Phthalates Officially in Scope of China RoHS from 1 January 2026

This blog was originally posted on 8th July, 2024. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY JOYCE COSTELLO, SENIOR REGULATORY COMPLIANCE SPECIALIST, COMPLIANCE & RISKS

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Introduction

After a long lead-in, China RoHS is finally being extended to cover a total of 10 restricted hazardous substances, including the addition of 4 phthalates bis(2-ethylhexyl) phthalate (DEHP) (0,1%), butyl benzyl phthalate (BBP) (0,1%), dibutyl phthalate (DBP) (0,1%) and diisobutyl phthalate (DIBP) (0,1%) to the list of restricted substances. 

Amendment No. 1 to GB/T 26572-2011 was published on 29 June 2024 through China National Standard Announcement No. 14.

An 18-month transitional period will now run until 1 January 2026, facilitating manufacturers in their preparations for the new obligations.

Impact for Manufacturers and Importers

Companies supplying electrical and electronic products to the Chinese market will be impacted in one of two ways, based on their product.

1) Manufacturers/importers of electrical and electronic products listed in the first batch may not contain any of the 10 hazardous substances at levels in excess of the maximum indicated threshold. Products impacted are:

• Refrigerators
• Air conditioners
• Washing machines
• Electric water heaters
• Printers
• Copiers
• Fax machines
• Televisions
• Monitors
• Microcomputers
• Mobile communication devices
• Telephones

2) Manufacturers/importers of all other electrical and electronic products within the scope of the Administrative Measures must indicate the presence of hazardous substances through the provision of a hazardous substance content table, and also label the product with the EFUP/EPUP.

Conformity Assessment System Testing Methods

Interested parties are also reminded that China’s National Certification and Accreditation Administration (CNCA) announced a change in the applicable conformity assessment system testing methods under China RoHS, effective 1 March 2024.

In order to be consistent with international standards for testing methods of hazardous substances in electrical and electronic products, the testing method standard for the conformity assessment system for restricted use of hazardous substances in electrical and electronic products has changed from GB/T 26125 to the GB/T 39560 series of standards for the determination of substances, specifically the following 8 standards:

• GB/T 39560.1 Determination of certain substances in electrical and electronic products—Part 1: Introduction and overview
• GB/T 39560.2 Determination of certain substances in electrical and electronic products—Part 2: Disassembly, disjointment and mechanical sample preparation
• GB/T 39560.301 Determination of certain substances in electrical and electronic products—Part 3-1: Screening lead, mercury, cadmium, total chromium and total bromine by X-ray fluorescence spectrometry
• GB/T 39560.4 Determination of certain substances in electrical and electronic products—Part 4: Mercury in polymers, metals and electronics by CV-AAS, CV-AFS, ICP-OES and ICP-MS
• GB/T 39560.5 Determination of certain substances in electrical and electronic products—Part 5: Cadmium, lead and chromium in polymers and electronics and cadmium and lead in metals by AAS, AFS, ICP-OES and ICP-MS
• GB/T 39560.6 Determination of certain substances in electrical and electronic products—Part 6: Polybrominated biphenyls and polybrominated diphenyl ethers in polymers by gas chromatography-mass spectrometry (GC-MS)
• GB/T 39560.701 Determination of certain substances in electrical and electronic products—Part 7-1: Hexavalent chromium—Presence of hexavalent chromium [Cr(VI)] in colorless and colored corrosion-protected coatings on metals by the colorimetric method
• GB/T 39560.702 Determination of certain substances in electrical and electronic products—Part 7-2: Hexavalent chromium—Determination of hexavalent chromium [Cr(Ⅵ)] in polymers and electronics by the colormetric method

The GB/T 39560 series corresponds to the IEC 62321 series of standards.

China RoHS conformity assessment is mandatory only for electrical and electronic products listed in the first batch of the Compliance Management Catalogue and manufactured or imported after 1 November 2019. This can be done through two approaches, either voluntary certification or self-declaration, at the discretion of manufacturers/suppliers. 

Work on the development of a mandatory standard for hazardous substances restriction and labeling, effectively combining existing Standards SJ/T 11364 and GB/T 26572, is ongoing.

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