China Releases Draft Revision of Standard Related to China RoHS Technical Documentation Preparation 
On June 8, 2026, the Standardization Administration of China (SAC) released a draft revision of Technical Documentation for the Assessment of Electrical and Electronic Products with Respect to the Restriction of Hazardous Substances (GB/T 36560), an important voluntary national standard under the China RoHS regulation and opened it for public comment. The deadline for submitting comments is August 7, 2026.
Under the China RoHS regulation, the 23 categories of products listed in the Compliance Management Catalogue for the Restriction of Hazardous Substances in Electrical and Electronic Products must submit supporting documentation demonstrating that the hazardous substance content in the products complies with restriction requirements. This standard serves as a guideline for manufacturers of target products when preparing such conformity assessment documentation. While the current GB/T 36560-2018 is identical (IDT) to “IEC 63000:2016”, it lacked provisions for assessing technical documentation and its data quality, which had caused obstacles in market supervision and administration. Therefore, this revision is being implemented. Based on IEC 63000, the draft revision adds quality requirements for technical documentation as well as evaluation content for such documentation. Furthermore, reference templates for the “Supplier Declaration,” “Material Declaration,” and “Correspondence between Materials, Components, and Respective Technical Documentation in Products” have been added to the appendices.
About Technical Documentation for Conformity Assessment
Products listed in the Compliance Management Catalogue for the Restriction of Hazardous Substances in Electrical and Electronic Products must meet the hazardous substance restriction limits stipulated in the national standard Requirements of Concentration Limits for Certain Restricted Substances in Electrical and Electronic Products (GB/T 26572-2011) (which will become GB 26572-2025 starting August 1, 2027). In addition, manufacturers are required to prepare supporting documents showing that the limits are met—namely, technical documentation that can prove compliance with the China RoHS regulation.
From the perspectives of substance testing costs and the validity of test results, it is practically difficult for manufacturers to conduct final testing on all materials in a product. For this reason, the approach where a manufacturer works with its suppliers to implement full-process compliance management and creates technical documentation for conformity assessment to prove that its products meet RoHS requirements is recognized by authorities as a common practice.
Scope of Application
This standard specifies requirements for technical documentation that manufacturers should compile to declare that their products comply with relevant restricted substance requirements, such as China RoHS, and sets forth requirements regarding the reliability and data quality of such technical documentation.
Main Revision Contents
Since the current GB/T 36560-2018 is identical (IDT) to “IEC 63000:2016,” the changes made from GB/T 36560-2018 in this revision draft are same to those made from IEC 63000:2016. This revision was carried out primarily to improve the quality of conformity assessment documentation. The main details are as follows:
| Clause No. | Main Revision Content | Reason for Revision |
|---|---|---|
| 5.4 | The following wording was added to the text: “The possibility of the presence of restricted substances shall be identified based on the methodology in Chapter 5 of Guidelines for Risk Assessment of Hazardous Substances in Electrical and Electronic Products (SJ/T 11467), and evaluated in accordance with Chapter 6.” | To provide methods for identifying and evaluating the risk of hazardous substances being present in products. |
| 6.1 | General requirements for material declarations from Material Declaration for Electrical and Electronic Products (GB/T 26668) were added. | To enhance the practicality of the standard. |
| 6.1 | Certification documents were added to the conformity assessment documentation. Additionally, a requirement was added specifying that such certificates must be issued by a qualified testing and measurement organization. | To align with current practices in hazardous substance management. |
| 6.3 | Traceability requirements for conformity assessment documentation were added for manufacturers. | To clarify the scope of collection for supporting documents. |
| 6.4 | Procedures and methods for preparing conformity assessment technical documentation were added. | To enhance the practicality of the standard. |
| 6.5 | Requirements for the storage methods of conformity assessment documentation and types of documents were added. | To enhance the practicality of the standard. |
| 7.1 | Specific requirements regarding the quality and reliability of conformity assessment documentation were added. | To enhance the practicality and feasibility of the standard. |
| Appendices A-C | Reference templates for conformity assessment documentation were added. | To enhance the practicality of the standard. |
Implementation of the Standard
The implementation date of the standard is not explicitly specified in the draft. Since this standard is a voluntary national standard, relevant companies will comply with it on a voluntary basis.
EnviX Comment
The revision of this standard is considered highly significant for the implementation of the China RoHS regulation. On May 22, 2026, the Compliance Management Catalogue for the Restriction of Hazardous Substances in Electrical and Electronic Products (2026 Edition) was promulgated, expanding the target products to 23 categories. This standard will be of great help when manufacturers of newly added target items prepare their conformity assessment documentation. Furthermore, since this draft standard is being formulated as “modified (MOD)” in relation to its equivalence to IEC 63000, companies that have already prepared conformity assessment documentation in accordance with IEC 63000 can comply by reviewing, adjusting, and updating their existing documents against the main revision contents mentioned above.
The original text of this draft standard can be viewed at the following URL (Simplified Chinese):
https://std.samr.gov.cn/gb/search/gbDetailed?id=42BB516E6A1E281DE06397BE0A0ADAB0
