Date August 1, 2025, China officially announced GB 26572-2025 — “Requirements to limit the use of hazardous substances in electrical and electronic products”. Here it is first mandatory RoHS standard of China, yes effective from August 1, 2027 and completely replace GB/T 26572-2011.
For Vietnamese businesses exporting to China — or buying components from China to resell — this is the biggest change in the past 15 years in this market. The article fully summarizes the new content and a to-do list before 2027.
1. From “GB/T” to “GB”: why is the letter T important?
The Chinese standard system distinguishes two types very clearly:
| Symbol | Type | Properties |
|---|---|---|
| GB/T | National standards recommended | Voluntary application; Businesses can choose to comply or not |
| GB | National standards required | Forced compliance; is the basis for market surveillance and sanctions |
Old standard GB/T 26572-2011 is a recommended standard — businesses comply largely because of commercial requirements from customers, not because of direct legal obligations. New standard GB 26572-2025 remove the “T”: from August 1, 2027, this is a legal obligation.
Practical consequences: electronic goods entering the Chinese market will have an additional layer of mandatory inspection, which may be inspected at the port, at the warehouse or at the point of sale; and Chinese importers will tighten documentary requirements with foreign suppliers long before the effective date.
2. Four main changes of GB 26572-2025
- Expanded from 6 to 10 substances — adds four phthalates, similar to EU RoHS.
- Specify only one set of test methods: string GB/T 39560.
- Divide into two product groups with different obligations: Group I and Group II.
- Raise label regulations to mandatory level — the content of SJ/T 11364-2024 is incorporated into the mandatory national standard.
3. List of 10 substances and limits
| # | Quality | Abbreviation | Threshold (% mass) |
|---|---|---|---|
| 1 | Lead | Pb | ≤ 0.1 |
| 2 | Mercury | Hg | ≤ 0.1 |
| 3 | Cadmium | CD | ≤ 0.01 |
| 4 | Hexavalent chromium | Cr(VI) | ≤ 0.1 |
| 5 | Polybrominated biphenyls | PBB | ≤ 0.1 |
| 6 | Polybrominated diphenyl ethers | PBDE | ≤ 0.1 |
| 7 | Dibutyl phthalate | DBP | ≤ 0.1 |
| 8 | Diisobutyl phthalate | DIBP | ≤ 0.1 |
| 9 | Benzyl butyl phthalate | BBP | ≤ 0.1 |
| 10 | Bis(2-ethylhexyl) phthalate | DEHP | ≤ 0.1 |
The four new substances are four phthalates (DBP, DIBP, BBP, DEHP) — plasticizers commonly found in PVC of cables, flexible housings, glues and printing inks. These are also the four substances that the EU added to RoHS with Directive (EU) 2015/863. In other words: after this change, The substance lists of China and the EU almost overlap in quantity and limit.
Implication for Vietnamese businesses: if the product has met EU RoHS and has been tested for phthalates in cables, fabric covers, and soft plastic covers, then the “substance” part is considered done. The missing part is usually label and Test method according to GB/T 39560.
4. Test method: GB/T 39560 series is the only choice
This point is clearly different from the EU. EU RoHS no specify only one set of test methods — businesses can use IEC 62321, or an in-house method of equivalent reliability, as long as it can be proven. GB 26572-2025 then Specify series GB/T 39560 as the only method of determination.
GB/T 39560 series (“Determination of certain substances in electrical and electronic products”) is built in accordance with the international standard IEC 62321, including the following main parts:
| Content | Corresponds to IEC 62321 |
|---|---|
| Overview and general instructions | Part 1 |
| Dissection, disassembly and mechanical sample preparation | Part 2 |
| X-ray fluorescence (XRF) screening | Part 3-1 |
| Determine mercury | Part 4 |
| Determination of cadmium, lead, chromium in polymers and electronics | Part 5 |
| Determination of PBB and PBDE | Part 6 |
| Determination of hexavalent chromium (colorimetric method; ion chromatography method) | Parts 7-1 and 7-2 |
| Determination of phthalates | Part 8 |
Consequences to note: a RoHS test report according to IEC 62321 in a Vietnamese laboratory may not be accepted directly for the purpose of demonstrating compliance with GB 26572-2025, since the standard requires a method according to GB/T 39560. In fact the two sets of standards are very close in principle and equipment, but Must ask the testing room first: whether the report properly cites GB/T 39560 or not.
5. Two product groups: Group I and Group II
| Group I | Group II | |
|---|---|---|
| Conditions | Product is inside regulatory management list (list published by the management agency) | Remaining products |
| Obligation on substance limitation | Required reached the limit of 10 substances | Only obligation label; REACHing the substance limit is encouraged voluntarily |
| Label obligations | Yes | Yes |
This grouping is a point to grasp firmly because it is decisive volume work: products in Group I must be fully tested; Group II products still must be properly labeled but are not required to prove substance limits. Businesses need to check the current list to know which group their products belong to — and should ask the Chinese importer, because this is the basis they use when checking goods.
6. Label: EFUP and list of 6 substances are now mandatory
Previously, China’s label regulations were in standard SJ/T 11364 (2014 version). GB 26572-2025 include these label requirements in mandatory national standards, through the integration of the content of SJ/T 11364-2024.
Two familiar label ingredients of the Chinese market:
- EFUP label (Environment-Friendly Use Period): “environmentally friendly use period” symbol — a circle with an arrow and a number in the middle, representing the number of years (from the date of manufacture) that toxic substances in the product do not leak out under normal use conditions. If this cycle is shorter than the design life, it is necessary to record the manufacturing date in the form of day/month/year (4 digits for the year).
- Table announcing toxic substances: The table lists 10 substances (after updating) and for each substance, write “O” (content below the required limit) or “X” (exceeds the limit), with an EFUP label in the middle of the table.
Practical note: Many pre-printed label sets in Vietnam still follow the table 6 substances of GB/T 26572-2011. With the August 1, 2027 date and the addition of four phthalates, the label mold needs to be updated to 10 lines of substance. This is a small thing but the easiest to miss, because it lies in the printing stage, not in the technical stage.
7. Update terminology
GB 26572-2025 changes the wording and adds three new definitions:
- The phrase “restricted substances” is replaced by “toxic substance” (hazardous substances).
- Additional definitions “environmentally friendly use cycle” (environment-friendly use period).
- Additional definitions “regulatory management list” — basis for determining Group I.
- Additional definitions “exemption” (exemption).
It may sound like just a matter of words, but here’s an important signal: defining “exemption” right in the standard means that China’s exemption mechanism will be more clearly operational — and businesses using exemptions will have to clearly state it in their records, just like the EU is doing.
8. Quick comparison of EU RoHS and GB 26572-2025
| Criteria | EU — Directive 2011/65/EU | China — GB 26572-2025 |
|---|---|---|
| Limited number of substances | 10 | 10 (after update) |
| Threshold | 0.1% (Cd 0.01%) according to homogeneous material | 0.1% (Cd 0.01%) |
| Test method | No single indication; IEC 62321 is the common reference | Unique designation GB/T 39560 |
| Label | No separate RoHS label; CE marking is required | The EFUP label and substance declaration sheet are required |
| Exemption mechanism | Annexes III and IV, extended in installments | There is a definition of exemption in the standard |
| Time of application | 2011/65/EU from 2013; Phthalates from 2019/2021 | Required words August 1, 2027 |
9. What do Vietnamese businesses need to do, according to the timeline?
- Right now — browse the categories: Determine whether products sold into China belong to Group I or Group II. Ask the Chinese importer directly; This is the party responsible before the domestic management agency.
- Before 2027 — test for four phthalates: If you’ve never tried phthalates, start with PVC cables, flexible plastic covers, glue and ink. This is the highest risk group.
- Before 2027 — test room closing with GB/T 39560: Check the scope of accreditation of the testing laboratory and request a report citing the correct GB/T 39560 series.
- Before 2027 — label mold update: From the table of 6 substances to 10 substances; Check the EFUP label specifications and manufacturing date.
- Before 2027 — technical profile update: Added phthalate results, new substance declaration table, and component supplier documents.
- Periodically — monitor the compliance management list: The catalog can be expanded, changing the grouping of your products.
10. Frequently asked questions
Does GB 26572-2025 apply to imports into China?
Yes. Mandatory national standards apply to products circulating in the Chinese market, regardless of domestic or imported production. The Chinese importer is usually the party subject to direct inspection, and they will require the foreign supplier to provide documents.
Does a product that has passed EU RoHS automatically meet GB 26572-2025?
Regarding the list of substances and limits, they are almost identical. But there are three separate things: EFUP label and substance declaration table (mandatory), test method according to GB/T 39560, and product grouping according to Chinese categories. So the answer is: The platform is reusable, but not automatically achieved.
Is the RoHS report according to IEC 62321 available?
Should not be used directly. GB 26572-2025 specifies GB/T 39560. The principle and equipment are almost equivalent, but the report needs to cite the correct set of specified standards so as not to be rejected during inspection.
Group II only needs the label — so can the trial be abandoned altogether?
Regarding legal obligations under GB 26572-2025, Group II only requires labels. But in reality, customers, retail chains and other regulations (for example, e-commerce platform requirements, or contractual requirements) can still force businesses to try. And if the product is moved into the regulatory control category, full obligations will apply.
What is the landmark to remember?
August 1, 2027 — effective date of GB 26572-2025. But the time to act is much earlier: Chinese importers often request new documents 6–12 months before the effective date, which is right in 2026.
11. Conclusion
GB 26572-2025 is China’s move from “recommended” to “mandatory” on RoHS, with four core changes: 6 → 10 substances (plus four phthalates), uniquely designates the GB/T 39560 series as the test method, divides the product into two groups, and raises the EFUP label requirement to mandatory level. Magnetic effect August 1, 2027.
Three things to do in 2026: one, determine whether the product belongs to Group I or Group II; two, test for four phthalates if you haven’t tried them before; three, update the label mold from 6 to 10 substances and choose a testing laboratory with GB/T 39560 within the scope of accreditation.
References
- GB 26572-2025 — Requires restrictions on the use of toxic substances in electrical and electronic products (announced August 1, 2025, effective August 1, 2027)
- GB/T 26572-2011 — previously recommended standard
- SJ/T 11364-2024 — label regulation, incorporated into GB 26572-2025
- GB/T 39560 series — determination of certain substances in electrical and electronic products
- SGS Safeguards 137/25 (September 18, 2025) — China Issues Mandatory RoHS Standard – GB 26572-2025
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Discuss further
Disclaimer
This article is an interpretive content compiled by us; not legal advice. The content of GB 26572-2025 is summarized from published information and introductory documents of certification organizations; may have been shortened from the standard text.
Before applying to a specific product, businesses need to compare the original standard GB 26572-2025, the current conformity management list, and consult with an importer or accredited testing unit in China.
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