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Blockbuster! China's RoHS control has been comprehensively upgraded: 10 substances are subject to mandatory limits, and 33 categories of products are listed
Author.
LCS
Source:
Post time:
2025-12-29
A 20-year history of environmental control evolution is profoundly influencing the production lines and supply chains of every electrical and electronic enterprise in China.
Has the environmental label of your product been updated? Is the hazardous substance information sheet ready? "This is not a routine inspection, but a warning signal that China's RoHS control is about to be fully upgraded.
With the development and evolution of the "Management Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products" (China RoHS), an environmental compliance marathon that began in 2006 is entering its most critical sprint stage.
01 Control Upgrade, Historic Turning Point
The evolution of China's RoHS is a history of continuously strengthening environmental regulations and improving them. Starting from "China RoHS 1.0" in 2006, it was upgraded to version 2.0 in 2016, and then a qualitative leap was achieved in 2025- the first mandatory national standard GB 26572-2025 was officially introduced.
This process reflects China's determination to gradually align with international standards in environmental control of electronic products. Looking back at the development process, a clear trend is that the scope of control continues to expand, standard requirements are becoming increasingly strict, and regulatory measures are becoming more systematic.
The construction of a public service platform for restricting the use of hazardous substances in electrical and electronic products provides technical support for the comprehensive implementation. From the initial industry self-regulation to the current mandatory requirements, China RoHS has formed a complete regulatory system.
02 From "recommendation" to "coercion": a profound transformation
The most fundamental change brought about by the new standards is the essential upgrade of legal effectiveness. GB/T 26572-2011, as a recommended national standard, has only guiding significance for enterprises; As a mandatory national standard, GB 26572-2025 has legal enforceability.
This means that products that do not comply with the new standards will no longer be considered 'not in line with best practices', but will directly violate national regulations.
The underlying logic of corporate compliance has changed. In the past, companies could independently choose whether to follow recommended standards; Now, meeting mandatory national standards has become the basic threshold for entering the market. This change will reshape the competitive landscape of the entire industry.
03 10 substances! Significant expansion of control scope
The expansion of the hazardous substance control list is another major highlight of the new standard. From the initial 6 substances (lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls, polybrominated diphenyl ethers), to 10 controlled substances.
The four newly added phthalates (DBP, BBP, DEHP, DIBP) are widely present in plastic products and used as plasticizers. This means that almost all electronic products containing plastic components must re-examine their material compliance.
The expansion of product range is also significant. The latest "Standard Management Catalogue (Draft for Comments)" plans to significantly expand the categories of products subject to mandatory control from the current 12 categories to 33 categories, covering almost all common electrical and electronic products.
04 Management Strategy: "Two step approach" has become a foregone conclusion
China RoHS has established a clear "two-step" management framework. The first step is that all electrical and electronic products must meet labeling requirements and clearly indicate the presence of harmful substances.
The second step is that for products listed in the "Standard Management Catalog", they must meet the requirements for harmful substance limits and pass the qualification assessment process. This classification management approach not only achieves comprehensive coverage, but also highlights the key control points.
Enterprises must first determine whether their products fall within the scope of the 'Standard Management Catalogue'. This judgment determines whether the enterprise needs to meet the labeling requirements or the dual requirements of labeling and limited quantity.
05 Important Timetable: Enterprise Action Guide
According to the latest announcement, companies must pay attention to the following key time points:
From now until December 31, 2025, the new and old standards will be used in parallel. Enterprises can choose to conduct qualification assessment based on GB/T 26572-2011, GB/T 26572-2011 with amendments, or directly adopt GB 26572-2025.
From January 1, 2026 to July 31, 2027, there will be a transitional period for the abolition of the old standards. The 2011 version of the standard is no longer applicable, and companies must conduct qualification assessments according to the requirements of 10 substances.
Starting from August 1, 2027, the new national standard will be fully implemented. All products produced or imported must comply with the requirements of GB 26572-2025. In addition, the new standard also sets a one-year inventory digestion period, allowing previously produced products to be sold until July 31, 2028.
06 Enterprise Response: Four Step Compliance Strategy
Faced with increasingly strict compliance requirements, companies can adopt the following strategies:
The first step is to identify the product category. Immediately confirm whether the product belongs to the current or future expanded 'Standard Management Catalog'. This is the foundation for developing compliance strategies.
The second step is a comprehensive review of the supply chain. Thoroughly investigate the materials used in the product, especially plastic components, for the four newly added phthalates, and require suppliers to provide a declaration of conformity and testing reports.
Step three, internal process transformation. Prepare new environmental labels (including digital displays or QR codes) in accordance with the new national standards, update the table of hazardous substance content, and establish a mechanism for retaining technical documents.
The fourth step is to submit platform information. All qualification assessment information must be promptly submitted to the "China RoHS Public Service Platform for the Restriction of Hazardous Substances in Electrical and Electronic Products" to ensure traceable compliance status.
Real time data from the public service platform for restricting the use of hazardous substances in electrical and electronic products shows that thousands of companies have completed compliance filing, but there are still a large number of companies in a wait-and-see state.
The upstream material suppliers in the supply chain are beginning to receive a large number of testing requirements, and the business volume of testing institutions has surged. The head of a testing agency stated that the number of RoHS related testing inquiries has increased by 300% recently, and "most companies are asking about the testing methods and limit requirements for phthalates".
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