---
title: "China e-waste compliance checklist"
canonical_url: "https://www.sorena.io/artifacts/apac/china-e-waste-law/checklist"
source_url: "https://www.sorena.io/artifacts/apac/china-e-waste-law/checklist"
author: "Sorena AI"
description: "Checklist for covered product scope, qualified disposal partner review, disposal records, and downstream evidence."
published_at: "2026-07-05"
updated_at: "2026-07-25"
keywords:
  - "China e-waste"
  - "WEEE"
  - "Waste electrical and electronic products"
  - "Product compliance"
---
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---

# China e-waste compliance checklist

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

*Product* *China*

## China E-Waste Law e-waste compliance checklist

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

Use this checklist to apply the treatment catalogue, decide whether the planned activity is regulated treatment, 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.

## Definitions

### Waste Electrical and Electronic Product Treatment Catalogue

**Term:** treatment catalogue

The national treatment catalogue determines which discarded product categories fall within the State Council e-waste regulation. The 2014 edition, effective since 1 March 2016, lists 14 categories and gives product definitions and technical limits for scope.

**Why it matters here:** Record the full catalogue entry, the model facts, and every applicable limit. A general description such as appliance, electronics, or recycler inventory does not establish catalogue coverage.

Sources:

- [Waste Electrical and Electronic Product Treatment Catalogue (2014 Edition)](https://www.ndrc.gov.cn/xxgk/zcfb/gg/201502/W020190905485475610247.pdf?ref=sorena.io)
- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Article 3](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io)

### Treatment under the e-waste regulation

**Term:** treatment

Treatment means dismantling; extracting substances for raw material or fuel; changing physical or chemical characteristics to reduce waste quantity or hazardous constituents; or final placement in an environmentally compliant landfill. Repair, refurbishment, and reuse as second-hand goods after repair or refurbishment are excluded.

**Why it matters here:** Classify the actual activity before checking the qualification. A collector, repairer, or logistics provider can also perform treatment and then carries the duties attached to that activity.

Sources:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Article 2](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io)

### Electrical and electronic product producer

**Term:** producer

The producer is the actor assigned product design, material, pollution-control information, and encouraged collection duties for products made in China. Producer collection is encouraged rather than stated as a general mandatory take-back duty.

**Why it matters here:** Assign the product-facing checklist items to the actual producer legal entity. Treatment-fund collection stopped on 1 January 2024, so fund payment is not a current checklist item for later periods.

Sources:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Articles 10-11](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io)
- [Announcement on cessation of the Waste Electrical and Electronic Product Treatment Fund](https://szs.mof.gov.cn/zt/mlqd_8464/zcgd/202401/t20240118_3926323.htm?ref=sorena.io)

### Import consignee or its agent

For imported electrical and electronic products, the regulation names the consignee or its agent alongside domestic producers for design, material, pollution-control, and product-information duties. The entity must be identified from the actual import transaction.

**Why it matters here:** Do not assign the importer checklist from a foreign manufacturer, brand, or seller name alone. Keep import duties separate from collector and treatment-enterprise duties.

Sources:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Article 10](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io)

### Waste electrical and electronic product collector

**Term:** collector

A collector provides users with convenient collection services. If it performs regulated treatment, it needs the treatment qualification; if it does not hold that qualification, it must transfer collected covered waste to a qualified treatment enterprise.

**Why it matters here:** Verify what the contractor actually does after collection. A collection invoice or recycler label does not show whether covered waste reached qualified treatment.

Sources:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Article 12](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io)

### Qualified treatment enterprise

**Term:** treatment enterprise

A treatment enterprise is an enterprise authorized to treat catalogue-listed waste electrical and electronic products. Its certificate identifies the legal person, treatment facility, categories, main equipment and operating parameters, capacity, validity period, issue date, and certificate number.

**Why it matters here:** Match the destination and planned activity to every relevant certificate field. A certificate for another site or group entity and an expired or out-of-scope certificate do not cover the shipment.

Sources:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Articles 11-12 and 22](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io)
- [Qualification Licensing Measures, Articles 11 and 16](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io)

### Treatment data-information management system

**Term:** data-information system

A treatment enterprise must maintain a system for its basic treatment data and related information, report the required information to the local city-level ecology and environment authority, make required information public under the licensing measures, and retain basic treatment data for at least three years.

**Why it matters here:** This statutory operator system is distinct from a customer's contract or shipment file. Check which operator reports and records exist and which evidence the contracting party can obtain.

Sources:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Article 17](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io)
- [Qualification Licensing Measures, Article 20](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io)

### China RoHS hazardous-substance regime

**Term:** China RoHS

China RoHS is the product-facing regime under the Measures for the Administration of the Restricted Use of Hazardous Substances in Electrical and Electronic Products. It addresses hazardous-substance restriction, marking and disclosure, environmental protection use periods, and conformity assessment for products in the applicable compliance-management catalogue.

**Why it matters here:** A China RoHS file does not prove e-waste catalogue scope, treatment qualification, or qualified downstream treatment. Record a separate conclusion and owner for each regime.

Sources:

- [Measures for the Administration of the Restricted Use of Hazardous Substances in Electrical and Electronic Products](https://www.miit.gov.cn/jgsj/zfs/gzdt/art/2020/art_26714a290ac8407fb6df9eb816c2596f.html?ref=sorena.io)

## What this guide helps you decide

Follow the legal sequence: treatment catalogue coverage, activity classification, actor role, qualified treatment 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 producer's product-information duties differ from a collector's transfer duty and a treatment enterprise'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 producer, import consignee or agent, seller, repairer, after-sales provider, collector, institutional holder, and treatment enterprise.
- Procurement or logistics owner - condition: covered treatment 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.

Sources for this answer:

- [Waste Electrical and Electronic Product Treatment Catalogue (2014 Edition)](https://www.ndrc.gov.cn/xxgk/zcfb/gg/201502/W020190905485475610247.pdf?ref=sorena.io) - Defines the 14 product categories and the product-specific capacity, output, format, speed, tuner, and network boundaries used in the scope check.
- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - Articles 2-3 and 10-19 support the scope, treatment definition, actor duties, qualified-treatment route, monitoring, reporting, and retention checks.
- [Qualification Licensing Measures for Waste Electrical and Electronic Product Disposal](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - Articles 7, 11-16, and 19-20 support operator eligibility, certificate checks, change controls, monitoring, and data-system checks.

## Checklist steps that should produce evidence

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

For an in-scope producer or an import consignee or its agent, confirm the applicable product design, material, and information duties. The former treatment-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 treatment 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: treatment enterprise 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: treatment enterprise. Maintain the annual monitoring plan, routine emissions monitoring, data-information system, required reports and public disclosure, basic treatment 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 treatment 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 treatment 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 treatment enterprise. 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.

Sources for this answer:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - 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.
- [Qualification Licensing Measures for Waste Electrical and Electronic Product Disposal](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - Articles 11-13, 16, and 19-20 define certificate content, reapplication triggers, unqualified-treatment prohibitions, monitoring reports, and data disclosure.
- [Announcement on cessation of the Waste Electrical and Electronic Product Treatment Fund](https://szs.mof.gov.cn/zt/mlqd_8464/zcgd/202401/t20240118_3926323.htm?ref=sorena.io) - Stopped treatment-fund collection on 1 January 2024 and ended the former subsidy for products treated from that date.
- [HJ 527-2026 Technical specification for pollution control of waste electrical and electronic equipment treatment](https://www.mee.gov.cn/ywgz/fgbz/bz/bzwb/gthw/gtfwwrkzbz/202602/t20260204_1143642.shtml?ref=sorena.io) - Current pollution-control and environmental-management specification for treatment operations, effective since 1 March 2026.

## Evidence to keep before launch or change approval

Separate legally required operator records from practical due-diligence evidence. The regulation requires the treatment enterprise's data-information system, reporting, and at least three years of basic treatment 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 treatment enterprise and state in the contract which evidence the customer can obtain.

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

Sources for this answer:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - Articles 12, 16, and 17 support qualified transfer, routine monitoring, data reporting, and retention of basic treatment data for at least three years.
- [Qualification Licensing Measures for Waste Electrical and Electronic Product Disposal](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - Articles 18-20 support inspection records, monitoring-report retention for at least three years, and treatment-data reporting and publication.

## Boundary with nearby China regimes

Do not use a China RoHS file as proof of catalogue scope or qualified treatment. 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 treatment, or calling dismantling repair to avoid the qualification check.
- Accepting a recycler label, collection invoice, or sustainability claim instead of verifying the treatment certificate and destination.

Sources for this answer:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - Articles 2-3 and 10-12 distinguish catalogue scope, treatment, repair and reuse, product information, collection, and qualified treatment.

*Put the requirement into practice*

*Placement: Before primary sources*

## Prepare the qualified disposal evidence file

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

- [Map official sources to evidence](/solutions/research-copilot.md): Keep each checklist result with the model facts, actor, certificate field, shipment evidence, operator record, and review trigger.
- [Review the China route](/contact.md): Check the China E-Waste Law scope decision and unresolved launch questions with Sorena.

## Primary sources

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - 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.
- [Qualification Licensing Measures for Waste Electrical and Electronic Product Disposal](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - Sets treatment-operator eligibility, certificate, change, supervision, monitoring, data, and enforcement requirements.
- [Waste Electrical and Electronic Product Treatment Catalogue (2014 Edition)](https://www.ndrc.gov.cn/xxgk/zcfb/gg/201502/W020190905485475610247.pdf?ref=sorena.io) - Lists the 14 product categories and their definitions and limits for the first scope check.
- [Announcement on cessation of the Waste Electrical and Electronic Product Treatment Fund](https://szs.mof.gov.cn/zt/mlqd_8464/zcgd/202401/t20240118_3926323.htm?ref=sorena.io) - Current source for the 1 January 2024 end of treatment-fund collection.
- [HJ 527-2026 Technical specification for pollution control of waste electrical and electronic equipment treatment](https://www.mee.gov.cn/ywgz/fgbz/bz/bzwb/gthw/gtfwwrkzbz/202602/t20260204_1143642.shtml?ref=sorena.io) - Current treatment pollution-control standard, effective since 1 March 2026.

## Related Topic Guides

- [China e-waste deadlines and compliance calendar](/artifacts/apac/china-e-waste-law/deadlines-and-compliance-calendar.md): China e-waste treatment permit deadlines, change triggers, monitoring dates, record-retention periods, and historical milestones.
- [China E-Waste Law FAQ](/artifacts/apac/china-e-waste-law/faq.md): China e-waste FAQ covering treatment-catalogue scope, actor duties, qualified treatment, operator records, and the boundary with China RoHS.
- [China e-waste penalties and enforcement exposure](/artifacts/apac/china-e-waste-law/penalties-and-fines.md): China e-waste fines and permit consequences by actor, violation, enforcement authority, and required correction.
- [China e-waste recovery and disposal requirements](/artifacts/apac/china-e-waste-law/requirements.md): China e-waste requirements for product lifecycle roles, qualified treatment, downstream evidence, and operator records.
- [China e-waste treatment qualification workflow](/artifacts/apac/china-e-waste-law/disposal-qualification-license-workflow.md): Decide whether a China e-waste treatment qualification is required, apply through the correct authority, and control certificate changes.
- [Covered products and e-waste recovery scope](/artifacts/apac/china-e-waste-law/covered-products-and-recovery-scope.md): How to document product family scope for China waste electrical and electronic product recovery and disposal without guessing catalogue coverage.
- [E-waste disposal operator qualification checklist](/artifacts/apac/china-e-waste-law/e-waste-disposal-operator-qualification-checklist.md): Verify China e-waste catalogue scope, treatment activity, facility-specific qualification, capacity, monitoring, downstream handoffs, and change triggers.
- [E-waste recycler contract and records template](/artifacts/apac/china-e-waste-law/e-waste-recycler-contract-and-records-template.md): Contract schedule and records register for checking China e-waste treatment qualifications, handoffs, treatment data, and changes.
- [How is China e-waste different from China RoHS?](/artifacts/apac/china-e-waste-law/faq/how-is-china-e-waste-different-from-china-rohs.md): China e-waste rules govern catalogued products at end of life. China RoHS governs hazardous-substance controls, marking, disclosure, and catalogue-based conformity assessment.
- [Producer and disposal operator duties](/artifacts/apac/china-e-waste-law/producer-and-disposal-operator-duties.md): How producers, sellers, recyclers, and disposal operators should separate e-waste responsibilities and records.
- [What records should a producer keep for e-waste recovery and disposal?](/artifacts/apac/china-e-waste-law/faq/what-records-should-a-producer-keep-for-e-waste-recovery-and-disposal.md): Separate the producer's own China e-waste evidence from records that the qualified treatment enterprise must keep for at least three years.
- [When does a disposal operator need a waste electrical product qualification permit?](/artifacts/apac/china-e-waste-law/faq/when-does-a-disposal-operator-need-a-waste-electrical-product-qualification-permit.md): An enterprise needs a treatment qualification before treating products in China's e-waste Treatment Catalogue, subject to the Regulation's narrow centralized-site provision.


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