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China has added electronic smart locks to its national list of products that must comply with strict limits on hazardous substances, marking the first time the fast-growing smart home device has been drawn into the country's RoHS-style regulatory net.

The move is part of the most significant overhaul of China's restriction of hazardous substances regime in nearly a decade, announced on 28 May 2026 by the Ministry of Industry and Information Technology (MIIT) alongside seven other central government bodies, including the National Development and Reform Commission, the Ministry of Finance, and the Ministry of Ecology and Environment.

A newly published Compliance Management Catalogue for the Restriction of Hazardous Substances in Electrical and Electronic Products (2026 edition) expands the number of regulated product categories from 12 to 33. Among the 23 additions is the electronic smart lock, a device officials say has become a ubiquitous consumer product with rapid technology turnover and high user contact frequency.

The original dozen categories — which have included televisions, refrigerators, washing machines, microcomputers and mobile phones since 2018 — have been consolidated into 10, with printers, copiers and fax machines merged into a single category. All legacy items are subject to the new rules with immediate effect. The newly added products, including smart locks, will be given a transitional period and must comply from 1 August 2027, aligning with the enforcement date of the updated mandatory national standard GB 26572—2025.

Under the catalogue, every homogeneous material within a covered product must not exceed the threshold concentrations set for ten internationally recognised high-risk substances: lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBBs), polybrominated diphenyl ethers (PBDEs), and four phthalates — DBP, DIBP, BBP and DEHP. Exemptions listed in a companion Exceptions List remain applicable.

Manufacturers of products on the list will be required to place their goods under China’s conformity assessment system for hazardous substance restrictions. They must upload results — either through voluntary product certification or a supplier’s declaration of conformity — to the public service platform chinarohs.miit.gov.cn for public scrutiny.

The Ministry said the new additions fall into three broad groups: everyday household and workplace items such as microwave ovens, rice cookers and portable power banks; rapidly evolving consumer electronics including smart wristbands, headphones, robotic vacuum cleaners and electronic smart locks; and products with heightened health and safety sensitivity such as electric toys, reading lamps, blood pressure monitors and hearing aids.

"Smart locks belong to the second group — products that are emerging and quickly refreshed along with the rapid development of information technology," one industry analyst noted, adding that the categorisation reflects regulators' assessment that smart locks have fast innovation cycles, rapidly rising market penetration and high consumer exposure.

The smart lock sector has grown explosively. According to data from RUNTO, nationwide sales reached 17.81 million units in 2025, with production and sales projected to hit 24 million units in 2026, a year-on-year increase of 6.7%. The device has moved beyond the early-adopter phase into mainstream mass consumption.

But alongside growth has come regulatory concern. Qu Zongfeng, vice-president of the China Household Electrical Appliances Research Institute, warned that hazardous substances in structural components, circuit boards and battery assemblies — including lead, cadmium and phthalates — can enter soil and water at the end of a product's life through dismantling, landfilling or improper recycling, accumulating in ecosystems and magnifying through the food chain with long-term damage to human health.

The MIIT's energy conservation department said the extended compliance timeline is designed to achieve a "smooth transition and effective continuity". Even before the 2027 deadline, all electrical and electronic products — whether or not they are on the catalogue — remain obliged to label hazardous substance content and correctly apply related marks under the overarching restriction measures.

Industry voices see the regulation as more than an environmental red line. Yu Xiuming, vice-president of the China Electronics Standardization Institute, urged companies to embed the mandatory standard into supplier qualification, procurement contracts and incoming inspection from the outset, build a product compliance list, carry out standardised testing, and strictly apply exemption provisions where appropriate.

Wei Ran, chief engineer at the China Academy of Information and Communications Technology, said bringing smart wristbands, robot vacuums and electronic smart locks into the regime would accelerate the substitution and reduction of hazardous substances in material selection, structural design and manufacturing, lowering environmental and health risks across the full product lifecycle.

The expansion is expected to reshape supply chains, forcing upstream material suppliers to upgrade and accelerating the phase-out of outdated capacity. Analysts say it will push the smart lock industry away from a race-to-the-bottom on price and toward competition based on value and sustainability.