China RoHS vs. EU RoHS: The Differences That Actually Matter for Sourcing
Same acronym, different mechanics. Marking, disclosure, and restricted-substance handling diverge in ways that catch sourcing teams off guard.
The shared name causes more confusion than it solves. China RoHS (formally, the Management Methods for the Restriction of Hazardous Substances in Electrical and Electronic Products) and EU RoHS restrict an overlapping — but not identical — set of substances, and the compliance mechanics diverge in ways that matter for sourcing and labeling decisions.
Where they diverge
Marking approach. EU RoHS has no product-marking requirement of its own — compliance is demonstrated through the technical file and the Declaration of Conformity. China RoHS uses a visible product mark: either the "environmentally friendly use period" (EFUP) logo, or, above the restricted concentration thresholds, a different marking indicating the substances are present.
Disclosure obligations. China RoHS requires disclosure of restricted substance presence and concentration on packaging or in accompanying documentation for products sold into the Chinese market, in a standardized table format — a requirement with no direct EU RoHS equivalent.
Catalogue-based scope. China RoHS's compliance-marking requirement historically applied first to a specific product catalogue, expanding over time, rather than to all covered product categories at once the way EU RoHS's Annex I does.
Enforcement posture. EU RoHS enforcement runs through market surveillance and national authorities per member state. China RoHS enforcement runs through China's own regulatory bodies with separate certification and labeling verification.
Why this matters for a global product line
A product engineered to EU RoHS thresholds is very often close to China RoHS compliance on substance content alone — the restricted-substance lists overlap heavily. But "close" is not "compliant." Shipping into China without the required EFUP marking or disclosure table is a labeling and documentation failure, not a materials failure, and it stops a shipment just as effectively.
The practical takeaway
Treat China RoHS as a second, related compliance question, not a formality layered on top of EU RoHS. Confirm substance overlap first, then separately confirm marking, disclosure table format, and catalogue applicability before a product ships into the Chinese market.