Materials & Environmental
Restricted substances (4 phthalates added 2026)
Mandatory GB 26572-2025 effective date
Product categories requiring conformity assessment
Regulation Overview
MIIT Order No. 32 (2016); GB 26572-2025
China RoHS restricts hazardous substances in electrical and electronic products (EEPs) sold in the Chinese market. The regulation operates on a two-tier system: catalogued products require substance limits and conformity assessment, while all other EEPs must comply with labeling requirements.
As of January 1, 2026, China RoHS restricts 10 substances—matching EU RoHS. The four phthalates (DEHP, BBP, DBP, DIBP) join the original six substances. The new mandatory standard GB 26572-2025 consolidates substance limits and labeling into a single enforceable framework.
All products require EFUP (Environmental Friendly Use Period) labeling and hazardous substance content tables in Simplified Chinese per SJ/T 11364-2024. Testing must follow GB/T 39560 series methods.
Key Components / Sub-Frameworks
Manufacturers producing EEPs for the Chinese market
Importers bringing EEPs into China
Distributors and brand owners selling EEPs in China
Foreign companies selling through Chinese distributors or e-commerce
Component suppliers providing parts for catalogued products
Online platforms facilitating EEP sales
Key Thresholds
Your supplier database shows 6-substance compliance. China now requires 10. The phthalate restrictions took effect January 1, 2026—but most suppliers haven't updated declarations. You're shipping products into China with incomplete substance data and no visibility into phthalate content.
Every product needs an EFUP icon and hazardous substance table—in Simplified Chinese. Your engineering team doesn't read Chinese. Your suppliers don't provide Chinese-language documentation. Creating compliant labels means manual translation, format conversion, and hoping nothing gets lost.
You're EU RoHS compliant. You assume China accepts the same exemptions. Wrong. China maintains 39 exemptions—different from EU Annex III. That exemption covering your solder joints in EU? May not exist in China. You're shipping products that fail China-specific requirements you didn't know existed.
Catalogued products require conformity assessment. Non-catalogued products need labeling only. Your product portfolio spans both tiers—but you're applying the same compliance approach to everything. Some products are over-documented. Others are non-compliant. You don't know which is which.
Certivo In Action
China RoHS Workflow
Electronics Manufacturing
Pain Point
Complex BOMs; phthalate exposure in plastics and connectors
Automotive Manufacturing
Pain Point
Tier 1/Tier 2 classification; OEM flowdown requirements
Industrial & Heavy Equipment
Pain Point
Large appliances in Catalogue; EFUP calculation complexity
Aerospace & Defense
Pain Point
Stringent documentation requirements; China-specific exemption gaps
Medical Devices & Equipment
Pain Point
Overlapping requirements with NMPA; exemption complexity
Construction Materials
Pain Point
Mercury content in lighting components; category-specific requirements
Consumer Goods
Pain Point
High SKU counts; rapid product cycles; phthalate exposure in plastics
Semiconductor & High-Tech
Pain Point
Catalogued products requiring conformity assessment
10-Substance Compliance Verified
CORA-powered regulatory intelligence collects and validates declarations for all 10 restricted substances—eliminating gaps from outdated 6-substance supplier data.
EFUP Documentation in Hours
Generate compliant EFUP labels and hazardous substance tables instantly—no translation delays or formatting errors.
Zero Customs Holds
Products validated against China's actual requirements—exemptions, thresholds, and labeling—not EU assumptions.
Key Statistics
Frequently Asked Questions
How does China RoHS differ from EU RoHS?
China RoHS now restricts the same 10 substances as EU RoHS, but differences remain. China maintains 39 exemptions that don't mirror EU Annex III. Labeling requirements—including EFUP icons and Simplified Chinese substance tables—are mandatory for all products, not just non-compliant ones. Certivo validates against China-specific requirements, not EU assumptions.
What changed with the January 2026 phthalate restrictions?
Amendment 1 to GB/T 26572-2011 added four phthalates (DEHP, BBP, DBP, DIBP) to the restricted list, bringing the total to 10 substances. Supplier declarations covering only 6 substances are now insufficient. Certivo's campaigns specifically request updated declarations covering all 10 substances.
What is the EFUP label requirement?
EFUP (Environmental Friendly Use Period) indicates how long a product can be used before hazardous substances may leak. All EEPs sold in China must display an EFUP label—either a green "e" symbol (compliant) or an orange number (years until potential leakage). Certivo generates compliant EFUP labels per SJ/T 11364-2024.
When does GB 26572-2025 become mandatory?
GB 26572-2025 takes effect August 1, 2027. It consolidates the substance standard (GB/T 26572) and labeling standard (SJ/T 11364) into a single mandatory framework. Products manufactured before that date must comply within 13 months. Certivo monitors regulatory changes and alerts you when portfolio reassessment is needed.
How does Certivo handle China's conformity assessment requirements?
Products in the 12-category Compliance Management Catalogue require conformity assessment through CCC certification or supplier self-declaration with testing. Certivo classifies your products into Tier 1 (catalogued) or Tier 2 (labeling only), tracks required documentation, and coordinates testing to GB/T 39560 methods through accredited laboratories.