI-assisted document parsing reduce duplicated effort.

What Is EU RoHS?

EU RoHS, formally the Restriction of Hazardous Substances Directive 2011/65/EU (commonly called RoHS 2), restricts the use of specified hazardous substances in electrical and electronic equipment (EEE) placed on the EU market. It was later amended by Delegated Directive (EU) 2015/863 (often called RoHS 3), which added four phthalates and brought the restricted list to ten substances.

Verify the consolidated legal text through the European Commission's RoHS Directive page and the primary text on EUR-Lex (Directive 2011/65/EU).

Restricted Substances and Thresholds

The maximum concentration values apply by weight in each homogeneous material, not at the product or component level. That distinction decides most compliance outcomes.

The four phthalates (DEHP, BBP, DBP, DIBP) were added through Directive (EU) 2015/863. They have been restricted since 22 July 2019 for most categories, and since 22 July 2021 for medical devices (Category 8) and monitoring and control instruments (Category 9).

Scope and Product Categories

EU RoHS classifies EEE into 11 categories. Since 22 July 2019 the Directive operates under an "open scope," meaning Category 11 captures any electrical and electronic equipment not already covered by Categories 1 to 10. A closed list of exclusions in Article 2(4) covers items such as military equipment, space equipment, and large-scale fixed installations.

Exemptions for specific applications are listed in Annexes III and IV and are time-limited. These change regularly: the wording of several lead exemptions was revised effective 1 July 2026, with many successor entries set to expire in 2027. Track these shifts through our analysis of EU RoHS lead exemption changes and the broader RoHS exemption update.

How You Demonstrate EU RoHS Compliance

EU RoHS is a self-declaration regime. There is no government pre-market approval. The manufacturer affixes the CE mark, draws up an EU Declaration of Conformity, and maintains technical documentation, typically assessed against the harmonized standard EN IEC 63000. Analytical testing commonly references the IEC 62321 series. The burden sits with the economic operator to hold evidence that the finished product meets the limits, and market-surveillance authorities in each member state can request that file.

What Is China RoHS?

China RoHS, formally the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products (China RoHS 2), took effect on 1 July 2016 and is administered under the Ministry of Industry and Information Technology (MIIT). It replaced the earlier 2006 measure and broadened the product scope from Electronic Information Products to the wider category of Electrical and Electronic Products (EEP).

China RoHS has always operated through two mechanisms. The first applies to all in-scope products and requires information disclosure and marking. The second applies restriction limits only to products listed on the official Compliance Management Catalogue, which must also pass conformity assessment. Our China RoHS framework overview breaks down how these two layers interact.

GB 26572-2025: The Shift to a Mandatory Standard

On 1 August 2025, China's State Administration for Market Regulation (SAMR) and the Standardization Administration released GB 26572-2025, the country's first mandatory national RoHS standard. It becomes effective on 1 August 2027 and fully replaces the previously recommended standard GB/T 26572-2011.

Two changes matter most for manufacturers:

• Expanded substance list. The number of controlled hazardous substances rises from six to ten by adding DBP, DIBP, BBP, and DEHP at a 0.1% (w/w) limit. This brings China's restricted list into alignment with EU RoHS.

• Mandatory labeling. The labeling provisions of SJ/T 11364-2024 are elevated to mandatory status, and GB/T 39560 is designated as the testing methodology.

For a deeper technical breakdown, see our GB 26572-2025 compliance guide. Note that the four phthalates were first introduced through a recommended amendment to GB/T 26572-2011 with a compliance date of 1 January 2026, ahead of the mandatory standard taking force in 2027.

Marking and Information Disclosure

Every in-scope product must carry the Environmental Protection Use Period (EFUP) logo and a hazardous substance disclosure table indicating which of the restricted substances are present above the limits in each component. This disclosure obligation is broader than the EU approach, because it applies even where a substance is present rather than only confirming overall conformity.

Catalogue and Conformity Assessment

Products on the Compliance Management Catalogue face more than disclosure. They must meet the substance restriction limits and complete the China RoHS conformity assessment process, through self-declaration or certification. MIIT has proposed an expanded 2025 catalogue and a revised exemption list, aligning mandatory compliance dates with the GB 26572-2025 implementation date.

Comparison of EU RoHS and China RoHS legal basis, marking, and compliance dates

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EU RoHS vs China RoHS: Side-by-Side Comparison

The restricted substances now match, but the compliance wrapper around them does not. The table below summarizes the practical differences a product compliance team needs to plan around.

The strategic takeaway is that the chemistry you must control is becoming harmonized, while the evidence you must produce is not. That gap is where most dual-market compliance effort is spent, a theme we explore in RoHS compliance strategy for 2025 and beyond.

Do You Need to Comply With Both?

Yes, if your products reach both markets. EU RoHS governs EEE placed on the EU market. China RoHS governs EEP manufactured in or imported into China. Meeting one does not satisfy the other, even where the substance limits are identical, because each regime requires its own marking, documentation, and, for China, its own conformity assessment and disclosure table.

A few practical scenarios clarify the point:

• Sell in the EU only: EU RoHS applies. CE marking and the EU Declaration of Conformity are mandatory.

• Sell in China only: China RoHS applies. Marking, EFUP, and the substance disclosure table are mandatory, with restriction and conformity assessment for catalogue products.

• Sell in both: Both apply in full. A single, well-structured material dataset can feed both, but you still produce two sets of market-specific evidence.

Because the restricted substances are converging, a product engineered to meet the stricter interpretation of both will generally satisfy the substance limits in either market. The remaining work is documentation and format, not reformulation. This is also where RoHS compliance connects to REACH SVHC obligations, since the same phthalates are listed as Substances of Very High Concern under REACH.

Managing RoHS across multiple markets with spreadsheets? See how Certivo centralizes material compliance across both regimes, or book a demo to walk through it with your own BOM.

Compliance Deadlines You Need to Track

Deadlines differ by market and by substance. The table below consolidates the dates that affect dual-market electronics manufacturers.

The 2027 China deadline carries a two-year transition period that began at publication in August 2025. Manufacturers that treat 2027 as a distant date risk discovering non-compliant phthalate content in legacy components with no time to requalify suppliers.

RoHS compliance timeline showing EU and China deadlines from 2019 to 2027

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Where Dual RoHS Compliance Breaks Down

For most manufacturers, the regulation is not the hard part. The hard part is the supply chain. The same homogeneous-material data must be collected once and then expressed two ways: as a conformity position for the EU and as a disclosure table for China.

Common failure points include:

1. Fragmented supplier data. Declarations arrive in different formats, languages, and levels of completeness, and rarely map cleanly to homogeneous materials.

2. Format mismatch. EU evidence assessed under EN IEC 63000 does not automatically generate a China RoHS disclosure table or EFUP determination.

3. Testing reference gaps. China designates GB/T 39560, while EU files commonly cite IEC 62321, which can create questions during audits if the chain of evidence is unclear.

4. BOM volatility. An engineering change that swaps one plasticizer can move a product in or out of compliance in both markets at once.

Solving this manually across thousands of parts is where teams lose time. The underlying issue is multi-tier supplier data collection and keeping it mapped to the BOM. For electronics specifically, our analysis of multi-tier supply chain compliance covers how this scales.

How to Manage EU and China RoHS Compliance at Scale

The practical goal is to collect material data once and reuse it across both regimes. Certivo acts as the system of record for product compliance, linking supplier declarations and test reports to the bill of materials so that a single verified dataset can satisfy EU RoHS conformity and China RoHS disclosure requirements.

Three capabilities matter most for dual RoHS compliance:

• AI document parsing. CORA-powered regulatory intelligence reads supplier certificates, mill test reports, and declarations, extracts the substance data, and validates it against the applicable thresholds, which reduces manual re-keying and flags gaps at intake rather than at audit. This also removes the need to force suppliers into a single rigid format, as explained in why you do not need IPC-1752 submissions.

• BOM-level compliance intelligence. Substance data mapped to homogeneous materials lets teams see instantly which finished products are affected when a threshold, exemption, or catalogue entry changes.

• Regulatory change monitoring. CORA-enabled regulatory analysis tracks exemption revisions and standard updates across both regimes, so a change such as the 2027 China deadline or an EU lead exemption expiry becomes a managed task rather than a surprise.

The result is a shift from reactive, document-chasing compliance toward continuous, audit-ready readiness across markets. For context on how RoHS fits alongside other chemical obligations, see our guidance on RoHS and REACH compliance.

Conclusion

EU RoHS and China RoHS are converging on substance restrictions but remain separate legal obligations. From 1 August 2027, both regimes restrict the same ten substances at the same limits, yet each still demands its own marking, documentation, testing references, and, for China, its own disclosure table and conformity assessment. Manufacturers selling into both markets must comply with both, and the efficient path is to control the chemistry once and generate market-specific evidence from a single, verified material dataset.

For enterprise compliance leaders, the strategic question is no longer whether to comply but how to do it without duplicating supplier outreach, re-keying data, or missing exemption changes. That is a data and evidence problem, and it is solvable with the right system of record.

Book a compliance risk assessment to see where your products stand across EU RoHS and China RoHS, or book a demo to review dual RoHS compliance against your own bill of materials.