China RoHS and Chemical Restrictions Update: 14 Restricted Substances and the July 1, 2025 Compliance Deadline

China’s Ministry of Industry and Information Technology (MIIT) published the revised Standards for Restricted Use of Hazardous Substances in Electrical and Electronic Products (GB/T 26572-2024) on October 15, 2024, expanding the controlled substances list from 6 to 14 compounds and setting a mandatory compliance date of July 1, 2025 for all new products entering the Chinese market. This marks the most significant tightening of China RoHS (《限制使用有害物质标准》, Xiànzhì Shǐyòng Yǒuhài Wùzhì Biāozhǔn) in nearly a decade, directly affecting over 40 product categories and an estimated 85% of imported electronic devices. The update closes a key regulatory gap between China and the EU RoHS Directive, while introducing unique domestic requirements for labeling, declaration, and market surveillance that foreign executives cannot afford to overlook.

What Changed: From 6 to 14 Restricted Substances

The core change is the expansion of the restricted substances list from the original six — lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), and polybrominated diphenyl ethers (PBDE) — to 14 substances, adding eight new entries including four phthalates and bisphenol A (BPA). This mirrors the EU RoHS 2015/863 amendment but with tighter maximum concentration values (MCVs) for three of the new substances. The updated standard also introduces a revised “China RoHS Logo” requirement under the 达标管理目录 (Compliance Management Catalog, Dábiāo Guǎnlǐ Mùlù), mandating that all 14 substances be declared on product labels and in technical documentation submitted to the China Electronic Product Compliance Database (CEPD).

* Includes hexabromocyclododecane (HBCDD), short-chain chlorinated paraffins (SCCP), and perfluorooctanoic acid (PFOA).

Products Affected: Expanded Scope and New Categories

The updated standard applies to all 电器电子产品 (Electrical and Electronic Products, Diànqì Diànzǐ Chǎnpǐn) placed on the Chinese market, covering the existing seven mandatory categories from the 2016 catalog — large household appliances, small household appliances, IT and telecommunications equipment, consumer electronics, lighting, electrical tools, and toys — while adding three new categories: medical devices with electronic components, monitoring and control instruments, and automatic dispensers. This expansion brings an estimated 12 million additional product units per year under China RoHS compliance obligations, based on 2023 import volume data from the General Administration of Customs. Products manufactured before July 1, 2025 can continue to use the old six-substance declaration until their end-of-life, but any product introduced after that date — including model upgrades or revamped packaging — must comply with the full 14-substance standard. The transition period of 8.5 months is the shortest in China RoHS history; the original 2006 standard gave 18 months, and the 2016 revision gave 12 months.

Compliance Timeline and Testing Requirements

From July 1, 2025, manufacturers and importers must submit a “14-substance Conformity Declaration” to the CEPD for each product model, backed by test reports from China National Accreditation Service (CNAS)-accredited laboratories. Testing costs are expected to increase from an average of RMB 18,000 per product family under the 6-substance regime to approximately RMB 45,000–72,000 per product family under the 14-substance regime, depending on the number of homogenous materials tested. The new testing protocols require XRF screening for metals, GC-MS for phthalates, and LC-MS/MS for BPA, adding an estimated 3–5 weeks to the typical 8-week compliance cycle. MIIT has also indicated that unannounced market surveillance inspections will increase by 60% in 2025–2026, with a focus on imported products in the IT and medical device categories, which accounted for 73% of all China RoHS violations in 2023 (source: MIIT Market Surveillance Report 2023).

Market Surveillance and Penalties

Non-compliance carries significant financial and operational consequences under the updated regulation. Fines for first-time violations range from RMB 50,000 to RMB 500,000, with repeat offenders facing fines up to RMB 1,000,000 and mandatory product recalls. Imported products found non-compliant are subject to detention at customs, and repeated violations can result in a three-year suspension from the Chinese market. In 2023, 18 foreign brands were publicly named by MIIT for China RoHS non-compliance, resulting in an average 22% drop in quarterly sales in China for the affected product lines. The updated regulation also introduces “responsible person” provisions — a designated compliance officer within the importer or manufacturer must be named for each product family, and that individual bears personal liability for accurate declarations. This mirrors the EU’s Responsible Person framework under the EU REACH regulation, making compliance a corporate governance issue rather than a purely technical one.

How This Differs from EU RoHS

While China RoHS 2024 aligns with EU RoHS on the core 10 substances (the original six plus four phthalates), it diverges in four critical ways. First, China adds BPA (MCV 100 ppm), HBCDD (500 ppm), SCCP (500 ppm), and PFOA (1000 ppm) — none of which are restricted under the current EU RoHS Directive. Second, China requires a “material declaration” format specified in GB/T 26572 Appendix B, which differs from the EU’s CE-marking documentation structure. Third, China mandates that the declaration be uploaded to the CEPD database and made publicly accessible, whereas the EU allows private declaration of conformity. Fourth, China enforces a “retrospective liability” clause: if a product passes customs but is later found non-compliant during market surveillance, the importer bears full liability including recall costs, which can reach RMB 3M–8M depending on product volume. Foreign executives should treat China RoHS as a separate compliance regime, not a subset of EU RoHS.

Action Framework for Foreign Executives

If your product portfolio includes fewer than 50 SKUs and your supply chain has existing EU RoHS data, choose a direct testing approach: submit each model to a CNAS-accredited lab for full 14-substance analysis, budget RMB 180,000–300,000 for testing, and target a February 2025 submission date. If your portfolio exceeds 200 SKUs or contains highly varied material compositions, choose a material declaration approach: work with your tier-1 suppliers to collect material-level declarations against the 14-substance list, conduct random verification testing on 10% of materials, and budget RMB 400,000–600,000 for the program. If your products fall under a newly added category (medical devices, monitoring instruments, automatic dispensers), choose a regulatory review approach: engage a China-based compliance consultancy to determine whether your specific product qualifies for any transitional exemptions — MIIT has indicated that some medical device subcategories may receive a 12-month extension, though this has not been officially confirmed as of December 2024.

NEXT STEPS

1. Audit your current product portfolio against the 14-substance list. Use our China RoHS Compliance Checklist to identify which products need accelerated testing. Begin with your top-selling SKUs in the Chinese market.
2. Request a “China RoHS gap analysis” from your testing partner. Contact our accredited testing partner for a free 14-substance gap report — turnaround time for the gap analysis is typically 5 business days.
3. Establish a China-specific compliance documentation system. Download our China Market Entry Compliance Framework that includes CEPD submission templates, label design guidelines, and market surveillance response protocols.

— China Gateway 360 —
Remote China market entry support, built around execution.