1.Distinct Regulatory Positioning and Scope

EU RoHS is a mandatory market access directive following the principle of "general control plus exemption exceptions", covering nearly all low-voltage electrical and electronic products. China RoHS is governed by mandatory national standard GB 26572-2025, adopting a tiered supervision model: mandatory substance limits for listed products and mandatory marking requirements for all product categories.

2.Independent Exemption Clauses with No Mutual Recognition

Lead exemptions for numerous solders, alloys and ceramic materials under EU RoHS are subject to ongoing review and will be tightened upon expiry. China maintains a separate exemption evaluation mechanism; exemptions valid under EU RoHS cannot be directly applied for the Chinese market.

3.Noticeable Differences in Conformity Assessment Procedures

For the EU market, manufacturers rely on self-declaration together with retention of complete technical documentation, with no mandatory official filing requirement. In China, products falling within the compliance catalogue require self-declaration submission on the MIIT platform to generate traceable official compliance records.

4.Mandatory Divergences in Product Marking Requirements

China RoHS mandates environmental labels printed or affixed on products or outer packaging, together with marked service life for environmental protection and hazardous substance information. No mandatory requirements for such graphical labels exist under EU RoHS.

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