A RoHS test report made according to IEC 62321 at an accredited laboratory is still possible not accepted when businesses need to demonstrate compliance with new Chinese standards. The reason lies in a small line in GB 26572-2025: this standard sole indication series of test methods GB/T 39560.
Correct understanding of the GB/T 39560 series helps businesses avoid two costly mistakes: one, pay for a standard testing kit and then have to do it again; two, thinking that GB/T 39560 is a “different” standard in principle, when in fact it is the equivalent set of IEC 62321.
This article explains what the GB/T 39560 series is, how it maps to the IEC 62321 series in principle, why China chose to designate only one series, and what businesses need to confirm with the testing laboratory before signing a contract.
1. What is GB/T 39560?
GB/T 39560 is one Chinese national standard chain (multi-part series) with a general name “Determination of some substances in electrical and electronic products“. In purpose, this is a set of test methods for determining the content of restricted substances — exactly the role that IEC 62321 plays at the international level.
Three points to understand about the nature of this chain:
- This is the chain GB/T (with a “T”) — is a recommended standard per se. But as GB 26572-2025 invokes it, correct use of the set becomes a condition for demonstrating compliance with the required standard.
- It is built corresponds to IEC 62321 — same division logic, same group of substances, same device principle.
- It no replacement IEC 62321 in other markets; it is just the set designated by China for GB 26572-2025 compliance purposes.
2. Map the GB/T 39560 series to IEC 62321 according to the principles
The table below maps accordingly content and principles. The specific part number and year of issuance of each part in the GB/T 39560 series is required Compare current standards — businesses should not quote part numbers from a secondary source.
| Method content | Corresponds to IEC 62321 | Used for |
|---|---|---|
| Overview and general instructions | Part 1 | Application framework, terminology, workflow |
| Dissection, disassembly and mechanical sample preparation | Part 2 | Divide products into uniform material levels |
| X-ray fluorescence (XRF) screening | Part 3-1 | Quick test, no sample destruction |
| Determine mercury | Part 4 | Hg in various materials |
| Determination of cadmium, lead, chromium in polymers and electronics | Part 5 | Cd, Pb, Cr (total) by wet method |
| Determination of PBB and PBDE | Part 6 | Bromine group is flame retardant by GC-MS |
| Determination of hexavalent chromium (Cr(VI)) by colorimetric method | Parts 7-1 and 7-2 | Two different sample objects, same color measurement principle |
| Determination of phthalates | Part 8 | Four phthalates DEHP, BBP, DBP, DIBP |
Important point: here not two different sets of scientific standards. Same sample, same equipment, same quantitative principles — just different reference text system. Therefore, once a laboratory has IEC 62321 capability, the gap to implementing and reporting according to GB/T 39560 is often much smaller than initially perceived.
3. Why does China designate only one ministry?
Specifying only one method chain is an intentional choice, not a formal one. Four main reasons:
- Comparability: When all laboratories use the same set of methods, results between laboratories, batches and time points can be directly compared.
- Coercion: Mandatory standards need a clear measure to monitor the market and handle disputes. “Use the equivalent method” is more difficult to enforce than “use this exact set”.
- Reduce disputes: When the importer and supplier disagree, a pre-specified set of methods helps to finalize technical arbitration.
- International harmonization: GB/T 39560 is built on IEC 62321, so it is still compatible with the global supply chain — the only difference is the text “door”.
4. Differences with the EU: The EU does not specify a single method
| Criteria | EU — Directive 2011/65/EU | China — GB 26572-2025 |
|---|---|---|
| Test method | No single indication; IEC 62321 is the common reference | Uniquely designate the GB/T 39560 series |
| “Equivalent” method | Acceptable if equivalent reliability is demonstrated | Do not make arbitrary substitutions; must follow the specified set |
| Reference method set | IEC 62321 (multipart series) | GB/T 39560 (corresponding to IEC 62321) |
Practical consequences: a report citing IEC 62321 is sufficient for CE dossier in the EU, but not sure enough for GB 26572-2025 compliance records. The principles and equipment are almost the same, but the standard reference line on the report must be the same as the set specified by China.
5. Three classes of methods in the sequence: screening — identification — analysis
To properly read and order services, it is necessary to distinguish three classes of work in any RoHS method set, including GB/T 39560:
- Screening: Use XRF to quickly check the total element. No sample destruction, fast, cheap — but only indicates “at risk”, does not determine valence status (e.g. total Cr is different from Cr(VI)).
- Determination: Use wet methods (ICP-OES, ICP-MS, AAS…) or GC-MS to accurately quantify substance content in homogeneous materials.
- Specification: with chromium, separately determine Cr(VI) — the most technically demanding part of the whole set.
A common mistake when reading reports: considering XRF results as final. In the method chain structure, XRF belongs to the screening layer — it only opens the way to the identification step when there are signs of exceeding the limit.
6. Cr(VI): the most confusing point in the series
In the entire series, the determination of hexavalent chromium is where expertise focuses and is also the area where the method is most commonly misunderstood.
Things to remember clearly: Both branches of methods for Cr(VI) are based on the principle of COLOMETRY. They are different sample object and sample handling, not the nature of the reaction:
- Branch 7-1: applied to metal coatings — used to test hexavalent chromium in passivation/plating layers on metals.
- Branch 7-2: applied to polymers and electronic materials — after separating Cr(VI) from the sample matrix, quantified by colorimetry.
Ion chromatography (IC) is just a complementary technique In some versions of the document, it is not the main principle of the entire Cr(VI) branch. Therefore, if a document describes “7-2 is ion chromatography”, that is a misinterpretation that needs to be corrected. Technical details and specific part numbers of GB/T 39560 need to be compared with the standard version — but the colorimetric principle for Cr(VI) is the point throughout.
7. Test report: what needs to be confirmed with the testing laboratory?
To avoid rework, businesses should clearly agree on four questions from the beginning:
- Report yes Correctly refer to the GB/T 39560 series or not (not just IEC 62321)?
- Testing room available scope of recognition cover the necessary parts of GB/T 39560?
- With chromium, the report says yes separate Cr(VI) by colorimetric method, or total Cr indicator from XRF?
- Report included all four phthalates (according to the corresponding part of the chain) if the product belongs to the group that must meet the limit of 10 substances?
8. Should businesses use IEC 62321 or GB/T 39560?
| Target market | Standard method should be used |
|---|---|
| EU / market uses IEC 62321 | IEC 62321 (multipart series) |
| China (according to GB 26572-2025, from August 1, 2027) | GB/T 39560 |
| Products sold in both markets | Ask if the testing room can provide it two reports same data, different references — often more economical than running two sample sets |
For businesses exporting to many markets, the optimal way is often to choose a testing laboratory that has both IEC 62321 and GB/T 39560 within the scope of accreditation, to use the same set of samples for two purposes.
9. Frequently asked questions
Is GB/T 39560 a translation of IEC 62321?
Not a word-for-word translation, but built accordingly in structure and principle. Both are divided by parts, same group of substances, same type of equipment. So the results are usually compatible, but the text references are different.
Is the old IEC 62321 report still available for China?
Should not be used directly for profile GB 26572-2025. In principle, they are close, but the standard specifies the GB/T 39560 set, so the report needs to cite this set to avoid being rejected.
Why must Cr(VI) be separated but XRF cannot?
XRF measures the total element, so it cannot distinguish metallic chromium from hexavalent chromium. Determining Cr(VI) requires a chemical method (colorimetry) to capture the correct valence state — this is the “form analysis” layer in the series.
Are the four phthalates in the GB/T 39560 series?
Yes — corresponds to the section for phthalates in IEC 62321. This matches GB 26572-2025 expanding the substance list from 6 to 10, including the four phthalates DEHP, BBP, DBP, DIBP.
Is the cost of testing under GB/T 39560 much higher?
There should not be a big difference, because the principle and equipment are almost identical to IEC 62321. The real increase in cost lies in the sample volume removed and in the four phthalates, not in which method set is used.
10. Conclusion
GB/T 39560 is a set of Chinese RoHS test methods, built in accordance with IEC 62321 and approved by GB 26572-2025 sole indication for compliance purposes. Correctly understanding this nature helps businesses not to be confused by the “new standard”: in terms of science, this is a familiar set; Regarding the text, this is a new constraint that needs to be followed.
Three things to do in 2026: one, request the testing laboratory to confirm that GB/T 39560 is within the scope of accreditation; two, prefix the standard citation line on the report; three, ensuring the Cr(VI) and four phthalates fractions are tested properly, not just screening XRF results.
References
- GB/T 39560 — Chinese national series of standards for the determination of certain substances in electrical and electronic products (need to compare with current version)
- GB 26572-2025 — requirements to limit the use of hazardous substances in electrical and electronic products
- IEC 62321 — international standard for the determination of restricted substances in electrical and electronic products
- Directive 2011/65/EU (RoHS 2) — regulations on conformity assessment and test methods
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- GB 26572-2025: China’s first mandatory RoHS standard, effective August 1, 2027
- What is IEC 62321? What parts does the RoHS test method set include and what substances is it used for?
- EFUP label and Chinese RoHS mark: read the correct table SJ/T 11364-2024
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Disclaimer
This article is an interpretive content compiled by us; not legal advice. The mapping between GB/T 39560 and IEC 62321 is presented in principle; The specific part number and year of issuance need to be compared to the original standard.
Before applying to a specific product, businesses need to compare the verbatim of GB/T 39560 and the current GB 26572-2025, along with the accreditation scope of the designated testing laboratory.
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