China RoHS 2: What You Need to Know About the Latest Compliance Requirements

If you’re building, selling, or shipping electronics into China, this regulation isn’t a footnote. China RoHS 2 (the Restriction of Hazardous Substances) is a mandated, enforced, and expanding compliance regime managed by MIIT — and it’s very different from what you’re used to under EU RoHS.

It covers:

• More than 12 product categories
• Substance thresholds at the homogeneous material level
• Mandatory EFUP labeling
• An exemption list tied to the China RoHS 2 Catalogue, not the EU Annex

And with 2024’s Amendment No. 1 now in force, it’s only getting tighter.

China RoHS 2 Scope: 12 Categories That Are Already Under the Microscope

Back in March 2019, China implemented the Standard Management Catalogue of Electrical and Electronic Equipment. It lists 12 product types that must comply with the GB/T 26572-2011 hazardous substance limits — unless specifically exempted.

The covered EEE categories include:

• Televisions, monitors, mobile phones, and computers
• Home appliances like refrigerators, air conditioners, and washing machines
• Printers, copy machines, and fax machines
• Electric water heaters and telephones

⚠️ If your product is on that list, RoHS compliance in China is legally binding — not voluntary.

China RoHS 2 Substance List: Same Limits as EU RoHS — for Now

China RoHS 2 restricts 10 substances, aligned with EU RoHS 3 — but don’t get comfortable:

These four phthalates were added in Amendment No. 1 to GB/T 26572, published in June 2024.

Your compliance clock runs out on January 1, 2026. Miss the deadline, and you're not shipping anything into China.

EFUP Isn’t a Label — It’s a Legal Declaration

Unlike the EU, where documentation lives behind the scenes, China wants labels — prominently and precisely.

If your product contains restricted substances above the limits, you must:

• Declare the Environmental Protection Use Period (EFUP)
• Use China’s official symbol (SJ/T 11364-2014 compliant)
• Indicate the number of years it can be safely used before substance leakage risk

The EFUP isn’t optional. It’s not "nice to have." And mislabeling it? That’s a compliance breach with teeth.

Yes, There’s China RoHS 2 Exemption List — But Only for 39 Specific Uses

China’s RoHS exemption list isn’t a mirror of the EU's Annex III — but it’s close.

There are 39 approved exemptions, mostly covering:

• Lead in alloys, solders, and ceramics
• Cadmium in specific applications
• Mercury in lighting

If your use case isn’t listed? You don’t have a grace period — you have a liability.

The Testing Rulebook Changed in 2024. Did You?

As of March 1, 2024, China RoHS 2 conformity is evaluated using the GB/T 39560 series — not the outdated GB/T 26125.

These standards are aligned with IEC 6232, giving global manufacturers one less headache — if their labs are ready.

Don’t rely on legacy reports. Start fresh. Align now.

Marking Compliance: SJ/T 11364-2014 Isn’t Just for Exports

Whether your product is fully compliant or includes restricted substances above limits, it must be labeled according to SJ/T 11364-2014.

That includes:

• The “e” mark or hazardous symbol
• The EFUP icon
• A hazardous substance content table
• Product traceability and contact information

No label = no market access.

China RoHS 2 Enforcement Is Real: Fines, Recalls, and CCC Certification

Compliance is enforced through China’s Compulsory Certification (CCC) system. Expect:

• Third-party lab validation
• Supply chain documentation audits
• Penalties for non-conformance, including fines and forced product withdrawal

Compliance isn’t a checkbox — it’s a moving target.

What To Do Now

• Audit your full material disclosures
• Update your compliance documentation to GB/T 39560
• Track China RoHS 2 exemptions in the 2019 MIIT catalogue
• Prep your EFUP and labeling per SJ/T 11364-2014
• Test for phthalates now — not in December 2025

Let Acquis Handle China RoHS 2 Complexity

RoHS compliance isn’t a box to check — it’s a risk to manage.

Acquis automates China RoHS 2 compliance so you can:

• Track restricted substances
• Flag at-risk components
• Manage EFUP and exemptions
• Generate audit-ready documentation
• Stay ahead of MIIT updates

Book a 20-minute with Acquis China RoHS2 Compliance experts. Find the gaps. Close them before MIIT does.