On March 12, 2026, the Fourth Session of the 14th National People’s Congress passed China’s first basic law in the field of ecological and environmental governance — the Ecological and Environmental Code, which will take effect on August 15, 2026. As the world’s first legal code directly named after “ecology and environment,” it is also China’s second law titled as a “code,” following the Civil Code. Comprising five books and 1,242 articles, the Code systematically integrates existing legal systems on pollution prevention, ecological protection, and green and low-carbon development.
Notably, the Code formally incorporates requirements for the restriction of hazardous substances in electrical and electronic products (RoHS). It stipulates that “the design of electrical and electronic products shall take into account their impact on human health and the ecological environment throughout their life cycle, prioritize non-toxic, harmless, easily degradable or recyclable solutions, and strengthen source reduction and substitution of hazardous substances in accordance with national regulations.” This legislative milestone signifies that China’s RoHS compliance framework has formally obtained superior legal support from the first-ever Ecological and Environmental Code, advancing the electronics sector towards a new era of high-quality development amid its green transition.
Moreover, the Code’s provisions on RoHS controls solidifies the legal foundation for implementing the Measures for the Administration of the Restricted Use of the Hazardous Substances Contained in Electrical and Electronic Products and the mandatory national standard GB 26572-2025 Requirements for restricted use of hazardous substances in electrical and electronic products (Effective from August 1, 2027) (See more details from our news coverage). The combination of the Ecological and Environmental Code and GB 26572-2025 creates a dual-layer “law + standard” governance framework. This addresses inconsistencies in compliance across the industry and transitions RoHS management into a normalized, legally binding regime.
Under the guidance of the Ministry of Industry and Information Technology and other authorities, further steps will be taken to deepen RoHS-related standards and technical research, accelerate the implementation of the revised Compliance Management Catalog for the Restriction of Hazardous Substances in Electrical and Electronic Products and its exemption list, refine enforcement mechanisms, and strengthen corporate compliance guidance. Among these efforts, the 2025 edition of the administrative catalogue and its exemption list for which a public consultation concluded in December 2025, proposes to expand the scope of controlled products from the first batch of 12 categories to 33, including newly added items such as microwave ovens, smart speakers, robotic vacuum cleaners, smart watches and wristbands, projectors, and electronic blood pressure monitors. The accompanying exemption list was also updated to align with international environmental conventions and technological feasibility. While the final versions are pending official release, these efforts aim to foster a full-chain green ecosystem and support a more sustainable, efficient, and innovative electronics industry.
As RoHS requirements are codified into the Ecological and Environmental Code, with GB 26572-2025 taking effect and the relevant Administrative Catalogue and its Exemption List under final revision, China’s RoHS management has entered a legally grounded and more standardized phase. For European companies in China, this necessitates elevating RoHS compliance to a core legal risk control priority, closely monitoring the final catalogue and exemption list, assessing whether their products and supply chains fall within the expanded scope, and proactively initiating technical upgrades, material substitution, and testing certification. Faced with imminent binding constraints, early action, systematic assessment, and proactive adaptation are key to transforming compliance challenges into a differentiated competitive advantage.
For your reference, the 2025 Chinese version of the Compliance Management Catalog for the Restriction of Hazardous Substances in Electrical and Electronic Products and its exemption list are available here.
