As of mid-2025, China has significantly advanced its regulatory framework governing the environmental compliance of electrical and electronic products. These changes—led by the updated China RoHS 2.0 and related green product standards—affect a wide range of industries and are reshaping the requirements for market access. For manufacturers, suppliers, and exporters, understanding these evolving obligations is essential not only for legal compliance but for long-term competitiveness in the Chinese market.
Understanding China RoHS 2.0
China RoHS 2.0, formally titled the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products, builds on the earlier version of the regulation with a broader product scope, stricter documentation expectations, and integration with national green development strategies. While it aligns with the EU RoHS in terms of core restricted substances—such as lead, mercury, cadmium, and hexavalent chromium—it also introduces domestic mechanisms for enforcement and transparency, including product registration and detailed labeling.
One major change is the expanded scope of coverage. A wider range of electrical and electronic equipment is now subject to compliance, including home appliances, telecommunications devices, office electronics, lighting products, power tools, toys, and certain industrial controls. Whether a specific product falls under the mandatory compliance framework is determined by its inclusion in the Key Product Catalog, which is maintained and updated by Chinese authorities.
Manufacturers must ensure that their products do not exceed the maximum concentration values of hazardous substances, which are generally consistent with international norms—0.1% or 0.01% by weight in homogeneous materials. Additional substances, particularly certain phthalates, are under review for future inclusion.
Material Declarations and Labeling Requirements
A central feature of China RoHS 2.0 is the obligation to submit product material declarations through the China RoHS Public Service Platform, a mandatory online reporting system somewhat comparable to the EU's SCIP database, though more centralized and directly tied to enforcement authorities. This system enables regulators to monitor compliance and allows for public transparency on restricted substance content.
In addition to regulatory declarations, manufacturers must ensure their product labeling complies with national standard GB/T 26572. This includes clearly displaying the Environmentally Friendly Use Period (EFUP)—an indicator of the timeframe during which hazardous substances will not leak or cause harm—and a standardized hazardous substance table. Products that meet voluntary eco-design criteria may also display the green “e” mark, a signal of higher environmental performance.
Green Supply Chain and Lifecycle Expectations
Beyond product-level requirements, China is integrating environmental performance into broader green supply chain initiatives. For businesses supplying components to major OEMs or participating in public procurement, this means meeting additional requirements related to energy efficiency, material recovery, and full lifecycle assessment. These obligations are part of China’s larger strategy to build a circular economy and reduce dependence on virgin raw materials.
What You Should Be Doing Now
For companies that manufacture or sell electrical and electronic products in China, 2025 is a critical year for compliance readiness. The first step is to review your current product portfolio against the latest version of the Key Product Catalog to determine which items fall under mandatory compliance. If any of your products are in scope, you will need to collect complete material declarations for all components and subassemblies and ensure that the information is properly submitted to the RoHS Public Service Platform.
In parallel, product labeling and user documentation should be reviewed and updated to include all required environmental information. This includes the EFUP indicator, hazardous substance disclosures, and any supporting detail aligned with GB/T 26572. Working closely with your suppliers to validate materials data is essential, as is setting up internal documentation processes to manage ongoing compliance.
Engagement with local legal or regulatory advisors may also be necessary to ensure full conformity with national requirements, particularly for companies unfamiliar with the RoHS submission process in China. Taking proactive steps now will not only help prevent supply chain disruptions or customs delays but also demonstrate commitment to sustainability in one of the world’s most important and tightly regulated electronics markets.
