China RoHS control upgrades: Interpretation of new standards and compliance guide

Hey friends! You cant afford to be careless about trade risk compliance. On April 14, 2025, the Department of Science and Technology of the Ministry of Industry and Information Technology made a major move by releasing three mandatory national standard drafts including Requirements for the Restriction of Hazardous Substances in Electrical and Electronic Products for public consultation. This is no small matter - we need to carefully consider it.

Main content and changes of the new standards

The changes in these new standards are significant, mainly including the following points:

Expansion of hazardous substance categories

• From 6 categories to 10 categories: Added four phthalate substances including DBP, DIBP, BBP, and DEHP.
• Limit requirements: All newly added substances have a limit requirement of ≤0.1% (mass fraction).

Chinese name	English name	Abbreviation	CAS number	Limit (mass fraction)
Lead	Lead	Pb	7439-92-1	≤0.1%
Mercury	Mercury	Hg	7439-97-6	≤0.1%
Cadmium	Cadmium	Cd	7440-43-9	≤0.01%
Hexavalent chromium	Hexavalent chromium	Cr(VI) or Cr6+	18540-29-9	≤0.1%
Polybrominated biphenyls	Polybrominated biphenyls	PBBs	—	≤0.1%
Polybrominated diphenyl ethers	Polybrominated diphenyl ethers	PBDEs	—	≤0.1%
Dibutyl phthalate	Dibutyl phthalate	DBP	84-74-2	≤0.1%
Diisobutyl phthalate	Diisobutyl phthalate	DIBP	84-69-5	≤0.1%
Butyl benzyl phthalate	Butyl benzyl phthalate	BBP	85-68-7	≤0.1%
Bis(2-ethylhexyl) phthalate	Bis(2-ethylhexyl) phthalate	DEHP	117-81-7	≤0.1%

Category management

• Category I products: Products included in the Compliance Management Catalog for Restricted Use of Hazardous Substances in Electrical and Electronic Products must strictly comply with the limit requirements in Chapter 5 and marking requirements in Chapter 6.
• Category II products: Products not included in the management catalog must comply with the marking requirements in Chapter 6.

Electrical and electronic product categories	Classification of electrical and electronic products	Restriction requirements for hazardous substances
Category I	Products included in the Compliance Management Catalog for Restriction of Hazardous Substances in Electrical and Electronic Products	Shall comply with the limit requirements specified in Chapter 5 (including limit values, testing methods, compliance determination requirements, testing unit classification and requirements, compliance determination rules) and the labeling requirements specified in Chapter 6 (including general requirements, marking requirements, format and requirements for hazardous substance information tables in electrical and electronic products, labeling requirements, and documentation retention).
Category II	Products not included in the Compliance Management Catalog for Restriction of Hazardous Substances in Electrical and Electronic Products	Shall comply with the labeling requirements specified in Chapter 6 (including general requirements, marking requirements, format and requirements for hazardous substance information tables in electrical and electronic products, labeling requirements, and documentation retention).

Labeling method upgrade

• Introduction of digital labels: Such as QR codes, to facilitate consumers access to product hazardous substance information.

Transition period provisions

• Implementation Time: Implementation begins 24 months after the standard is issued.
• Transition period: For products manufactured or imported before the standard implementation date, compliance with the new standard requirements is required starting from the 13th month after implementation.

Removal of redundant content

• Simplification of standards: Deleted content from the original standard regarding the disassembly of electrical and electronic products and typical disassembly examples.

Impact and requirements of the new standard on enterprises

The issuance of the new standard imposes higher compliance requirements on enterprises, with the main impacts and requirements as follows:

• Comprehensive understanding of the new standard: Enterprises need to quickly familiarize themselves with the content and changes of the new standard to ensure that product design, production, testing, and other processes comply with the new requirements.
• Attention to hazardous substance limits and labeling: Ensure that the content of hazardous substances in products does not exceed the specified limits and that labeling is performed as required.
• Classification compliance: Take corresponding compliance measures based on whether the product is included in the management catalog (Category I or II).
• Attention to the transition period: Ensure compliance work is completed during the transition period to avoid violation risks.

Compliance recommendations and measures

To help enterprises smoothly comply with the new standards, here are some practical compliance suggestions and measures:

Establish a comprehensive compliance management system

• Start from the source: Consider hazardous substance control during the product design phase, selecting raw materials and components that meet the standards.
• Process management: Establish a full-process compliance management mechanism covering procurement, production, testing, and sales.

Strengthen Supply Chain Management

• Supplier evaluation: Build close cooperation with suppliers to ensure their provided raw materials and components meet the new standard requirements.
• Contract Agreement: Clearly specify hazardous substance limit requirements in procurement contracts to ensure supplier responsibilities and obligations.

Adopt advanced testing technologies

• Regular testing: Conduct periodic hazardous substance content testing on products to ensure compliance with standard requirements.
• Cooperation with testing institutions: Partner with authoritative testing institutions to ensure the accuracy and reliability of test results.
• Database establishment: Build a hazardous substance database to monitor product content in real-time, promptly identifying and addressing issues.

Update product labeling

• Adopt new labeling methods: Such as QR codes, ensuring consumers can easily access product hazardous substance information.
• Label content: Ensure labeling content is accurate, complete, and complies with the new standard requirements.

Strengthen employee training

• Enhance compliance awareness: Through training, help employees understand the importance and specific requirements of the new standards.
• Skill improvement: Train employees in hazardous substance testing and labeling methods and skills.

Regular self-inspection and improvement

• Self-inspection mechanism: Establish a regular self-inspection mechanism to promptly identify and correct non-conformities.
• Continuous Improvement: Continuously optimize the compliance management system based on self-inspection results and market feedback.

Conclusion

The release of the new standard is a significant event for the electrical and electronic products industry, and companies must actively respond. By establishing a comprehensive compliance system, strengthening supply chain management, adopting advanced testing technologies, updating product labeling, enhancing employee training, and conducting regular self-inspections, companies can not only smoothly meet the challenges of the new standard but also enhance their competitiveness and sustainable development capabilities. Friends, lets work hard!