China RoHS 2026 Catalogue Expands Product Scope and Exemption List

China RoHS 2026 Catalogue: What Has Changed?

The 2026 update is not simply an administrative refresh. It expands the compliance management scope and aligns the product catalogue with China’s new mandatory standard, GB 26572-2025, which will apply from August 1, 2027.

The updated catalogue:

• consolidates the original 12 product types into 10 categories;

• adds 23 new product categories;

• covers 33 product categories in total;

• updates product definitions and scope descriptions;

• introduces a revised exemption list for restricted substance applications.

The newly covered products mainly fall into three practical risk areas for global companies:

This means companies that previously treated China RoHS as a marking or disclosure-only issue may now need to prepare for substance restriction verification and conformity assessment for additional products.

Key Compliance Dates for China RoHS 2026

Companies should pay particular attention to products that were not previously in the first-batch catalogue but will fall into the 2026 Catalogue from August 2027. These products may require new technical documentation, supplier data, testing evidence and conformity assessment planning.

What Companies Need to Comply With

Products listed in the 2026 Catalogue must comply with the applicable restricted substance requirements under China RoHS and supporting standards.

The controlled substances include:

• lead (Pb);

• mercury (Hg);

• cadmium (Cd);

• hexavalent chromium (Cr(VI));

• polybrominated biphenyls (PBBs);

• polybrominated diphenyl ethers (PBDEs);

• di(2-ethylhexyl) phthalate (DEHP);

• butyl benzyl phthalate (BBP);

• dibutyl phthalate (DBP);

• diisobutyl phthalate (DIBP).

For catalogue products, companies will need to complete conformity assessment through either:

• state-promoted voluntary certification; or

• self-declaration of conformity.

The conformity assessment results must be uploaded to the China RoHS Public Service Platform for public supervision.

Companies should also note that China RoHS obligations are not limited to catalogue products. Under the existing China RoHS framework, electrical and electronic products, whether included in the Compliance Management Catalogue or not, are still required to provide hazardous substance content information and use the relevant marking correctly.

Updated Exemption List: Do Not Assume EU RoHS Equivalence

The 2026 Exemption List has also been revised. According to MIIT’s policy interpretation, the update removes six exemption clauses, updates one clause, refines ten clauses and adds six new exemption clauses.

For companies already managing EU RoHS compliance, this is a critical point. China’s exemption list may reference international practices, but it should not be treated as identical to the EU RoHS exemption system.

Companies should therefore:

• check whether each restricted substance use is expressly covered by the 2026 Exemption List;

• verify exemption conditions, scope and validity requirements;

• avoid relying only on EU RoHS exemption conclusions;

• document the technical basis for any exemption claim;

• update product compliance files when exemption wording changes.

This is especially important for components, spare parts, repair or refurbishment scenarios, and products involving medical electronics, lighting, batteries, sensors, soldering, coatings or plastics.

Impact & Actionable Advice for Global Manufacturers

The 2026 China RoHS update will mainly affect companies that manufacture, import, sell or supply electrical and electronic products into China. The practical compliance burden will depend on product category, supply chain complexity and whether the product is newly included in the catalogue.

1. Map Products Against the 2026 Catalogue

Companies should first determine whether their products fall within the updated catalogue or newly expanded product scopes.

Recommended actions include:

• reviewing all China-bound SKUs against the 33 product categories;

• identifying newly covered products subject to the August 1, 2027 deadline;

• checking whether accessories, adapters, smart devices or electronic modules are sold separately;

• confirming whether the product is sold as an end product or only as a component for another product.

Product classification should be completed early because it determines whether substance limits, conformity assessment and platform submission obligations apply.

2. Collect 10-Substance Data Across the Supply Chain

The expansion of China RoHS means companies need more reliable substance data from suppliers, especially for phthalates and high-risk components.

Recommended actions include:

• collecting declarations covering all 10 restricted substances;

• reviewing BOMs, plastics, cables, coatings, solders and electronic components;

• identifying suppliers still using outdated six-substance RoHS declarations;

• arranging targeted testing for high-risk materials or uncertain data;

• maintaining traceable documentation for conformity assessment and customer review.

3. Prepare Conformity Assessment Strategy

Catalogue products must complete China RoHS conformity assessment. Companies should decide whether to use voluntary certification or self-declaration based on product risk, customer requirements and market strategy.

Recommended actions include:

• confirming the applicable assessment route;

• preparing technical documentation;

• aligning test reports with GB 26572-2025 and related testing standards;

• reviewing marking and hazardous substance information disclosure;

• preparing for submission to the China RoHS Public Service Platform.

For multinational electronics companies, the self-declaration route may appear efficient, but it requires strong internal documentation control and reliable supplier evidence.

4. Review Product Marking and Customer-facing Information

China RoHS is not only a substance restriction regime. It also includes marking and hazardous substance content information requirements.

Companies should check whether:

• product labels and manuals contain required China RoHS information;

• hazardous substance content tables are accurate and consistent;

• Environmental Protection Use Period or related marking is properly determined;

• digital or screen-based information display is acceptable for the product type;

• online or distributor materials are consistent with product compliance files.

Incorrect marking or inconsistent disclosure may create regulatory and commercial risks even where substance limits are met.

5. Reassess Exemptions Before the 2027 Deadline

For products relying on restricted substance exemptions, companies should recheck each use against the 2026 Exemption List.

Recommended actions include:

• identifying all restricted substance uses above applicable limits;

• checking whether an exemption applies under the China-specific list;

• reviewing whether the exemption wording has been removed, refined or replaced;

• documenting technical justification for the exemption;

• preparing alternative materials or redesign plans where exemptions no longer apply.

This step is particularly important for companies using global RoHS compliance data generated primarily for the EU market.

Looking Ahead

The 2026 China RoHS update shows that China is moving toward a more comprehensive and structured control system for hazardous substances in electrical and electronic products. With the expansion of regulated product categories, the addition of new restricted substances under GB 26572-2025, and the updated exemption framework, companies supplying the China market will need to manage product composition, supplier data, conformity assessment evidence and China-specific disclosure requirements more carefully.

Although the transition period gives newly covered products time to prepare before August 1, 2027, the practical work required for product mapping, material data collection, supplier coordination and technical documentation may take much longer than expected. Global manufacturers and exporters should use this period to review affected product lines, identify compliance gaps and align internal RoHS management systems with China's updated requirements.

As China RoHS continues to evolve, companies should closely monitor official updates from MIIT and related authorities, especially further implementation guidance, conformity assessment requirements and changes to exemption rules. Early preparation will help reduce market access risks and improve supply chain readiness before the new requirements fully apply.