Customers ask: “My product has passed European RoHS, so if I sell it to China, Korea, Japan, Russia or California, do I need to do it again?” The honest answer is: depending on the market — because each place has its own “RoHS code”, which differs in the substance list, enforcement method and type of label required.
What makes this confusing is the general rules look similar: same few heavy metals, same 0.1% limit, same talk about “homogeneous material”. But just one detail difference – for example, where there are 6 substances limited, where there are 10 substances – the document proving conformity can no longer be used together.
This article builds a table comparing six markets at the principle level: EU, China, Korea, Japan, EAEU and California. The goal is not to replace the original document, but to let businesses know which documents they need to compare correctly before printing labels and signing declarations of conformity.
1. Six regulatory “roofs” — an overview first
The common point of all six places: they all limit a number of toxic substances in electrical and electronic products, and they all take common standards from four familiar heavy metals – lead, mercury, cadmium, hexavalent chromium. The difference lies in three questions:
- Limitations how much substance? And what substances?
- How to execute — prohibited from being placed on the market, mandatory labeling, nice conformity declaration?
- Who checks and any mark/label is the evidence?
| Market | Background text | Number of substances restricted (principle) | Main mechanism |
|---|---|---|---|
| EU | Directive 2011/65/EU (RoHS 2, amended by (EU) 2015/863) | 10 substances | Ban on market + CE mark + technical documents |
| China | GB 26572-2025 (mandatory, effective August 1, 2027), replaces GB/T 26572-2011 | 10 substances | Mandatory limit + label according to SJ/T 11364 |
| Korea | Regulations on recycling of electrical and electronic equipment and vehicles (K-RoHS) | 10 substances (gradually harmonized with the EU) | Limit + conformity declaration |
| Japan | J-Moss (marking system according to JIS C 0950) | 6 substances | Required label according to the specified product group |
| EAEU | Technical regulations of the Eurasian Economic Union on substance restrictions in electrical and electronic products | 6 substances | Limit + EAC conformity mark |
| California (United States) | Electronic Toxins Act (EWRA) | 4 heavy metals | Restricted to groups of devices with specified screens |
Important note: The table above is the picture principle. The number of substances, product ranges and potency dates for each market change over time, so any specific details need to be met. Compare the current text verbatim before using it for a real batch.
2. First axis: substance list — 4, 6 or 10?
The most practical way of classifying is to count from the “core” out:
- Heavy metal 4 core: lead (Pb), mercury (Hg), cadmium (Cd), hexavalent chromium (Cr(VI)). Almost every market limits these four substances.
- Up to 6 substances: Add two groups of brominated flame retardants: PBB and PBDE. This is the popularity of “6 elements” type programs — common in Japan (J-Moss) and EAEU.
- Up to 10 substances: add four phthalates (DEHP, BBP, DBP, DIBP). This is the EU level after 2015, and is also the direction that China and South Korea have followed.
The practical consequences are clear: one product REACHing 6 substances is not necessarily achieving 10 substances — because there are four phthalates left. On the contrary, products with 10 substances usually cover the requirement of 6 substances (because 6 substances are a subset of 10), unless That market has its own qualities beyond the EU list. Therefore, the strongest set of documents to go to many markets is the set that proves all 10 substances, plus separate comparisons for each place.
3. Second axis: limit and calculation — almost identical
Here’s the good news: most markets use the same limits and the same calculation logic.
| Factor | Popularity level |
|---|---|
| General limit | 0.1% by mass (equivalent to 1,000 ppm) |
| Particularly cadmium | 0.01 % (equivalent to 100 ppm) — 10 times tighter |
| How to calculate | Theo homogeneous material, not the whole product |
Because of the same limit and the same calculation method, Test results and test methods are reproducible between markets. What has to be redone is only part conformity conclusion: compare the results with the correct substance list and the correct exemption list of that market.
4. Third axis: enforcement mechanism — ban, label or declare?
This is where markets differ the most, and is also where businesses often misunderstand.
| Mechanism | What does it mean? | Typical market |
|---|---|---|
| Prohibited from being placed on the market | Exceeding the limit without an exemption cannot be sold; Must demonstrate compliance | EU |
| Mandatory limit with label | Must meet the limit and print the board/label according to regulations | China |
| Declaration of conformity | Enterprises self-assess and declare and are responsible for the information | Korea |
| Labeling required | The focus is information disclosure substance content for buyers to know | Japan (J-Moss) |
Points to remember: “labeled” is not the same as “allowed to exceed the limit”. In some systems, the labeling is to declare the substance status, not the license. Confusion between “must be labeled” and “exempt” is a common reason why goods are detained at the border.
5. Fourth axis: labels and conformity marks
| Market | Typical markings/labels | Note the principle |
|---|---|---|
| EU | CE mark | CE covers RoHS; accompanied by declaration of conformity and technical documents |
| China | Label according to SJ/T 11364 (label style EFUP/substance table) | The label is covered by national mandatory regulations |
| Korea | Label/mark of the K-RoHS compliance declaration system | Associated with the declaration obligations of the manufacturer/importer |
| Japan | J-Moss mark (blue/orange according to substance state) | The mark shows whether the product is in excess or not |
| EAEU | EAC mark | A common mark for the entire block |
| California | There is no separate CE mark of conformity | Enforcement through regulatory agency requirements and procurement conditions |
A note about label language: absolutely do not label yourself “certified” or “certified” if there is actually only a test report. Each market has its own regulatory wording, and misstatements can be considered misleading.
6. Detailed comparison table of six markets
| Criteria | EU | China | Korea | Japan | EAEU | California |
|---|---|---|---|---|---|---|
| Number of substances (principle) | 10 | 10 | 10 | 6 | 6 | 4 |
| Specific cadmium 0.01 % | Yes | Yes | Yes | Yes | Yes | Yes |
| How to calculate | Homogeneous materials | Homogeneous materials | Homogeneous materials | Homogeneous materials | Homogeneous materials | Homogeneous materials |
| Mechanism | Ban + CE | Required + label | Limit + declaration | Label | Limit + EAC | Restrictions by device group |
| Scope | Open scope for EEE | Product grouping | According to EEE category | Designated product group | By product category | Devices with screens (regulated group) |
| Primary evidence | Technical documents + declaration of conformity | Test report + label | Declaration of conformity + report | Label + internal data | Profile + EAC marking | Documents according to agency requirements |
How to read the table: the first four lines are almost identical, the “mechanism” and “scope” lines are where the difference is. In other words, Test results can be used everywhere, but the proof and type of labels must be made according to each place.
7. Why do some markets only stop at 6 substances?
Japan (J-Moss) and EAEU keep the level of 6 substances while the EU has increased to 10. There are two common reasons:
- Management philosophy: Some places choose to “announce so the market can self-regulate” (label) instead of completely banning it. J-Moss is a prime example — the focus is on substance information transparency.
- Update cadence: Trade blocs update substance lists according to their own schedules. When the EU added phthalates in 2015, other markets took more time to harmonize.
So don’t assume “the moves that follow will always keep 6 suits”. China is the latest example of how a market can go from six to 10 substances and make it mandatory — so the safe strategy is Designed according to 10 substances and track changes in each location.
8. 5-step process when selling to many markets
- List target markets for each product code, with sales channel (direct, import, e-commerce platform).
- Determine the highest “quality level”. must meet (4, 6 or 10) and take that as the design goal.
- Establish a common material data set at the homogeneous material level, enough to answer for all 10 group substances.
- Compare individual exemptions for each market — exemptions are not shared.
- Prepare labels and separate statements For each market, clearly state the compared legal basis.
9. Five common misconceptions
- “If you meet EU RoHS, you can sell everywhere.” Not really — the 10-substance market is convenient, but places that require private labels (China, Japan) still have to comply with the label part.
- “6 substances are enough for everyone because that is the international standard.” Wrong — EU, China, Korea are already at level 10 substances.
- “Mandatory labeling means being allowed to exceed the limit.” False — the label is a disclosure, not a license.
- “Shared exemption across markets.” False — each has its own exemption category and its own update schedule.
- “The number of substances and potency markers remain unchanged.” Incorrect — these are frequently edited documents; Must check each batch.
10. Frequently asked questions
If we have reached 10 substances according to the EU, do we have to retest for China?
There is usually no need for technical retesting, because the substance list is similar and the methods are shared. But the limit, product range and label requirements must be reconciled according to current Chinese regulations.
Is J-Moss a mandatory substance limiter like RoHS?
Not in the same way. J-Moss is the system label by designated product group: the focus is on disclosing information on substance content, different from the EU-style market ban mechanism.
How is California different from other US states?
California has its own laws on toxics in electronic devices, focusing on the regulated group of devices with screens, rather than a federal RoHS set. The scope and list of equipment need to be compared with current state documents.
Does this table replace reading the original text?
No. This is a framework for orientation. All substance numbers, validity dates and label requirements must be compared verbatim to the current effective text in each market before application.
At what level should the product be designed?
As high as the target market requires — typically 10 substances — and keep the material data set at a consistent material level. This method helps reuse data when opening new markets.
11. Conclusion
Six markets, six sets of regulations, but same technical core: four heavy metals, limit 0.1 % (Cd 0.01 %), calculated on homogeneous material. The difference focuses on number of substances (4, 6 or 10), enforcement mechanism (ban, label, declare) and label type.
Pragmatic strategy: design and collect data for 10 substances at a uniform material level, then separate labels and claims for each market. So businesses only have to do the technical part once, instead of trying again for each location.
And the principle cannot be abandoned: all legal details must be compared verbatim to the current document. The reference table helps you know what to read — it doesn’t read it for you.
References
- Directive 2011/65/EU (RoHS 2) and Directive (EU) 2015/863 — EU
- GB 26572-2025 and label set SJ/T 11364 — China
- Regulations on recycling of electrical, electronic and vehicle equipment (K-RoHS) — Korea
- J-Moss (JIS C 0950) — Japan
- Technical regulations of the Eurasian Economic Union on substance restrictions in electrical and electronic products (EAC mark)
- Electronic Toxins Act (EWRA) — California, United States
Related articles
- How are RoHS and REACH different? Thresholds, scope and reporting obligations
- RoHS for textiles, footwear and toys: when does RoHS NOT apply?
- CE marking for electronics: RoHS, EMC, LVD — and why WEEE is a different story
- Same toy, three sets of limits: RoHS vs EN 71-3 vs CPSIA
- Selling electronics on Amazon/eBay Europe: how must foreign sellers prove RoHS?
- What is RoHS? Complete guide to Directive 2011/65/EU and its 10 restricted substances
- GB 26572-2025: China’s first mandatory RoHS standard, effective August 1, 2027
- RoHS and ELV: two different sets of substance limits for electronics and automobiles
- 10 RoHS restricted substances: how do the 0.1% and 0.01% limits apply to “homogeneous materials”?
Discuss further
Disclaimer
This article is an interpretive content compiled by us; not legal advice. The number of substances, limits, scope and validity milestones for each market are stated at the principle level and It is necessary to compare the current text verbatim before applying to specific products.
See more: Copyright Policy & Disclaimer by ticforall.com.
