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China ROHS Standard Update

On 9 July 2014, the Ministry of Industry and Information Technology (MIIT) of China issued standard SJ/T 11364-2014 Marking for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Product[1].

China RoHS (Administrative Measure on the Control of Pollution Caused by Electronic Information Products)[2] has been discussed for years to enhance its impact by expanding its product scope from EIPs (electronic information products) to all EEPs (electric and electronic products)[3]. Although the new China RoHS is still under discussion, its labeling standard has been updated to SJ/T 11364-2014. The new labeling standard will repeal SJ/T 11364-2006 and shall be applied from 2 January 2015.

Compared to the old standard, the new standard expands the product scope from EIPs to all EEPs. Since currently only EIPs fall into the product scope of China RoHS, EIPs sold in China shall be properly labeled according to this standard. For other EEPs, they can be voluntarily labeled according to this standard. And if the new China RoHS expands the product scope to EEPs, all EEPs sold in China shall be labeled according to this standard.

Other changes of the new labeling standard include adding a digital format label which is only applicable for EEP with a display function, the revision of the suggested color of the label and the declaration table of the hazardous substances that exist in the product. According to the new standard, the label can be used in logistics of EEPs to communicate the China RoHS information through the supply chain. Furthermore, the requirement of labelling the packaging materials for EIPs according to GB 18455-2001 is deleted in the new standard. The updated status of China RoHS regulation and standards is summarized in the following table .


Old Version

New  Version

Update Status


Administrative Measure on the Control of Pollution Caused by Electronic Information Products

Administrative Measure on the Control of Pollution Caused by Electric and Electronic Products

Under discussion

Supporting Standards

Labeling Standard
SJ/T 11364-2006

SJ/T 11364-2014

1. Takes effect on 1 January 2015

2. Change Product scope from EIP to include EEP

3. Delete packaging marking requirement (GB18455)

Limit Standard
SJ/T 11363-2006

GB/T 26572-2011

Include sample disassembling examples and the high risk component/material in IEC/PAS 62596

Testing Standard
SJ/T 11365-2006

GB/T 26125-2011

Translation of IEC62321:2008

Summary of China RoHS Regulation and Standards Update

Besides the update of the labeling standard, a new standard, GB/T 31274-2014 Restricted Substances Management Systems of Electrical and Electronic Products - Requirements was published on 10 October 2014 and will be enforced on 16 April 2015. GB/T 31274-2014 is not a mandatory requirement and is a recommended standard for enterprises establishing hazardous substances process management systems (HSPMS). With the ongoing update of China RoHS related standards, companies should keep focusing on the requirements and take measures to ensure the products comply with China RoHS requirement.

The global footprint of SGS will support you in product compliance with global RoHS (EU, China, Korea, US, etc.), REACH/SVHC, textiles or hard-goods, CPSIA or other toy regulations and many more consumer product related requirements like packaging materials or battery requirements. Regardless if you are in need of chemical testing or services in the fields of inspection, certification, compliance assurance, outsourcing, training or auditing SGS is dedicated to satisfy your needs. Providing service to help your products to be fit for the market requirements of the future – whatever the legal frameworks might be.


[1] standard SJ/T 11364-2014

[2] Administrative Measure on the Control of Pollution Caused by EIPs

[3] Administrative Measure on the Control of Pollution Caused by EEPs (exposure draft)

Email SGS Hong Kong Ltd. at mktg.hk@sgs.com for enquiries or visit http://www.sgsgroup.com.hk/.

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