China Adjusts Standards for Hazardous Substance Content Limits and Testing Methods Under RoHS Compliance Assessment System

On November 18, 2025, the State Administration for Market Regulation and the Ministry of Industry and Information Technology announced Adjustments to the Applicable Standards for Hazardous Substance Content Limits and Testing Methods Under the Compliance Assessment System, a key mechanism of China’s RoHS regulation. The announcement clarifies the implementation schedule for standards governing hazardous substance content limits—GB/T 26572-2011, its NO.1 Supplement, and GB 26572-2025—and specifies that substance content testing must follow relevant requirements in the GB/T 39560 series standards.

Compliance Assessment System

Under China’s RoHS regulation, electrical and electronic products listed in the “Management Catalog for Electrical and Electronic Products Meeting Hazardous Substance Restriction Requirements” (currently 12 categories) must not only display hazardous substance content information but also meet content limit requirements and undergo compliance assessment. The system requires proof of conformity with relevant hazardous substance restriction standards and technical specifications, either by a third-party organization or by the enterprise itself. Two assessment options are available, and companies must choose one:

• Option 1: Voluntary Certification Promoted by the State
  Companies may voluntarily apply for certification, with a third-party organization verifying compliance with hazardous substance restriction standards and technical specifications.
• Option 2: Self-Declaration
  Suppliers (including manufacturers and authorized representatives) must complete a conformity assessment using reasonable methods and report product compliance information, proving that their products meet hazardous substance restriction standards and technical specifications.

Implementation Schedule for Standards on Hazardous Substance Content Limits

Over the past two years, NO.1 Supplement to GB/T 26572-2011 and GB 26572-2025 have been issued. The latest announcement sets out the following schedule for applying these standards in compliance assessments:

Testing Methods

The announcement also specifies that testing methods for compliance assessments under GB/T 26572-2011, its Supplement 1, or GB 26572-2025 must follow relevant parts of the GB/T 39560 series standards. Currently, the GB/T 39560 series includes 14 standards, such as:

• GB/T 39560.1-2020: Measurement of Certain Substances in Electrical and Electronic Products – Part 1: Introduction and Overview
• GB/T 39560.2-2024: Part 2: Decomposition, Separation, and Mechanical Sample Preparation
• GB/T 39560.301-2020: Part 3-1: Screening for Lead, Mercury, Cadmium, Total Chromium, and Total Bromine by X-ray Fluorescence Analysis
• GB/T 39560.302-2024: Part 3-2: Screening for Fluorine, Chlorine, and Bromine in Polymers and Electronic Devices by Combustion Ion Chromatography (C-IC)
• GB/T 39560.303-2024: Part 3-3: Screening for Polybrominated Biphenyls, Polybrominated Diphenyl Ethers, and Phthalates in Polymers by Py/TD-GC-MS
• GB/T 39560.4-2021: Part 4: Analysis of Mercury in Polymers, Metals, and Electronic Devices by CV-AAS, CV-AFS, ICP-OES, ICP-MS
• GB/T 39560.5-2021: Part 5: Analysis of Cadmium, Lead, and Chromium in Polymers and Electronic Devices, and Cadmium and Lead in Metals by AAS, AFS, ICP-OES, ICP-MS
• GB/T 39560.6-2020: Part 6: Analysis of Polybrominated Biphenyls and Polybrominated Diphenyl Ethers in Polymers by GC-MS
• GB/T 39560.701-2020: Part 7-1: Determination of Hexavalent Chromium [Cr(VI)] in Colorless and Colored Corrosion-Protective Coatings on Metals by Colorimetric Method
• GB/T 39560.702-2021: Part 7-2: Quantification of Hexavalent Chromium [Cr(VI)] in Polymers and Electronic Devices by Colorimetric Method
• GB/T 39560.8-2021: Part 8: Analysis of Phthalates in Polymers by GC-MS and Py/TD-GC-MS
• GB/T 39560.9-2024: Part 9: Analysis of Hexabromocyclododecane in Polymers by GC-MS
• GB/T 39560.10-2024: Part 10: Analysis of Polycyclic Aromatic Hydrocarbons (PAHs) in Polymers and Electronic Devices by GC-MS
• GB/T 39560.12-2024: Part 12: Simultaneous Measurement of Polybrominated Biphenyls, Polybrominated Diphenyl Ethers, and Phthalates in Polymers by GC-MS

The full text of the announcement (in simplified Chinese) is available at:
https://www.cnca.gov.cn/zwxx/gg/2025/art/2025/art_a112fdc22f064071b489dd069f2e7b46.html