Last updated: 26 September 2026.
Quick answer. RoHS is two regimes, not one. EU RoHS restricts six substances in electrical and electronic equipment placed on the EU market, with the manufacturer declaring conformity and affixing CE marking. China RoHS covers products in a published catalogue placed on the Chinese market, administered by MIIT and SAMR.
Your supplier's RoHS document may answer to Chinese law, not EU law. Here is what each regime covers, who owes it, and which one your market requires.
The EU provisions on this page are the text of Directive 2011/65/EU as published on EUR-Lex. The China RoHS facts are the Ministry of Industry and Information Technology's own published compliance statistics and the legal instruments they cite. Both were retrieved on 26 September 2026 and are listed at the end.
The word "RoHS" is used on both sides of the same shipment and it means two different things. A Chinese supplier may send you a test report headed RoHS. That report may demonstrate compliance with European law, with Chinese law, with both, or with neither — and the document itself usually does not say which.
The distinction matters because the two regimes are not copies of each other. They have different legal bases, different administering authorities, different scopes, different routes to demonstrating compliance, and different people who owe the obligation. A buyer who assumes that a RoHS report from a Chinese supplier is evidence of EU compliance is relying on an assumption the paperwork does not support.
| EU RoHS | China RoHS | |
|---|---|---|
| Legal instrument | Directive 2011/65/EU (as published on EUR-Lex) | The Measures for the Administration of the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products, MIIT and seven other departments, Order No. 32 of 2016 |
| Who administers it | EU Member States, applying the Directive | Ministry of Industry and Information Technology (MIIT) with the State Administration for Market Regulation (SAMR) |
| Apparatus | A single market-placement restriction on substances | A conformity-assessment and information-reporting regime, with a published catalogue of product categories |
| Key evidence | EU declaration of conformity drawn up by the manufacturer, with CE marking affixed | Conformity-assessment result reported to the national China RoHS public service platform |
| What it attaches to | EEE placed on the EU market | Products in the catalogue placed on the Chinese market |
The operative provision is Article 4(1), which requires Member States to ensure that EEE placed on the market — expressly including cables and spare parts for its repair, reuse, updating of functionalities or upgrading of capacity — does not contain the substances listed in Annex II. Article 4(2) adds the concentration rule: no more than the maximum concentration value by weight in homogeneous materials is tolerated.
The phrase "by weight in homogeneous materials" is doing real work here, and the Directive defines it. A homogeneous material is "one material of uniform composition throughout or a material, consisting of a combination of materials, that cannot be disjointed or separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes." The threshold applies per homogeneous material, which is why a compliant assembly can still contain a part that is over the limit — and why the analysis behind a "RoHS report" usually names the individual materials tested.
Annex II lists the restricted substances and the concentrations tolerated in homogeneous materials:
| Restricted substance | Maximum concentration tolerated by weight in homogeneous materials |
|---|---|
| Lead | 0,1 % |
| Mercury | 0,1 % |
| Cadmium | 0,01 % |
| Hexavalent chromium | 0,1 % |
| Polybrominated biphenyls (PBB) | 0,1 % |
| Polybrominated diphenyl ethers (PBDE) | 0,1 % |
Annex I sets the categories of equipment the Directive covers: large household appliances; small household appliances; IT and telecommunications equipment; consumer equipment; lighting equipment; electrical and electronic tools; toys, leisure and sports equipment; medical devices; monitoring and control instruments, including industrial monitoring and control instruments; automatic dispensers; and other EEE not covered by any of those categories. Annex III carries the applications exempted from the Article 4(1) restriction.
The obligation sits with the manufacturer. Article 7(1) requires that, when placing EEE on the market, manufacturers ensure it has been designed and manufactured in accordance with Article 4; that they draw up the required technical documentation and carry out the internal production control procedure in line with module A of Annex II to Decision No 768/2008/EC; and that, where compliance has been demonstrated by that procedure, they draw up an EU declaration of conformity and affix the CE marking on the finished product. That last step is worth holding on to: under EU RoHS the CE marking and the declaration are the visible outputs, not a laboratory report.
China's regime is built on three published instruments, which MIIT's own compliance notice cites by number:
The instruments are published in Chinese; the renderings above are translations of their titles, and the number-and-year citations are the identifiers to use when checking them.
The practical shape of the regime, as MIIT states it, is a product-catalogue system. Products in the catalogue, manufactured or imported after 1 November 2019, must undergo China RoHS conformity assessment, and the results must be reported to the China RoHS public service platform. MIIT gives refrigerators, washing machines and televisions as examples of the product categories concerned.
The platform itself is a joint MIIT and SAMR construction that went live in December 2019. MIIT describes its functions as unified management of conformity-assessment information, publication of assessment results, information reporting, public query, statistical analysis and information release. It is the official place to check whether a product's conformity-assessment information has been filed, and the address MIIT publishes is chinarohs.miit.gov.cn.
The catalogue is not static. The 2026 edition adds product categories and brings them into the conformity-assessment system on a stated date: per MIIT's notice, the 23 newly added product categories enter mandatory conformity assessment on 1 August 2027.
MIIT also publishes how much has been filed, which is the closest thing to an official measure of how far the regime has been taken up. As of the end of July 2026, MIIT reports 1,517 companies having submitted 21,234 conformity-assessment records covering 33,535 product types for the product categories in force. For the 23 newly added categories, 11 companies had filed 28 records covering 28 product types ahead of the August 2027 date.
That last figure is the practically useful one. If you are buying a product that falls into one of the newly added categories, the population of suppliers that have already filed is small, and the filing date is still ahead.
The two regimes have different evidence attached to them, so the useful question is not "is it RoHS compliant" but "which RoHS, and what is the document?"
| If the supplier offers… | What it is evidence of | What it is not evidence of |
|---|---|---|
| An EU declaration of conformity with CE marking | The manufacturer's own declaration under Article 4 of Directive 2011/65/EU, drawn up after the internal production control procedure | An independent test of your batch; and not compliance with Chinese law |
| A third-party laboratory report headed "RoHS" | Test results for the materials named in the report | By itself, either regime: it does not identify the legal instrument, and a report is not the declaration of conformity the Directive requires |
| A filing on the China RoHS platform | That the product's conformity-assessment information has been reported under the Chinese regime | Compliance with EU RoHS, or compliance with the Chinese regime for products outside the catalogue |
| A certificate of compliance referring to "China RoHS" for an industrial part | Nothing about the EU market | Scope: China's catalogue is a product-catalogue system, and MIIT's published examples are household appliances |
The underlying point is the same one that runs through this site's compliance pages: read the mark for what it is. A RoHS document tells you which regime its author was working to — and often, the author was working to a different market than yours.
If your supplier relationship is at the stage where documentation is being agreed rather than checked, how to find a manufacturer in China covers the paperwork conversation, and quality control covers what to inspect and when. The EU-side obligations that sit next to RoHS are set out in REACH and RoHS for importers.
No. They are separate regimes with different legal bases, different administering authorities and different scopes. EU RoHS is Directive 2011/65/EU and restricts substances in electrical and electronic equipment placed on the EU market. China RoHS rests on MIIT Order No. 32 of 2016 and operates a conformity-assessment and reporting system for products in a published catalogue placed on the Chinese market.
Annex II lists six: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE). The tolerated maximum concentration by weight in homogeneous materials is 0,1 % for all of them except cadmium, which is 0,01 %.
The Directive defines it as one material of uniform composition throughout, or a material consisting of a combination of materials that cannot be disjointed or separated into different materials by mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes. The concentration limit applies per homogeneous material, not to the finished product as a whole.
MIIT states that the 23 newly added product categories enter mandatory conformity assessment on 1 August 2027. The categories already in force have applied to products manufactured or imported after 1 November 2019.
MIIT publishes the China RoHS public service platform, which it describes as the official system for managing and publishing conformity-assessment information, at chinarohs.miit.gov.cn. MIIT reports that 1,517 companies had filed 21,234 records covering 33,535 product types as of the end of July 2026.
All sources retrieved 26 September 2026. This page is an independent reading of the sources listed; the official pages themselves are the specification.
| Fact used on this page | Source |
|---|---|
| S1 — Directive 2011/65/EU: Article 4(1) requiring that EEE placed on the market, including cables and spare parts for repair, reuse, updating of functionalities or upgrading of capacity, does not contain the substances listed in Annex II; Article 4(2) limiting the maximum concentration value by weight in homogeneous materials as specified in Annex II, with detailed rules to be adopted by delegated act; the Article 3 definition of "homogeneous material"; Article 7(1) on manufacturers' obligations including technical documentation, the internal production control procedure in line with module A of Annex II to Decision No 768/2008/EC, the EU declaration of conformity and the affixing of CE marking on the finished product; Annex I's eleven categories of EEE; Annex II's restricted substances and maximum concentration values (lead 0,1 %, mercury 0,1 %, cadmium 0,01 %, hexavalent chromium 0,1 %, PBB 0,1 %, PBDE 0,1 %); Annex III's exempted applications | Directive 2011/65/EU of the European Parliament and of the Council, EUR-Lex, retrieved 26 September 2026 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32011L0065 |
| S2 — The legal instruments cited as the basis of the China RoHS reporting regime: the Measures for the Administration of the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products (Order No. 32 of 2016, MIIT and seven other departments), the Implementation Arrangements for the Conformity Assessment System (SAMR Announcement No. 23 of 2019) and the Catalogue for Compliance Management (2026 edition, MIIT Announcement No. 11 of 2026); that products in the catalogue manufactured or imported after 1 November 2019 must undergo conformity assessment and report results to the China RoHS public service platform, with refrigerators, washing machines and televisions given as examples; that the platform was built jointly by MIIT and SAMR, went live in December 2019 and provides information reporting, public query, statistics and information release, at chinarohs.miit.gov.cn; the filing statistics as of the end of July 2026 (1,517 companies, 21,234 records, 33,535 product types); the addition of 23 product categories entering mandatory conformity assessment on 1 August 2027 and the 11 companies, 28 records and 28 product types filed for them as of end-July 2026 | Ministry of Industry and Information Technology — China RoHS information reporting status as at 31 July 2026 (published in Chinese), published 2 September 2026, retrieved 26 September 2026 https://www.miit.gov.cn/jgsj/jns/qjsc/art/2026/art_ab21c6c2b89b484ebbcd66a6eaf5ff0c.html |
| S3 — The same filing figures as at 30 June 2026, confirming the monthly reporting series and the legal instruments cited in each edition | Ministry of Industry and Information Technology — China RoHS information reporting status as at 30 June 2026 (published in Chinese), published 14 July 2026, retrieved 26 September 2026 https://www.miit.gov.cn/jgsj/jns/qjsc/art/2026/art_30610de283094e5b9a561d8bfcb3a50f.html |