China RoHS for Small Teams: What to Check First, What Can Wait

Selling electronics into China, or sourcing from Chinese manufacturers, means dealing with SJ/T 11364-2014 — usually just called China RoHS. It's a different system from the EU's RoHS Directive, with its own paperwork and its own marking requirements, so it's worth understanding on its own terms even if you've already handled RoHS for Europe.

For a small team without a dedicated compliance person, the goal isn't to master every clause. It's to know the handful of things that actually get checked, and to get those right first.

**What matters first**

Two things should be sitting in your files before a shipment moves: a China RoHS Declaration of Conformity and a material composition report from your supplier. These documents state what's in the product and confirm it stays under the restricted substance limits. If your supplier can't produce them, that's the first thing to chase — not the last.

The substance limits themselves are straightforward and match figures you may already recognize from other RoHS rules:

You also need the Hazardous Substance Table (HST) printed on the product or in the manual, and the Environmental Use Period (EUP) marking — the green circle with a number inside it, showing how many years the product can be used safely before the substances inside pose a risk. These aren't optional extras; they're part of the minimum package.

**What can wait**

Deep technical audits of every component, or building an internal testing program, isn't something a small team needs to tackle on day one. Start with getting documentation from suppliers and confirming the EUP marking is correct. Refine your process once that baseline is solid.

**The minimum to get right**

If you take away one thing: don't accept a shipment without the Declaration of Conformity, the material composition report, and correct EUP marking on the product itself. Everything else can be built up over time.

If you're sourcing from multiple suppliers, keeping track of who has provided what is the real challenge. Read more on [China RoHS](/regulations/china-rohs-sj-t-11364) requirements, and see how [supplier compliance](/supplier-compliance) tracking can help you stay on top of documentation without hiring a specialist.

Complyra can help you keep this paperwork organized as your supplier list grows — feel free to take a look.