China Proposes New ROHS-Like Catalogue for EEE Products (G/TBT/N/CHN/2149)
Country: China
Notification Date: 2025-11-26
China has issued a significant draft notification, G/TBT/N/CHN/2149, introducing a new “Standard Achieving Management Catalogue for the Restriction of Hazardous Substances in Electrical Appliances and Electronic Products (2025 Edition)”. This initiative signals China’s intent to further align with global efforts to manage hazardous substances in electronics, similar to the EU's RoHS Directive. The draft aims to regulate 33 product categories, providing detailed scope, definitions, and an exception list for cases of technical or economic unfeasibility.
Key Details- Country: China
- Document Symbol: G/TBT/N/CHN/2149
- Notification Date: 2025-11-26
- Comment Deadline: Not specified
- Effective Date: To be determined
The proposed catalogue identifies 33 distinct product types subject to new restrictions on hazardous substances. Each product entry includes a clear scope, definition, and applicable use scenarios. Key product categories covered include air conditioners, refrigerators, washing machines, televisions, computers, mobile phones, smartwatches, and various other household and industrial electronic equipment.
A crucial element of this draft is the provision of an exception list for applications where restriction of hazardous substances is deemed technically or economically unfeasible. Regarding implementation, several products such as air conditioners, refrigerators, washing machines, and electric water heaters are slated to be effective from their final publication date. The majority of the remaining products, including most consumer electronics and IT equipment, are scheduled for implementation on August 1, 2027.
Impact Assessment- Which products or sectors are affected: This catalogue broadly impacts manufacturers and exporters of electrical and electronic products destined for the Chinese market. It specifically targets 33 categories, encompassing consumer electronics, IT equipment, telecommunications devices, and some medical and industrial machinery.
- Potential impact on international trade: This regulation may introduce new technical barriers to trade for companies exporting EEE products to China. Compliance will likely require significant adjustments in product design, material sourcing, and manufacturing processes, potentially increasing production costs.
- Compliance requirements for exporters: Exporters will need to ascertain if their products fall within the defined scope, identify the specific hazardous substance restrictions (once detailed standards are released), and ensure their supply chains can meet these new requirements. Demonstrating compliance through testing and documentation will be critical.
- Market access implications: Non-compliant products may face restrictions on market entry, import prohibitions, or delays at customs. Proactive compliance is essential to maintain seamless market access in China, a major global market.
- Recommended actions for affected companies: Companies should thoroughly review the full draft document, identify all potentially affected products in their portfolio, and begin assessing their current material compliance status. It is crucial to monitor for the release of specific hazardous substance limits and testing methods.
- Compliance timeline: Given that some products could be effective from the final publication date and others by August 1, 2027, companies should initiate internal preparations immediately. Early engagement with supply chain partners for material declarations and potential substitutions is advisable.
- Resources or contacts for more information: Consult with trade compliance specialists, industry associations, and regulatory experts specializing in Chinese environmental regulations. Engage with relevant Chinese authorities or their representatives for clarifications and updates.
China's proposed “Standard Achieving Management Catalogue for the Restriction of Hazardous Substances in Electrical Appliances and Electronic Products” represents a significant development in global trade compliance for the electronics sector. Companies exporting to China must proactively understand and prepare for these new requirements to ensure continued market access and avoid potential disruptions. Staying informed and adapting supply chain strategies will be paramount for successful compliance.
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