China E-Waste Law Covered products and e-waste recovery scope
How to document product family scope for China waste electrical and electronic product recovery and disposal without guessing catalogue coverage.
Match the discarded model to the catalogue's category definition and every technical boundary, then classify each unit or batch as collection, repair, refurbishment, second-hand resale, or regulated treatment.
Start with the (2014 Edition), effective since 1 March 2016. It lists 14 categories, but each category has its own definition or limit. A product is not covered merely because it contains electrical or electronic parts.
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What this guide helps you decide
The regulation covers recovery, , and related activities for discarded products that fall within the catalogue. The 14 categories are refrigerators, room air conditioners, range hoods, washing machines, electric water heaters, gas water heaters, printers, copiers, fax machines, televisions, monitors, microcomputers, mobile communication handsets, and telephone sets. Catalogue examples and limits include refrigerators with volume <=800 litres; room air conditioners with cooling output <=14,000 W, measured at the outdoor unit for multi-split systems; washing appliances with dry-clothes capacity <=10 kg; electric water heaters with capacity <=500 litres; and gas water heaters with heat load <=70 kW. The gas-water-heater entry also shows why an electrical function is not the catalogue test: the official product entry controls.
means dismantling; extracting substances for use as raw material or fuel; changing physical or chemical characteristics to reduce the quantity of waste or its hazardous constituents; or final placement in a landfill that meets environmental requirements. Repair, refurbishment, and second-hand reuse after repair or refurbishment are expressly excluded from that definition.
Match the product family and model to the catalogue's full category definition and any technical limit; do not rely on the category name alone.
For printers and copiers, both boundaries apply: the print area must be smaller than A2 and speed must be <=80 pages per minute. A device at A2 does not meet the stated smaller-than-A2 boundary. Multifunction equipment follows the entry for its main function.
A television entry requires a television tuner; a monitor is an image-output device without that tuner. Record the tuner fact rather than classifying both products from screen technology or marketing name.
Microcomputers include desktops, all-in-one computers, portable computers, tablets, and handheld computers. The handset entry gives legacy network examples but uses cellular-network communication as the functional boundary; the telephone-set entry separately covers PSTN, IP, special-purpose, and other subscriber telephone equipment.
Record whether the planned activity is collection, storage, transport, repair, refurbishment, second-hand resale, dismantling, material recovery, hazard reduction, or final disposal.
If a repaired product will be sold, verify applicable mandatory health and safety requirements and mark it visibly as .
If a collector will itself perform , route it through the treatment-qualification analysis; an unqualified collector must deliver the waste to a qualified .
Record the exact catalogue edition and entry used, and reopen the decision when the catalogue, product specification, end-of-life route, or downstream operator changes.
Answer three questions separately: does the discarded product meet a catalogue entry, does the planned activity meet the legal definition of , and will the actor treat the waste or only collect and transfer it? A yes at one branch does not decide the others. The treatment catalogue also differs from the former fund-collection scope, which was published separately; do not use an old fund category as the catalogue decision.
The regulation encourages producers to collect waste themselves or through sellers, repairers, after-sales providers, or collectors. It does not state a general mandatory producer take-back duty. Once covered waste is collected, it must be treated by an enterprise holding the required qualification.
Input: model identity, technical specification, discarded status, catalogue edition, full product entry, and each applicable limit.
Covered outcome: the discarded model meets the complete catalogue entry. Continue to the activity and actor tests.
Outside-catalogue outcome: the model does not meet the entry or a required boundary. Record the reason and assess other waste, hazardous-waste, product, transport, import, and local rules; do not treat outside-catalogue status as a general waste-law exemption.
Discarded-product status and the planned physical activity.
outcome: the activity is dismantling, material or fuel extraction, physical or chemical hazard reduction, or compliant final landfill placement. Continue to the qualification test.
Excluded-from- outcome: the activity is repair, refurbishment, or second-hand reuse after repair or refurbishment. Keep the unit or batch evidence and apply the separate mandatory safety and conspicuous second-hand marking requirements when repaired goods are sold.
Owner and trigger for reviewing the conclusion, including catalogue revision, model or specification change, a different end-of-life activity, mixed-stream routing, contractor or facility change, and certificate change. A repaired unit that later moves to dismantling must be reclassified at that point.
The regulation expressly requires enterprises to report treatment data and retain the basic data for at least three years. The broader scope note, contract, handoff record, and certificate copy below are practical evidence, not prescribed forms in these two instruments.
Keep enough detail to show which models and quantities followed a repair, resale, collection, or qualified- route, especially where one return stream splits between reuse and treatment.
Scope note with model identifiers, product specifications, catalogue edition, entry, and conclusion.
Activity and actor-role decision, including any mixed repair and route.
-enterprise certificate check for the named facility, category, and capacity.
Contract, shipment, receipt, and destination records sufficient to trace each handoff.
For the , reported basic data and the records retained for at least three years.
Change log for catalogue, product specification, activity, facility, or operator changes.
The e-waste regulation requires producers and relevant importers to follow product pollution-control rules and provide required hazardous-substance and recovery information. Those product-facing duties do not decide whether discarded units fall within the catalogue or whether a is qualified.
Keep the product assessment and the end-of-life catalogue and assessment as separate conclusions, even when they use the same model and material data.
Treating RoHS material declarations as proof of end-of-life disposal compliance.
Using an unverified recycler or disposal vendor without checking the qualification permit path.
Treating a sustainability claim or collection invoice as proof that qualified downstream occurred.