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China E-Waste Law e-waste compliance checklist

Checklist for covered product scope, qualified disposal partner review, disposal records, and downstream evidence.

Use before collection or begins. Each completed item should name the responsible actor, the evidence reviewed, the result, any exception, and the trigger for reassessment.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Oct 15, 2026
4 sections6 primary sources
Overview

Use this checklist to apply the , decide whether the planned activity is regulated , assign each duty to the actor that performs it, verify the qualified destination, and retain the required operator records. Mark an item not applicable only with the catalogue entry, product or activity facts, and reason supporting that result.

Section 1

What this guide helps you decide

Follow the legal sequence: coverage, activity classification, actor role, qualified route, required records, and change review. A product name, recycler label, or collection invoice cannot answer all six checks. Record a pass, fail, or not-applicable result for each step and identify who approved it.

Assign each item to the China entity or contractor that performs the role. A 's product-information duties differ from a 's transfer duty and a 's qualification, monitoring, reporting, and retention duties. Fund payment belongs only in a historical check for periods before 1 January 2024.

  • Scope owner - condition: the discarded model matches the full 2014 catalogue entry and every limit. Evidence: catalogue entry, model identifier, specification, and dated conclusion. Examples include refrigerator volume <=800 litres and printer or copier format smaller than A2 at <=80 pages per minute.
  • Operations owner - condition: every unit or batch has an activity outcome. Evidence: route map distinguishing collection, storage, transport, repair, refurbishment, second-hand resale, dismantling, material or fuel extraction, hazard reduction, and final disposal.
  • Legal or compliance owner - condition: every China entity and contractor has the roles it actually performs. Evidence: role matrix covering , import consignee or agent, seller, repairer, after-sales provider, , institutional holder, and .
  • Procurement or logistics owner - condition: covered has a qualified destination before the first shipment. Evidence: dated certificate verification, contract, facility address, accepted categories, and handoff controls.
  • Control owner - condition: reassessment triggers are active. Evidence: change log covering catalogue, model specification, activity, legal entity, contractor, facility, certificate, category, equipment, capacity, and downstream route changes.
Section 2

Checklist steps that should produce evidence

Complete the scope and role record before contracting for or sending waste. Verify that the destination certificate covers the legal person, facility, product category, equipment, operating parameters, capacity, and validity period. A that performs no treatment does not need this treatment qualification for collection alone, but it must transfer covered waste to a qualified .

For an in-scope or an , confirm the applicable product design, material, and information duties. For producers, also verify compliance with the recovery-system and public-disclosure duty in force since 15 August 2026 under Environmental Code Article 978. The former -fund process applies only to periods before collection stopped on 1 January 2024. Sellers, repairers, and after-sales providers must display recovery and treatment information prominently at their business premises.

  • Scope check - owner: product or compliance team. Pass when the discarded model meets a complete catalogue definition and every applicable limit. If a specification is missing, hold the decision open and obtain it. If the model sits outside a boundary, record an outside-catalogue outcome and assess other waste, hazardous-waste, product, transport, import, and local rules. Keep the catalogue edition, entry, model evidence, result, and reviewer.
  • Activity check - owner: operations. Pass the repair route only for units actually repaired or refurbished for reuse; repaired goods sold onward must meet applicable mandatory health and safety requirements and carry a conspicuous second-hand mark. Dismantled or otherwise treated units follow the route.
  • Role check - owner: legal or compliance. Record every actor's legal entity, role, activity, transfer point, and duty. For an institutional holder, include asset-write-off procedures and any state-secrecy handling.
  • Destination check - owner: procurement or logistics. Before the first shipment, match the certificate identity, site, categories, equipment, operating parameters, capacity, and validity. Keep the certificate copy or authority record, verification date, verifier, contract, and approved destination.
  • Change check - owner: and contract owner. Amend a changed legal-person name, legal representative, or registered address within 15 working days after business registration changes. Reapply before adding a category, building a facility, altering or expanding a facility, or treating more than 20% above certified capacity.
  • Operator-record check - owner: . Maintain the annual monitoring plan, routine emissions monitoring, , required reports and public disclosure, basic data and monitoring reports for at least three years, and HJ 527-2026 controls for storage, dismantling, outputs, pollution control, and environmental management.
  • Exception check - owner: legal or compliance. Treat Article 34 only as a narrow route for a provincially approved centralized site meeting its pollution-control and planning conditions; do not infer an exception from an industrial-park address or shared facility.
  • Failure check - owner: legal or compliance. Stop the affected and do not ship covered waste to a proposed treatment destination whose qualification or certificate scope fails the check. A collection-only transfer can follow a separate controlled route to a qualified . Unqualified treatment can lead to shutdown or closure, confiscation of illegal proceeds, and a CNY 50,000-500,000 fine; missing data systems, reports, retention, or routine monitoring can lead to correction orders and fines up to CNY 50,000.
Section 3

Evidence to keep before launch or change approval

Separate legally required operator records from practical due-diligence evidence. The regulation requires the 's , reporting, and at least three years of basic data. The licensing measure also requires monitoring reports to be retained for at least three years.

Scope notes, contracts, certificate copies, handoff records, and review logs are practical ways to demonstrate the route, but these two instruments do not prescribe a single customer checklist or handoff form. Keep the statutory operator record with the and state in the contract which evidence the customer can obtain.

  • Catalogue and model scope note.
  • Activity classification and actor-role matrix.
  • qualification certificate and dated verification record.
  • Contract, shipment, receipt, destination, and quantity records.
  • Required data, reports, public disclosures, and monitoring reports for the .
  • Exceptions with their legal basis, approval, expiry or review condition, corrective actions, and change-review log.
Section 4

Boundary with nearby China regimes

Do not use a file as proof of catalogue scope or qualified . Product pollution-control duties, end-of-life treatment qualification, hazardous-waste controls, transport rules, and treatment-fund administration can require separate assessments.

Link shared model and material facts, but record a separate conclusion and owner for each regime.

  • Treating any electronic product as catalogued without checking the entry's definition and limits.
  • Treating repair or refurbishment as , or calling dismantling repair to avoid the qualification check.
  • Accepting a recycler label, collection invoice, or sustainability claim instead of verifying the certificate and destination.
Put the requirement into practice

Prepare the qualified disposal evidence file

Assign each checklist item to an owner and retain the evidence behind each scope, role, and treatment decision.

Research workflow
Map official sources to evidence

Keep each checklist result with the model facts, actor, certificate field, shipment evidence, operator record, and review trigger.

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Talk to Sorena
Review the China route

Check the China E-Waste Law scope decision and unresolved launch questions with Sorena.

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Primary sources

References and citations

Regulation on Recovery and Disposal of Waste Electrical and Electronic Products
mee.gov.cn5 citations
Referenced sections
  • Use for waste electrical/electronic product recovery and disposal scope, producer and disposal duties, qualified treatment, recordkeeping, penalties, 1 January 2011 effective date, and 2019 revision.
  • Articles 2-3 and 10-19 support the scope, treatment definition, actor duties, qualified-treatment route, monitoring, reporting, and retention checks.
  • Articles 10-17 set producer, importer, seller, repairer, collector, treatment-enterprise, monitoring, data-reporting, and three-year treatment-data duties; Articles 27-32 state the relevant information, unqualified-treatment, data, and monitoring consequences.
Show 2 more
  • Articles 12, 16, and 17 support qualified transfer, routine monitoring, data reporting, and retention of basic treatment data for at least three years.
  • Articles 2-3 and 10-12 distinguish catalogue scope, treatment, repair and reuse, product information, collection, and qualified treatment.
Qualification Licensing Measures for Waste Electrical and Electronic Product Disposal
mee.gov.cn4 citations
Referenced sections
  • Sets treatment-operator eligibility, certificate, change, supervision, monitoring, data, and enforcement requirements.
  • Articles 7, 11-16, and 19-20 support operator eligibility, certificate checks, change controls, monitoring, and data-system checks.
  • Articles 11-13, 16, and 19-20 define certificate content, reapplication triggers, unqualified-treatment prohibitions, monitoring reports, and data disclosure.
Show 1 more
  • Articles 18-20 support inspection records, monitoring-report retention for at least three years, and treatment-data reporting and publication.
Environmental Code of the People's Republic of China
mee.gov.cn2 citations
Referenced sections
  • Binding law adopted on 12 March 2026; Articles 978 and 1242 establish the producer recovery-system and public-disclosure duty from 15 August 2026.
  • Articles 978 and 1242 establish the producer recovery-system and public-disclosure duty from 15 August 2026.

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