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China E-Waste Law E-waste treatment qualification workflow

Decide whether a China e-waste treatment qualification is required, apply through the correct authority, and control certificate changes.

Use this workflow before a business treats catalogue-listed waste electrical and electronic products in China or sends them to a treatment operator. It separates treatment from collection and repair, maps the application, and shows when a certificate must be changed, replaced, or cancelled.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Jul 25, 2026
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5

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4

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Sorena AI
Published Jul 5, 2026
Updated Jul 25, 2026
Overview

Except for the narrow provincially approved route in Article 34, a business must hold a waste electrical and electronic product before it treats products covered by the . First classify the product and activity. Then confirm that the legal person, facility, product category, equipment, operating parameters, capacity, and validity shown on the certificate cover the planned work. A collector that does not treat the waste does not need this treatment qualification for collection alone, but it must send the waste to a qualified enterprise.

Section 1

1. Confirm that the catalogue and treatment tests are met

The Regulation applies to waste products listed in the . The 2014 catalogue, effective since 1 March 2016, contains 14 classes: 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. Apply the catalogue's product definitions and limits; a familiar product name alone does not settle coverage.

includes 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; and final placement in a landfill that meets environmental requirements. Repair, refurbishment, and resale as second-hand goods after repair or refurbishment are excluded from that definition. A business that both collects and treats waste still needs the qualification for its treatment activity.

  • Record the catalogue class, full definition, technical limit, and product facts used in the scope decision. Representative limits include refrigerator volume <=800 litres, room-air-conditioner cooling output <=14,000 W, washing capacity <=10 kg, and printer or copier format smaller than A2 at <=80 pages per minute.
  • Describe each planned activity separately: collection, storage, transport, repair, refurbishment, dismantling, material or fuel extraction, physical or chemical , or final disposal.
  • If the operator only collects covered waste, route it to an enterprise whose qualification covers the ; do not treat a collection registration or commercial recycling claim as a .
  • Check other applicable regimes separately. Waste outside this catalogue and hazardous waste generated by can be subject to different environmental controls.
Sources for this answer
Waste Electrical and Electronic Product Treatment Catalogue (2014 edition)
The announcement made the 2014 catalogue effective on 1 March 2016 and links the catalogue defining the 14 covered product classes, scope, and technical limits.
Regulation on the Administration of the Recovery and Treatment of Waste Electrical and Electronic Products
Articles 2, 3, 11, and 12 define treatment, limit the Regulation to catalogue products, exclude repair and refurbishment from treatment, and require collected covered waste to reach a qualified treatment enterprise.
Section 2

2. Prepare and submit the application

The applicant submits a written application and supporting evidence to the ecology and environment authority for the city divided into districts where the facility is located. The applicant must be a lawfully established with , fit the regional treatment development plan, and meet the facility, equipment, management, emergency, and personnel conditions in Article 7 of the Licensing Measures.

Within three working days after accepting the application, the authority must publicize the relevant information. The public-comment period must last at least ten working days. The authority verifies comments, reviews the documents, performs an on-site inspection, and decides within 60 days after acceptance. If it refuses the application, it must give written reasons.

  • Corporate and planning file: legal establishment, legal-person and tax status, business registration, and consistency with the regional development plan. The licensing measures require the regional plan to be revised every five years, so record the plan version used for the application.
  • Site and system file: workshop and site, storage areas, dismantling and treatment equipment, pollution-control facilities, and the supporting data-information management system.
  • Handling file: sorting and packaging equipment, vehicles, handling and baling equipment, dedicated containers, central monitoring, metering, and emergency-response equipment suited to the requested capacity and categories.
  • Management file: environmental management system, a route for products or outputs the facility cannot fully treat, environmental-incident prevention measures, emergency plan, and qualified safety, quality, and environmental personnel.
  • Procedure file: submission receipt, evidence that materials were complete, acceptance date, public notice issued within three working days after acceptance, at least ten working days for comment, comments and authority verification, on-site inspection record, and the decision made within 60 days after acceptance.
  • Do not begin until the authority has issued the qualification certificate.
Sources for this answer
Measures for Qualification Licensing for Waste Electrical and Electronic Product Treatment
Articles 3 and 7-10 set the five-year regional-plan cycle, applicant conditions, application authority, public-notice period, document and on-site review, 60-day decision period, and written refusal requirement.
Regulation on the Administration of the Recovery and Treatment of Waste Electrical and Electronic Products
Articles 22-24 establish the qualification requirement, core eligibility conditions, application route, and 60-day decision period after complete materials are received.
Section 3

3. Read the certificate as an operating boundary

The certificate states the legal person and legal representative, registered address, -facility address, covered product categories, main facilities and equipment with operating parameters, treatment capacity, validity period, issue date, and certificate number. Compare every planned waste stream and facility operation with those fields. The measures require a validity period to appear on the certificate but do not state one universal duration in these provisions, so read the date on the actual certificate. The company name or a generic description such as 'licensed recycler' is not enough.

Before sending waste to another enterprise for , obtain the certificate details and check the issuing authority's announcement or confirmation where available. The Licensing Measures prohibit providing or entrusting covered waste to an unqualified unit or individual for treatment.

  • Match the exact legal person and -facility address.
  • Match every catalogue category in the shipment to a category on the certificate.
  • Confirm that the planned equipment, operating parameters, and volume stay within the certificate.
  • Record the certificate number, validity period, issuing authority, verification date, verifier, and supporting copy or authority record.
  • Keep the contract, shipment or batch record, receiving confirmation, record, and downstream output or residual route together so the handoff can be reconstructed.
  • Escalate any mismatch or uncertainty before shipment or ; do not infer permission from a related certificate or another facility in the same corporate group.
Sources for this answer
Measures for Qualification Licensing for Waste Electrical and Electronic Product Treatment
Articles 11 and 16 specify the certificate contents and prohibit treatment without a certificate, treatment outside its terms, and entrusting treatment to an unqualified party.
Section 4

4. Route changes to amendment, reapplication, or cancellation

Recheck the certificate after each relevant change. Route the change according to the Licensing Measures and stop affected when the existing certificate no longer covers the operation.

The enterprise must also maintain its regulatory operating records. It must operate a data-information management system, report basic treatment data and related information to the local city-level authority, and retain basic treatment data for at least three years. It must conduct routine environmental monitoring under an annual plan and retain monitoring reports for at least three years.

  • Amendment: apply to the original issuing authority within 15 working days after the business-registration change when the legal-person name, legal representative, or registered address changes.
  • under the original procedure: add a category, build a new treatment facility, alter or expand an existing facility, or process more than 20% above the capacity stated on the certificate.
  • Replacement after a regional-plan revision: regional development plans are revised every five years. After a revision, the original issuing authority reviews enterprises that intend to continue and replaces certificates for those that still qualify.
  • Cancellation: before ending , control pollution at the site and properly handle untreated waste; apply for cancellation within 20 days after taking those measures. The authority cancels the qualification after a satisfactory on-site inspection. The enterprise must also investigate and assess environmental risk at the site and carry out remediation when the assessment shows it is required.
  • Customer review: refresh the certificate and records check when the operator, facility, category, equipment, capacity, route, certificate status, regional plan, or contract changes. Separate the operator's routine monitoring from the authority's supervisory monitoring, which the licensing measures require at least once every six months.
Sources for this answer
Measures for Qualification Licensing for Waste Electrical and Electronic Product Treatment
Articles 12-15 govern amendments, fresh applications, replacement after plan revision, and cancellation; Articles 19-20 distinguish operator monitoring from at-least-half-yearly supervisory monitoring and require monitoring-report retention and treatment-data management.
Regulation on the Administration of the Recovery and Treatment of Waste Electrical and Electronic Products
Articles 16-17 require routine environmental monitoring, a treatment data-information management system, reporting to the local city-level authority, and retention of basic treatment data for at least three years.
Section 5

5. Keep the qualification decision separate from technical compliance

The qualification confirms permission to conduct specified at a specified facility. It does not by itself show that each shipment was received and treated correctly, that outputs and residuals followed an appropriate route, or that the facility met every pollution-control duty.

has applied since 1 March 2026 and replaced HJ 527-2010. It sets pollution-control and environmental-management requirements for storage, dismantling, and the use or disposal of outputs. Check that standard and any other waste, hazardous-waste, transport, occupational-safety, planning, and local requirements that apply to the actual operation.

  • Do not use declarations as evidence of end-of-life or performance.
  • Do not use a collection invoice, sustainability statement, or certificate copy alone as proof that a particular batch received qualified .
  • Keep the product-scope decision, activity classification, certificate check, contract, handoff evidence, record, and change review as separate but linked records.
Sources for this answer
HJ 527-2026 Technical specification for pollution control of waste electrical and electronic equipment treatment
The Ministry page states that HJ 527-2026 took effect on 1 March 2026, replaced HJ 527-2010, and covers storage, dismantling, treatment-output use or disposal, pollution control, and environmental management.
Apply the requirement

Prepare the treatment qualification evidence file

Sorena AI helps assign the China treatment-qualification decision, application evidence, certificate checks, and change controls to named owners.

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Map official sources to evidence

Keep the application conditions, public-notice record, inspection, certificate fields, and amendment or reapplication trigger together.

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

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