China has expanded its hazardous-substance compliance catalogue for electrical and electronic products. The 2026 catalogue now covers 33 product categories, including 23 newly added categories, and links those products to the country’s updated restricted-substance requirements and conformity-assessment system.
For overseas buyers, the main issue is not simply whether a supplier says it is “RoHS compliant.” The useful question is whether the exact product being purchased falls within China’s rules, which substance limits apply, what evidence supports the supplier’s claim, and whether the supplier is ready for the August 1, 2027 transition deadline.
This matters most when products are intended for sale, import, distribution or use in China. China RoHS is a domestic Chinese compliance regime. It should not be treated as automatically equivalent to EU RoHS or as a universal export requirement for every product made in China.
1. What changed in the 2026 China RoHS catalogue?
On May 28, 2026, China’s Ministry of Industry and Information Technology (MIIT), together with seven other authorities, published the 2026 Catalogue for Compliance Management of Restricted Use of Hazardous Substances in Electrical and Electronic Products and a revised exemptions list.
The catalogue replaces the 2018 first-batch catalogue. The earlier scope covered 12 product types. The 2026 version reorganizes the original scope into 10 categories and adds 23 more, bringing the total to 33 product categories.
MIIT’s policy interpretation says the newly added products include widely used household and office products such as microwave ovens, rice cookers, drinking-water dispensers, projectors and portable power banks. It also includes newer consumer and digital products such as smart watches and bands, headphones, smart speakers, robotic vacuum cleaners, electronic smart locks, servers, network switches and routers. Other newly covered areas include electronic toys, reading lamps, electronic blood-pressure monitors, blood-glucose meters and hearing aids.
The catalogue itself should be checked for the exact product definition and scope. A product that sounds similar to a listed category is not automatically within scope unless it matches the catalogue definition.
2. Which hazardous substances are controlled?
Products in the catalogue must comply with China’s restricted-substance requirements for ten substances:
- lead (Pb);
- mercury (Hg);
- cadmium (Cd);
- hexavalent chromium (Cr6+);
- polybrominated biphenyls (PBBs);
- polybrominated diphenyl ethers (PBDEs);
- bis(2-ethylhexyl) phthalate (DEHP);
- benzyl butyl phthalate (BBP);
- dibutyl phthalate (DBP); and
- diisobutyl phthalate (DIBP).
MIIT states that products in the catalogue must meet the relevant substance-limit standards and enter the China RoHS conformity-assessment system. The mandatory national standard GB 26572-2025, Requirements for restricted use of hazardous substances in electrical and electronic products, is scheduled to take effect on August 1, 2027.
For buyers, this means material declarations, component-level controls and test reports become more important than a general supplier statement that the factory follows “RoHS.”
3. What happens on August 1, 2027?
The transition depends on whether the product was already in the older catalogue or is newly covered.
Products that were already within the first-batch catalogue moved into the revised 2026 catalogue without a transition gap. The revised exemptions list also took effect when the 2026 announcement was published.
Newly added product categories and newly expanded product scopes receive a transition period until August 1, 2027. That date aligns with the effective date of GB 26572-2025.
Buyers sourcing newly covered products should therefore use the transition period to understand whether suppliers have updated their bill-of-material controls, restricted-substance procedures, declarations, testing plans and conformity-assessment documentation.
4. What conformity evidence should buyers ask for?
MIIT’s interpretation explains that products in the compliance catalogue fall within China’s hazardous-substance conformity-assessment system. Manufacturers may use the nationally promoted voluntary certification route or the self-declaration route, depending on the applicable system requirements, and conformity results are submitted to the public China RoHS service platform.
A practical buyer check can include:
- the exact product category and catalogue scope relied on by the supplier;
- the supplier’s restricted-substance declaration or certification evidence;
- the product model and specification covered by that evidence;
- material or component declarations from upstream suppliers;
- recent test reports for high-risk materials or components;
- the standards and test methods cited in those reports;
- applicable exemptions and the technical basis for using them;
- the legal entity responsible for the conformity declaration;
- the manufacturing site and whether the same controls apply to the quoted production line; and
- evidence that the supplier’s compliance data is updated when materials or components change.
A document should be connected to the exact product being purchased. A report for a related model, another factory, an obsolete bill of materials or a different material grade may not answer the buyer’s actual compliance question.
5. Why the exemptions list matters
The 2026 update did not only expand the product catalogue. It also revised the list of permitted applications for restricted substances.
MIIT says the update removed six exemptions, revised one, refined ten and added six new exemption provisions. An exemption is therefore not a permanent blanket permission to use a restricted substance. It applies only within the scope and conditions stated in the exemptions list.
When a supplier relies on an exemption, buyers should ask which exemption applies, which component or application it covers, and whether the exemption is still current for the intended product.
This is particularly important for buyers that maintain their own restricted-substance specifications. A product may satisfy a China RoHS exemption while still failing a stricter customer specification or a destination-market requirement.
6. Do not confuse China RoHS with EU RoHS
The names are similar, but the compliance frameworks are not interchangeable.
China’s system has its own product scope, marking and disclosure requirements, catalogue-management structure, conformity-assessment arrangements, exemptions and national standards. The European Union has its own legal framework, product scope, exemptions, conformity obligations and technical documentation requirements.
A Chinese supplier may manufacture one product for the China market, another version for the EU, and another version for a different customer specification. Buyers should therefore define the destination market and compliance requirements in the purchase specification rather than asking only whether a product is “RoHS compliant.”
For export purchases, the relevant question is usually: Which jurisdiction’s restricted-substance rules apply to this exact product, and what evidence demonstrates compliance with those rules?
7. What should buyers verify in the supply chain?
Restricted-substance compliance is often a supply-chain control issue rather than a final-product inspection issue.
A factory may assemble the product correctly but still face compliance risk if an upstream component supplier changes solder, plating, cable insulation, pigments, plasticizers or other materials without proper control.
Useful supplier-verification questions include:
- Does the supplier maintain a controlled bill of materials for the exact product?
- Are critical materials and components linked to approved suppliers?
- How are restricted-substance declarations collected and reviewed?
- Which components are treated as high risk and subject to periodic testing?
- What happens when a material, component or sub-supplier changes?
- Are incoming-material records traceable to production batches?
- Can the supplier show current evidence rather than only old test reports?
- Does the supplier understand the August 2027 transition for newly covered products?
- Are China-market requirements separated clearly from EU, US or customer-specific requirements?
These checks do not replace legal or laboratory advice. They help buyers identify whether a supplier’s compliance claim is supported by a functioning control system.
8. Common buyer mistakes
Accepting a generic “RoHS compliant” statement. The statement may not identify the jurisdiction, product model, standard, test scope or date.
Using one test report for every product. A report is useful only when its samples, materials and model coverage are relevant to the goods being purchased.
Ignoring product-scope definitions. A product may be inside or outside the 2026 catalogue depending on the official definition, not its marketing name.
Assuming China RoHS automatically covers export-market requirements. Destination markets may impose different rules.
Ignoring supplier changes. A product can drift out of compliance when materials or sub-suppliers change even if an earlier sample passed testing.
Treating an exemption as permanent. Exemptions can be revised, narrowed or removed.
9. A practical buyer checklist before the 2027 deadline
For electrical or electronic products that may fall within the expanded China RoHS catalogue:
- confirm whether the exact product and model are within one of the 33 catalogue categories;
- identify whether the product was already covered or is newly added;
- confirm the applicable implementation date;
- review the supplier’s restricted-substance declaration or conformity evidence;
- connect reports and declarations to the exact product, legal entity and manufacturing site;
- review high-risk materials, components and upstream declarations;
- verify whether any exemption is being used and whether it remains applicable;
- check how the supplier controls material and component changes;
- define any destination-market or customer-specific substance requirements separately; and
- plan re-verification before mass production if the product design or bill of materials changes.
Conclusion
China’s 2026 RoHS catalogue is a significant expansion of the country’s hazardous-substance compliance system for electrical and electronic products. The practical impact is not that every Chinese export suddenly needs a new universal certificate. The impact is that more China-market products now sit within a defined restricted-substance and conformity-assessment framework, with newly added categories moving toward the August 1, 2027 implementation date.
For buyers, the best response is product-specific verification. Confirm the exact scope, identify the applicable standard and date, connect compliance evidence to the actual model and manufacturing chain, and avoid relying on generic claims. That provides a much stronger basis for supplier due diligence than simply asking whether a factory is “RoHS compliant.”
Sources / Research Notes
Ministry of Industry and Information Technology (MIIT), Announcement No. 11 of 2026, published May 28, 2026:
https://www.miit.gov.cn/jgsj/jns/wjfb/art/2026/art_c8f5ccd5bd7e465c99ade198358d5ccc.html
MIIT policy interpretation of the 2026 catalogue and exemptions list, published May 28, 2026:
https://www.miit.gov.cn/zwgk/zcjd/art/2026/art_5e3da83febf5461ca1b063165c660dea.html
National Standard Open System, GB 26572-2025, implementation date August 1, 2027:
https://openstd.samr.gov.cn/bzgk/std/newGbInfo?hcno=279928A31DAA3737BD0205BD3A0A4857
