China RoHS 2 Compliance Guide for New Consumer Devices
Launching or importing a new gadget into China requires more than performance features and a sharp price. China RoHS 2 sets material limits, labeling rules, and documentation duties that apply across many categories of electrical and electronic products. This guide explains what manufacturers, brands, and retailers need to know to keep devices compliant and avoid costly delays.
China RoHS 2 sets rules on hazardous substances in electrical and electronic products placed on the market in China. For most products, disclosure via labeling and a hazardous substance table is required, while items listed in the Compliance Management Catalogue must also meet substance limits and pass conformity assessment. Understanding scope, documentation, testing, and labeling is essential for teams planning production, importing, or merchandising new devices in your area.
Discount electronics deals: compliant or risky?
Aggressively priced products can still be compliant, but cost-cutting sometimes increases the risk of undocumented components or unverified materials. Verify whether the device is within China RoHS 2 scope and if it appears in the current Compliance Management Catalogue. If it is catalogued, limits for substances such as lead, mercury, cadmium, hexavalent chromium, PBB, and PBDE must be met, not just disclosed. Ask for evidence that the brand completed conformity assessment (self-declaration or third‑party) and uploaded results to the official platform.
Online electronics bargains: documents to request
Before listing or purchasing, request a Bill of Materials (BOM), supplier declarations for each homogeneous material, and recent test reports aligned with applicable Chinese methods (for example, GB/T or IEC 62321 series used by accredited labs). For non‑catalogue items, ensure the hazardous substance table (HST) is prepared and traceable to material data. Keep contracts requiring suppliers to notify you of material changes, and set a refresh cadence for test data when components, solders, or plastics change.
Flash sale gadgets: China RoHS labeling checks
Labeling must follow SJ/T 11364 requirements. Confirm the presence of the Environment-Friendly Use Period (EFUP) symbol with the correct number, plus the circular “e” mark if applicable. The HST must indicate whether each restricted substance is within limits for major components. Packaging and manuals should carry the same information consistently. Mismatched EFUP numbers, missing HST, or untranslated labels are frequent causes of detentions during customs inspection and should be corrected before shipment.
Affordable electronic devices: testing and materials control
Screening with XRF is useful for triage, but only wet chemistry (e.g., ICP, GC-MS) can confirm limits for many materials. Adopt a risk-based plan: prioritize high-risk parts such as solder joints (lead), PVC cables (phthalates if applicable in your case), pigments, and plating. Validate the highest-risk materials at the material or homogeneous level. Maintain change control with suppliers and require material declarations that match your BOM structure. For catalogue products, retain certificates, test reports, and platform records to demonstrate due diligence during audits.
Best tech deals: avoiding non‑compliance in your supply chain
Low prices should not short-circuit traceability. Pre-qualify factories, confirm that they can produce the HST from real supplier data, and verify that they use approved solder, adhesives, and plastics. When products share common parts, leverage component-level test reports across projects, but only if bills of materials and suppliers are identical. For private-label or white-label goods, ensure your brand appears on declarations and labels, since accountability follows the entity placing the product on the market.
Pricing and provider options for China RoHS 2 testing and documentation vary by product complexity, number of materials, and whether you choose self-declaration or third‑party certification. The estimates below reflect typical quotes observed in the market for consumer devices in China; actual fees depend on sample count, turnaround, and lab scope. Prices are indicative and provided to help planning.
| Product/Service | Provider | Cost Estimation |
|---|---|---|
| XRF screening (per sample) | SGS | RMB 500–1,500 (approx. USD 70–210) |
| Full RoHS wet-chemistry testing (per material set) | TÜV Rheinland | RMB 1,500–3,500 (approx. USD 210–490) |
| BOM risk assessment and test plan (per project) | Intertek | RMB 2,000–8,000 (approx. USD 280–1,120) |
| Documentation review and China RoHS self-declaration support | UL Solutions | RMB 3,000–10,000 (approx. USD 420–1,400) |
| Factory/supplier audit (per audit day) | Bureau Veritas | RMB 6,000–12,000 (approx. USD 840–1,680) |
| Labeling and HST verification (per SKU) | SGS | RMB 1,000–3,000 (approx. USD 140–420) |
Prices, rates, or cost estimates mentioned in this article are based on the latest available information but may change over time. Independent research is advised before making financial decisions.
Practical steps to structure compliance
- Determine scope: confirm whether your product is in the Compliance Management Catalogue. If yes, plan for substance limits and conformity assessment; if not, prepare disclosure and labeling.
- Build your technical file: BOM, supplier material declarations, test reports mapped to homogeneous materials, labeling proofs, and EFUP rationale.
- Choose a conformity route: self-declaration with evidence uploaded to the national platform, or voluntary certification via an accredited body. Keep platform receipts and certificates.
- Control changes: when suppliers switch materials or finishes, re‑evaluate risk and re‑test as needed, updating the HST and labels.
Common pitfalls and how to avoid them
- EFUP and HST inconsistencies between the device, packaging, and manual.
- Using legacy test reports that do not match the current BOM or that reference outdated materials.
- Relying solely on XRF for high‑risk plastics or solders where wet chemistry is required.
- Missing Chinese-language labeling or incomplete translations on manuals.
- Assuming a low-cost item is exempt; many small accessories still fall within scope and need disclosure.
Conclusion China RoHS 2 compliance is manageable with clear scope determination, disciplined documentation, and targeted testing. Whether you handle declarations internally or use a third-party lab, align your BOM, materials data, and labels before production. A structured approach reduces rework, speeds customs clearance, and supports consistent quality across new consumer devices marketed in China.