Adjustments to the Applicable Standards for Hazardous Substance Content Limits and Testing Methods Under the Compliance Assessment System, a crucial component of China's RoHS regulation, were announced on November 18, 2025, by the State Administration for Market Regulation and the Ministry of Industry and Information Technology. The notice stipulates that substance content testing must adhere to pertinent requirements in the GB/T 39560 series standards and explains the implementation timeline for standards governing hazardous substance content limitations, including GB/T 26572-2011, its NO.1 Supplement, and GB 26572-2025.
System for Compliance Assessment
Electrical and electronic products listed in the "Management Catalog for Electrical and Electronic Products Meeting Hazardous Substance Restriction Requirements" (currently 12 categories) are required by China's RoHS regulation to display information about the content of hazardous substances, comply with content limit requirements, and undergo compliance assessment. The system requires the firm or a third-party organization to provide verification of compliance with pertinent technical requirements and hazardous substance limitation guidelines.
Companies are required to select one of two assessment options:
Option 1: Certification on a voluntary basis Encouraged by the State, businesses can voluntarily apply for certification, with a third-party body confirming adherence to technical specifications and hazardous substance limitation standards.
Choice 2: Self-Statement
To demonstrate that their products adhere to technical requirements and hazardous material limitation criteria, suppliers—including manufacturers and authorized representatives—must report product compliance information and execute a conformity assessment using reasonable techniques.
The timeframe for implementing these criteria in compliance assessments is outlined in the most recent announcement:
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Period Standards Applicable for Compliance Assessment Transition from Previous Assessment Nov. 18, 2025 – Dec. 31, 2025 GB/T 26572-2011, or GB/T 26572-2011 with Supplement 1, or GB 26572-2025 No transition required Jan. 1, 2026 – July 31, 2027 GB/T 26572-2011 with Supplement 1, or GB 26572-2025 Products assessed under GB/T 26572-2011 and continuing to be manufactured or imported must switch to GB/T 26572-2011 with Supplement 1 or GB 26572-2025 by Jan. 1, 2027 Aug. 1, 2027 onward GB 26572-2025 Products assessed under GB/T 26572-2011 with Supplement 1 may transition to GB 26572-2025 through natural processes such as renewal upon expiration or updates due to product changes |
Testing Methods The announcement clarifies that RoHS compliance testing under GB/T 26572-2011, its Supplement 1, or GB 26572-2025 must follow applicable standards from the GB/T 39560 series. This series currently comprises 14 standards covering sample preparation, screening, and quantitative analysis of restricted substances—such as heavy metals, brominated flame retardants, phthalates, PAHs, HBCDD, and Cr(VI)—using methods including XRF, GC-MS, ICP-OES/MS, AAS/AFS, colorimetry, and combustion ion chromatography.
