China RoHS: Draft Updated Compliance Management Catalog and Application Exception List Open for Public Comment

On November 3, 2025, China's Ministry of Industry and Information Technology (MIIT) issued a notice seeking public comments on two draft documents – the Catalog for Compliance Management of the Restriction of Hazardous Substances in Electrical and Electronic Products (2025 Edition) and the draft List of Applications Exempted from Restricted Substances in the Compliance Management Catalog (2025 Edition). The updated drafts consolidate the first batch of 12 products into ten categories, and add 23 new product types. The public consultation period will remain open until December 2, 2025.

Key Updates

• Expansion of the Compliance Management Catalog

The first batch of 12 products has been optimized and consolidated into 10 categories (e.g., printers, copiers, and fax machines are merged into one category: Printing/Copying/Scanning/Faxing and Multi-function Machines). Furthermore, 23 new product types with relatively mature control conditions have been added.

After this adjustment, the Catalog will contain a total of 33 product types (see table below), all of which are electrical and electronic products frequently used by consumers in daily life.

• Update of the Application Exception List

Amendments are made to relevant exemption clauses based on newly effective domestic provisions of international environmental conventions like the Minamata Convention on Mercury. For example, the exemption for mercury in single-capped fluorescent lamps for general lighting is deleted.

Some exemption clauses are revised with reference to international exemption requirements and the newly added controlled products. For instance, the exemption for lead in solders for flip-chip packages is deleted, while a new exemption for phthalates in components recycled from electronic medical devices and used for repair/refurbishment is added.

• Effective Dates

Existing products from the first batch Catalog are planned to take effect immediately upon the publication of the revised Catalog.

Newly added product categories are granted a transition period and are planned to take effect from August 1, 2027.

The revised Exception List will replace the first batch List upon publication. Exemptions that are retained or newly added take effect immediately. Exemptions slated for deletion will be granted a transition period and are planned to be revoked from August 1, 2027.

According to the mandatory national standard for China RoHS (GB 26572-2025), published on August 1, 2025, products included in the Compliance Management Catalog must comply with both the hazardous substance limit requirements and the marking requirements.

The adjustments to the Catalog impose higher environmental protection requirements on electrical and electronic enterprises. The expansion of the Catalog will be implemented in sync with the mandatory national standard GB 26572-2025, signifying a significant strengthening of the management system for restricting hazardous substances in electrical and electronic products. Relevant enterprises should closely monitor regulatory developments and plan their compliance strategies in advance to address potential impacts on production, supply chains, and markets.

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Further Information

MIIT