China’s RoHS label is the part most often falsified — and also the part that is seen the fastest when goods cross the border or hit retail shelves. Unlike the EU (where the CE mark is the result of a conformity assessment process), the Chinese market requires businesses announced Hazardous substance status right on the product and in accompanying documents, according to standards SJ/T 11364.
If you have read about GB 26572-2025, you know China’s new mandatory standard brings these label requirements to the mandatory national standard level. This article delves into exactly that part: what ingredients the label contains, how to read the substance declaration table, what the EFUP label says, and why the pre-printed label molds of many Vietnamese businesses need updating.
A note before reading: this is an interpretation for understanding principle. When printing labels for a specific product, businesses need to compare the text of SJ/T 11364-2024, the current guidance of Chinese regulatory agencies and the importer’s specific requirements.
1. The Chinese RoHS label consists of two components, not one
Many people call it the “Chinese RoHS label”, but in fact this is a declaration system consisting of two separate components, often appearing in two different places:
| Ingredients | Location | Content |
|---|---|---|
| EFUP label (symbol “environmentally friendly use cycle”) | On the product/packaging | The symbol represents the number of years that the product has been considered safe from hazardous substances under normal conditions of use |
| Table announcing toxic substances | In the documentation/instructions included with the product | The table lists each substance and its content status (under or over limit) at a uniform material level |
These two components complement each other: one answers the question “how long is it safe to use”, the other answers the question “which substance exceeds the limit”. If one of the two is missing, the label record is considered incomplete.
2. Substance declaration table: read symbols O and X correctly
The disclosure table is the most important technical part, because it is based on homogeneous material — same approach as European RoHS. The table lists each substance and uses two familiar symbols:
| Symbol | Meaning | Correct understanding |
|---|---|---|
| O | The substance content in the material is uniform do not exceed required limit | “Pass” for that quality |
| X | The substance content in the material is uniform pass required limit | “Exceed” for that substance — does not mean the product is banned, but must be declared |
Three points to remember about this table:
- The table is presented in Simplified Chinese in product documentation, not arbitrarily translated into other languages.
- Symbol “X” is not a violation — it is published. Violation only arises when the product belongs to the group required to comply with the limit but still exceeds the limit.
- The letters “O” and “X” here are marker symbol, is not a capital letter of the alphabet, so it is not translated and cannot be replaced with a check mark/square.
3. EFUP label: circle with two arrows and number in the middle
EFUP (Environment-Friendly Use Period) is an “environmentally friendly use cycle”. In essence, this is the amount of time that toxic substances stay in the product not yet capable of leaking out under normal conditions of use.
EFUP label conventions that businesses need to understand:
- Products pass limit of any substance: use the orange symbol consisting of two arrows forming a circle, number in the middle is the number of EFUP years (for example, a circle marked 10 means a period of 10 years from the date of manufacture).
- Products do not exceed which substance limit: a special EFUP label bearing the letter “e” can be used to indicate that all substances in the restricted group are below the limit.
- The way to calculate EFUP is specified in a separate guidance standard (SJ/Z group); Businesses need to compare the current version when building a calculation basis for their products.
Easy to confuse: EFUP label no is a food-style “use by” date, and is also not a warranty period. It is a statement about the level of chemical safety over time. Mistyping numbers — or copying another product’s EFUP label — is the type of mistake that is discovered the fastest.
4. When must the date of manufacture be added?
Because EFUP counts from the date of manufacture, so in some cases the product must have an additional manufacturing date on the label — specifically when the EFUP cycle is shorter than the product’s design life. The date is recorded in the form day/month/year, with a four-digit year.
This is a detail that is rarely noticed but is important when goods are stored for a long time: if there is only an EFUP circle without a date stamp, the inspector cannot determine how many years the product has “run” in the safety cycle. Businesses should agree with the printer and importer on their specific case, and compare the current label regulations.
5. SJ/T 11364-2024: current version and what needs to be checked
Previously, China’s label requirements were contained in SJ/T 11364-2014 — the version in common use for nearly a decade. When GB 26572-2025 was introduced, the label content was integrated and updated, tied to the original version. SJ/T 11364-2024.
Because this is an electronics industry standard (“SJ/T”), businesses need to understand its true nature: SJ/T 11364 itself is a standard. recommended, but when invoked by GB 26572-2025, compliance with the label becomes part of the mandatory obligation. In other words: the legal path goes through GB, while the technical details for printing labels lie in SJ/T.
When switching from the 2014 version to the 2024 version, businesses should review at least four points: the list of substances on the declaration sheet, the specifications and size of the EFUP symbol, the way of recording the date of manufacture, and the language/format requirements of accompanying documents. The specific details of the 2024 version need to be compared to the standard verbatim — this article does not replace the original.
6. Six substances or ten substances on the board?
This is the biggest transition point and also the most common printing error.
| Phase | Number of substances on the announcement table | Category |
|---|---|---|
| According to GB/T 26572-2011 (formerly) | 6 substances | Pb, Hg, Cd, Cr(VI), PBB, PBDE |
| According to GB 26572-2025 (from August 1, 2027) | 10 substances | 6 substances above + 4 phthalates (DBP, DIBP, BBP, DEHP) |
Many pre-printed label molds and templates in Vietnam still follow the 6-substance table of GB/T 26572-2011. When GB 26572-2025 comes into force, the declaration needs to be expanded to 10 lines of substance. This is a small technical matter but lies in the printing stage — so it’s easy to miss until reminded by the importer.
7. Which products must be labeled?
It is necessary to separate two concepts that are often combined into one:
| Label obligations | Obligation to limit substance | |
|---|---|---|
| Product is inside regulatory management list (compulsory group) | Yes | Yes — must meet the 10 substance limit |
| Other electrical and electronic products circulating in China | Yes | Not required (voluntary encouraged) |
In other words: eye pressure for most electrical and electronic products circulating on the Chinese market, while the obligation to meet the substance limit is only mandatory for product groups that are in the list of regulated management (list announced by the management agency, including familiar groups such as computers, display devices, phones, refrigerators, washing machines, air conditioners, printers… — The complete list needs to be compared to the current version).
Practical consequence: don’t infer “my product doesn’t belong to the category so it doesn’t need a label”. Not being on the list only exempts you from the obligation to meet the substance limit, but does not eliminate the obligation to label.
8. Five common errors when printing labels
- Use the table of 6 substances while the new template requires 10 substances.
- Entered wrong EFUP number — copied from other products, or has no basis in calculating according to guiding standards.
- Missing publication table in the document — just put the label on the machine and forgot the table in the instructions.
- Translate the table into another language or restate it with homemade symbols, while the request is a simplified Chinese table with O/X symbols.
- The EFUP symbol is incorrect — wrong circle ratio, wrong color (orange/black), or printing too small to read.
9. Frequently asked questions
Is the Chinese RoHS label the same as the CE mark?
No. The CE mark is the result of a conformity assessment process and demonstrates that the product meets applicable directives. The Chinese RoHS label (EFUP + declaration sheet) is the tool information disclosure, indicates the status of hazardous substances and the safety cycle — but does not by itself certify that the product meets or fails a directive.
Is just putting the EFUP label on the product enough?
Not yet. Label obligations include the substance declaration table in the accompanying documents. In fact, many batches were cited because there was a label on the machine but a missing label in the instructions.
Do products that meet EU standards have to have their labels re-labeled?
Yes. Having met EU RoHS, the “substance” part can almost be reused (provided that all four phthalates have been tested), but the EFUP label and declaration table are China’s own requirements, not available in the EU.
Does the announcement sign “X” mean the product is banned from sale?
No. “X” is simply a statement that the substance exceeds the limit at the homogeneous material level. The product only violates when it belongs to the group required to comply with the limit but still exceeds the limit, or when it lacks a label/declaration according to regulations.
Does the label need to be updated before August 1, 2027?
Should be done early. Chinese importers often request new documents and labels 6–12 months before the effective date, which is right in 2026. Updating the label mold should start from the packaging design stage.
10. Conclusion
The Chinese RoHS label is not a single symbol, but a system of claims EFUP label on the product and substance declaration table in documents. Correct understanding of this mechanism helps businesses avoid the most common mistake: treating Chinese labels as European CE marks.
Three things to do immediately: one, review the current label to see if it follows the 6 or 10 substance list; two, check the EFUP label and the year basis; three, ensure documents accompanying the product have the correct format announcement. All should be checked against the current SJ/T 11364-2024 and confirmed with the Chinese importer.
References
- SJ/T 11364 — Marking for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products (Chinese electronics industry standard; 2014 version and 2024 version)
- GB/T 26572-2011 and GB 26572-2025 — substance limit requirements in electrical and electronic products
- Guidance standards for calculating environmentally friendly use cycles (group SJ/Z) — need to compare with the current version
- Documents introducing the EFUP label and substance declaration tables of international certification organizations
Related articles
- How are RoHS and REACH different? Thresholds, scope and reporting obligations
- Is the RoHS report from 2 years ago still available? When to try again?
- What is the correct RoHS label? What words are considered misleading?
- J-Moss (Japan) and K-RoHS (Korea): who needs it, how is it different from the EU?
- What is GB/T 39560? Why does China uniquely specify this set of test methods?
- Circular 30/2011/TT-BCT and European RoHS: how do Vietnamese businesses comply with both?
- GB 26572-2025: China’s first mandatory RoHS standard, effective August 1, 2027
- What is RoHS? Complete guide to Directive 2011/65/EU and its 10 restricted substances
Discuss further
Disclaimer
This article is an interpretive content compiled by us; not legal advice. Descriptions of the EFUP label and substance declaration table are summarized to help understand the principles, and can be shortened from the standard text.
Before applying to a specific product, businesses need to compare the original standard SJ/T 11364-2024 and current related documents/standards, and confirm with the importer or accredited testing unit in China.
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