China RoHS 2026: Electronics Supplier Compliance and Inspection Checklist

Among the most significant regulations affecting the electronics industry is China RoHS, formally known as the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products.

China RoHS, often viewed as China's equivalent of the European Union's RoHS Directive, regulates the use of hazardous substances in electrical and electronic products sold within the country. For manufacturers, importers, and suppliers, compliance involves much more than simply obtaining declarations from suppliers. It requires effective supply chain management, product testing, documentation, and ongoing due diligence.

As environmental regulations continue to evolve, businesses sourcing electronics from China need a structured approach to compliance. This guide explains the key requirements of China RoHS and provides a practical supplier compliance and inspection checklist to help manufacturers reduce risk and maintain market access.

Table of Contents

• What Is China RoHS?
• The 10 Substances That Are Now Restricted
• Two Types of Products — Two Sets of Rules
• The 23 New Product Categories Now Covered
• Labeling: What Your Products Must Show
• How to Prove Compliance: Two Options
• The Supplier Inspection Checklist
• Common China RoHS Compliance Gaps
• The Business Benefits of China RoHS Compliance
• Is Your Supply Chain Ready for China RoHS?
• How AMREP Helps

RoHS stands for Restriction of Hazardous Substances. It is a set of rules that limits how much of certain toxic materials can be present in electronics sold in a particular market.

You may already know about EU RoHS, the European version of this regulation. China has its own version, and the two are not the same. Passing EU RoHS does not automatically mean you pass China RoHS. They have different product lists, testing methods, labeling rules, and exemptions.

China RoHS is managed by China's Ministry of Industry and Information Technology (MIIT). It applies to any electrical or electronic product (EEP) that is manufactured in or sold into China.

The 10 Substances That Are Now Restricted

China RoHS restricts ten hazardous substances. All limits are measured at the homogeneous material level, meaning each individual material in the product, such as a coating, plastic part, or wire insulation layer, must stay within the limits, not just the product as a whole.

Pay special attention to the four phthalates (DBP, DIBP, BBP, DEHP). These are commonly found in plasticized cables, plastic housings, connectors, and rubber components. Many suppliers have not yet tested for these specifically, especially if their existing data was generated only for the EU market.

Two Types of Products — Two Sets of Rules

China RoHS splits all electronics into two groups. Which group your product falls into determines what you must do.

Category I — Products on the Catalogue

These products must:

• Stay within the substance limits for all 10 restricted substances
• Complete a formal conformity assessment
• Carry the correct environmental labeling

If your product was already in the 2018 Catalogue, you are probably familiar with these requirements. If your product is one of the 23 newly added categories, you now have to meet all three obligations for the first time.

Category II — All Other Electronics

Products not on the Catalogue still have obligations. They must carry the correct labeling and disclose hazardous substance information. They do not have to meet substance concentration limits, but they cannot skip labeling. Getting the labeling wrong is an enforcement trigger even for Category II products.

The big shift in 2026: Many products that companies had treated as "just labeling," including smart speakers, servers, routers, wearables, and home appliances, are now Category I. They require testing, documentation, and formal compliance declarations.

The 23 New Product Categories Now Covered

If you make or source any of the following products for the Chinese market, they are now subject to full China RoHS compliance requirements from August 1, 2027.

Home and Kitchen Electronics

Microwave ovens, rice cookers, water dispensers, projectors, robotic vacuum cleaners, electric smart locks

Connected and Digital Devices

Smart watches, smart bands, earphones and headphones, smart speakers, servers, routers, network switches, portable power banks

Health and Safety Products

Electric toys, reading lamps, electronic blood pressure monitors, blood glucose meters, hearing aids

Office Equipment Scope Expanded

Printers, copiers, fax machines, and scanners are now consolidated and their scope broadened

Five existing categories also have expanded definitions, so even if your product was already on the catalogue, you should check whether the new scope covers additional components or configurations that you supply.

Labeling: What Your Products Must Show

Labeling is one of the most commonly mishandled parts of China RoHS, and it applies to every electronics product sold in China, not just Category I items.

The EFUP Mark (Environmentally Friendly Use Period)

Every product needs an EFUP mark, a number inside a green circle or house symbol that indicates how many years the product can be used before the risk of hazardous substance leakage increases. This must appear directly on the product where it can be seen. If the product is too small or the surface does not allow it, the mark can instead appear in the product manual, on the packaging, or on your website.

The Hazardous Substance Content Table

Your product must include a table in Simplified Chinese that shows whether each of the 10 restricted substances is present in each major component. Even if your substance levels are well within the applicable limits, this table is still required.

QR Codes Are Now Allowed

GB 26572-2025 formally permits digital labeling. You can use a QR code or on-screen display to deliver hazardous substance information, which is helpful for small or compact products. The linked content must be current and complete.

Common mistake: Many companies publish their hazardous substance table in English only, or copy EU RoHS documentation without adapting it for China's format requirements. This creates a compliance failure even when the actual substances are fully compliant.

How to Prove Compliance: Two Options

For Category I products, you need to formally demonstrate compliance through one of two pathways.

Option 1: Supplier Declaration of Conformity (SDoC)

Your company (or an authorized agent) prepares a self-declaration stating that the product meets China RoHS requirements. This declaration must follow the requirements of GB/T 27050.1 and be submitted to the official China RoHS Public Service Platform. You will need test reports from CMA/CNAS-accredited labs using GB/T 39560 methods, and at least 70% of your components should be covered by test data.

This option is faster and lower-cost, but it requires strong internal controls. If your documentation is weak or your supplier data is unreliable, a self-declaration creates significant risk.

Option 2: Third-Party Certification

A qualified certification body tests and certifies your product. This results in the official China RoHS conformity mark being applied to your product. It takes more time and costs more, but it provides stronger market assurance and reduces enforcement risk, especially for products with complex global supply chains.

Either way, your compliance declaration must be registered on the China RoHS Public Service Platform, and it must reflect your current bill of materials. If you change a component or supplier after certification, a compliance review is required.

The Supplier Inspection Checklist

Use this checklist when auditing a supplier for China RoHS compliance, qualifying a new factory, or reviewing your own product portfolio ahead of the August 2027 deadline.

Section A: Is Your Product in Scope?

• Does the product meet the definition of an electrical or electronic product (EEP) sold in China?
• Is the product listed in the 2026 Compliance Management Catalogue (Category I)?
• Has the product portfolio been reviewed against the 23 newly added categories?
• Is the product's Category I or II status documented and assigned to a compliance owner?

Section B: Substance Testing

• Has testing been completed at the homogeneous material level for all 10 restricted substances?
• Are all test reports based on the GB/T 39560 series methods (not the old GB/T 26125)?
• Were tests conducted at a CMA or CNAS accredited laboratory in China?
• Has phthalate testing been completed specifically for cables, connectors, plastic housings, and rubber components?
• Do cadmium levels fall at or below 0.01% in all applicable materials?
• Does testing cover at least 70% of components at the component level?
• Has any EU RoHS test data been reviewed to confirm it meets China's testing method requirements, or does supplemental testing need to be ordered?

Section C: Supplier Documentation

• Do all Tier 1 suppliers have current RoHS compliance declarations covering all 10 substances?
• Are Material Declaration sheets or Full Material Declarations (FMDs) available for all key components?
• Is the Bill of Materials (BOM) current and traceable to tested material specifications?
• Are processes in place to detect component substitutions that might affect substance levels?
• Do supplier contracts include China RoHS notification obligations?

Section D: Exemption Checks

• Are all claimed exemptions verified against the 2026 China RoHS Exemption List (not the EU list)?
• Have the six removed exemptions been checked against current product configurations?
• Are the six new exemptions reviewed for potential applicability?
• Are exemption claims supported by technical documentation?
• Have products involving medical electronics, lighting, batteries, sensors, or plastics received detailed exemption review?

Section E: Labeling

• Does the product carry a visible EFUP mark in the correct format?
• Is the Hazardous Substance Content Table present, complete, and in Simplified Chinese?
• Does the table cover all 10 restricted substances across all major component categories?
• Does labeling comply with SJ/T 11364-2024 (now part of GB 26572-2025)?
• If QR code or digital labeling is used, does the linked content include all required information and is it currently accessible?
• Is the correct conformity assessment mark (SDoC or third-party certification) applied to Category I products?
• Do packaging and user manuals match the product labeling?

Section F: Conformity Assessment

• Has a conformity assessment pathway been selected (SDoC or third-party certification)?
• If SDoC: does the declaration meet GB/T 27050.1 requirements?
• Has the declaration been submitted to the China RoHS Public Service Platform?
• Are all referenced test reports current and from CMA/CNAS-accredited labs?
• Does the declaration reflect the current BOM, with no unapproved component changes since the last certification?

Section G: Records and Audit Readiness

• Is all compliance documentation version-controlled and linked to specific product models and production batches?
• Can documentation be retrieved quickly in the event of a MIIT or customs review?
• Is there a designated compliance owner tracking China RoHS regulatory changes?
• Has the team reviewed MIIT Announcement No. 11 of 2026 and the GB 26572-2025 guidance documents?

Common China RoHS Compliance Gaps

Many organizations face recurring challenges. The following gaps are among the most common challenges manufacturers and electronics suppliers face.

Overreliance on Supplier Declarations

Many companies rely solely on supplier declarations and certificates without independently verifying the information. While supplier documentation is important, declarations may be incomplete, outdated, or inaccurate, increasing the risk of non compliant materials entering the supply chain.

Limited Testing and Verification

Some organizations conduct little or no verification testing, relying entirely on supplier assurances. Without risk based testing programmes and periodic sampling, companies may fail to identify hazardous substance issues until products have already reached the market.

Poor Documentation and Record Keeping

Compliance activities may be performed, but supporting records are often incomplete, inconsistent, or difficult to retrieve. Missing declarations, outdated test reports, and inadequate documentation can make it difficult to demonstrate due diligence during customer or regulatory reviews.

Weak Supplier Oversight

Many manufacturers do not regularly assess their suppliers' hazardous substances management capabilities. Limited supplier audits and insufficient monitoring can result in poor material controls and increased compliance risks throughout the supply chain.

Inadequate Change Management

Changes to materials, components, suppliers, or manufacturing processes can introduce new compliance risks. Without formal change control procedures, organizations may unknowingly use materials that no longer meet China RoHS requirements.

Limited Material Traceability

Some companies struggle to trace materials and components back to specific suppliers or production lots. Weak traceability systems can significantly delay investigations and corrective actions when potential compliance issues arise.

Identifying and addressing these common gaps can significantly reduce compliance risks and strengthen an organization's overall hazardous substances management programme.

The Business Benefits of China RoHS Compliance

Organizations that invest in China RoHS compliance often realize benefits that extend far beyond meeting regulatory requirements.

Reduced Supply Chain Risk

Improved supplier oversight and material visibility help identify risks earlier and reduce the likelihood of supply chain disruptions.

Improved Product Quality

Stronger material controls and verification processes contribute to greater product consistency and reliability.

Greater Customer Confidence

Customers increasingly expect manufacturers to demonstrate environmental responsibility and robust compliance programmes.

Enhanced Market Access

Effective compliance supports entry into regulated markets and helps avoid delays, product restrictions, and customer concerns.

Better Operational Control

Improved documentation, traceability, and change management processes strengthen overall quality management and decision making.

A thorough supplier audit can uncover quality, compliance, and production risks before they impact your business. Learn more in our guide on Supplier Audits: What They Are and Why Your Business Can’t Ignore Them.

Is Your Supply Chain Ready for China RoHS?

Use the following questions to assess your organization's readiness:

• Do you know which products and components fall within the scope of China RoHS?
• Can you identify all materials and substances used in your products?
• Do you maintain current supplier declarations and supporting documentation?
• Have you independently verified compliance through testing or audits?
• Are material and supplier changes formally assessed and approved?
• Can you trace materials and components to specific suppliers and production lots?

If the answer to any of these questions is no, your organization may have compliance gaps that require attention. Identifying and addressing these weaknesses early can significantly reduce risk and strengthen your long term compliance strategy.

Ongoing supplier monitoring is essential for maintaining compliance long after the initial audit. Our article on Monitor Supplier Performance Remotely: Tools & Tactics explores practical ways to strengthen supplier oversight across global supply chains.

How AMREP Helps

Navigating China RoHS on paper is one thing. Verifying it at the factory floor is another.

AMREP Inspect has worked with electronics manufacturers and OEMs across China, Vietnam, Malaysia, Thailand, and Mexico for over 35 years. Through our Quality Management Solutions, we put qualified engineers on site at your contract manufacturer or supplier to verify that compliance is real, not just declared.

What We Do for China RoHS Readiness

We conduct supplier audits that check BOM documentation, test report validity, substance testing coverage, and labeling accuracy against the 2026 Catalogue requirements. We do source inspections at the factory before shipment, checking labels, documentation, and traceability in person, not just on paper. Our resident quality engineers work directly at supplier sites to build the documentation systems and supplier controls that make ongoing compliance sustainable. And when corrective actions are required, our on site team follows them through to closure, which is where most compliance programmes quietly fail.

If you are selling electronics into China and the 2026 updates affect your product line, the time to act is now, not the month before the August 2027 deadline.