China RoHS Update: New Compliance Obligations For Electrical Products

I. Regulatory Background and Legislative Developments

The regulatory framework for China RoHS (Restriction of Hazardous Substances) was established by the Administrative Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products, which took effect on July 1, 2016. This regulation applies to all electrical (and electronic) products¹ manufactured, sold, or imported into China, covering consumer household appliances and electronics as well as industrial machinery and equipment. The regulation introduces specific compliance management requirements for certain products: Products listed in the Catalog of Compliance Management for the Restriction of Hazardous Substances in Electrical and Electronic Products (the “Compliance Management Catalog”) must meet strict limits on hazardous substances and undergo a formal conformity assessment. In November 2025, the Ministry of Industry and Information Technology(MIIT) issued the 2025 Edition of the