Public Consultation on the Final Draft of the Mandatory National Standard Requirements for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products
If you have any comments, please fill out the Feedback Form for Mandatory National Standards (attached) and send it by email to KJBZ@miit.gov.cn (please specify in the subject line: “Feedback on the Final Draft for Approval of the Mandatory National Standard Requirements for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products”).
Contact numbers: +86-10-64102958, +86-10-68205261
Department of Science and Technology,
Ministry of Industry and Information Technology
April 14, 2025
Background on the Standard Development
“China RoHS” refers to the Regulations for the Administration on the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products. It is China’s regulatory system aimed at restricting hazardous substances in electrical and electronic products, similar in nature to the EU RoHS Directive. The first version came into effect in 2006 (RoHS 1), and the current version (RoHS 2) has been in force since July 1, 2016.
On December 28, 2023, the Standardization Administration of China (SAC) issued the project task for developing a new mandatory national standard titled Requirements for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products (Project No. 20231685-Q-339). The MIIT initiated the development and designated SAC/TC297/SC3 (Subcommittee on Hazardous Substance Testing Methods under the National Technical Committee on Environmental Standardization for Electrical and Electronic Products and Systems) to organize the drafting. The China Electronics Standardization Institute (CESI) was appointed to lead the process. The planned development period is 16 months.
Following the task assignment, SAC/TC297/SC3 issued an official call for standard drafting organizations between January 26 and February 29, 2024. On March 20, 2024, the lead drafting organization CESI held a kick-off meeting in Beijing. The drafting working group was formally established, consisting of electrical and electronic product manufacturers, industry associations, research institutes, and relevant testing and certification bodies—representing key stakeholders involved in hazardous substance control.
On October 10, 2024, the working group completed the draft for public consultation and submitted it to MIIT’s Department of Energy Conservation and Comprehensive Utilization. Between November 19, 2024 and January 18, 2025, MIIT’s Department of Science and Technology issued a public consultation notice. After collecting public feedback, the drafting team revised the text accordingly. On March 16, 2025, SAC/TC297/SC3 convened a full committee review meeting (online). The final draft was revised based on committee comments and submitted for approval.
Key Considerations Behind the Technical Content
Regulatory Alignment
The standard directly supports the Regulations for the Administration on the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products and aligns in terms of product scope and regulatory objectives.
Need for a Mandatory Standard
Previously, the main supporting standards were GB/T 26572-2011 (Requirements for Concentration Limits for Certain Hazardous Substances in Electrical and Electronic Products) and SJ/T 11364-2014 (Marking for Restriction of Hazardous Substances in Electronic and Electrical Products), both of which are recommended standards. The lack of legal enforceability and ambiguity in their application has led to compliance issues. Some companies misinterpreted the standards as voluntary, resulting in inadequate labeling or failure to meet concentration limits, even for products listed in the Conformity Management Catalogue. Hence, a mandatory standard is necessary.
Closing the Legal Gap
Currently, China lacks a legal basis for enforcing recommended standards in support of mandatory regulations. This standard resolves the disconnect between regulatory requirements and technical implementation, while also updating technical content to reflect industry developments.
International Alignment
The standard specifies limit values for 10 hazardous substances—lead, mercury, cadmium, hexavalent chromium, PBB, PBDE, DEHP, DBP, BBP, and DIBP—which are consistent with the EU RoHS Directive (2011/65/EU).
Scope, Implementation, and Transition
This standard consolidates and updates the technical content of GB/T 26572-2011 and SJ/T 11364-2014. It will officially replace GB/T 26572-2011 and its amendment upon implementation, and it is recommended that SJ/T 11364 be withdrawn.
Given that the previous standards have been implemented for many years, and considering the industry's readiness, a two-year transition period is proposed before the new standard comes into force. Additionally, for products manufactured or imported prior to the implementation date, a one-year grace period is proposed—starting from the 13th month after the implementation date—to allow for inventory clearance.
This standard applies to all products falling under the scope of China RoHS. It does not specify conformity assessment methods or requirements.
For electrical and electronic products listed in the Conformity Management Catalogue, conformity assessment shall be conducted in accordance with relevant implementation documents, including the Implementation Plan for the Conformity Assessment System, Voluntary Certification Rules, and Supplier Declaration of Conformity Rules.
Due to the short consultation period (only one week), BESTAO provides the above summary only. For inquiries, please contact: assistant@bestao-consulting.com
