--- title: "China e-waste treatment qualification workflow" canonical_url: "https://www.sorena.io/artifacts/apac/china-e-waste-law/disposal-qualification-license-workflow" source_url: "https://www.sorena.io/artifacts/apac/china-e-waste-law/disposal-qualification-license-workflow" author: "Sorena AI" description: "Decide whether a China e-waste treatment qualification is required, apply through the correct authority, and control certificate changes." published_at: "2026-07-05" updated_at: "2026-07-25" keywords: - "China e-waste" - "WEEE" - "Waste electrical and electronic products" - "Product compliance" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # China e-waste treatment qualification workflow Decide whether a China e-waste treatment qualification is required, apply through the correct authority, and control certificate changes. *Product* *China* ## China E-Waste Law E-waste treatment qualification workflow 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. Except for the narrow provincially approved centralized treatment site route in Article 34, a business must hold a waste electrical and electronic product treatment qualification before it treats products covered by the Waste Electrical and Electronic Product Treatment Catalogue. 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 treatment enterprise. ## Definitions ### Waste Electrical and Electronic Product Treatment Catalogue The national catalogue determines which discarded product categories fall within the State Council e-waste regulation and the treatment-qualification system. The 2014 edition, effective since 1 March 2016, lists 14 categories and gives product definitions and technical limits. **Why it matters here:** Match the exact model to the full catalogue entry before applying this workflow. An electrical or electronic function, recycler description, or former fund category does not by itself 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:** Collection, storage, transport, repair, and refurbishment do not by themselves require this treatment qualification. An actor that also dismantles or performs another listed treatment activity must follow the qualification route for 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) ### Waste electrical and electronic product treatment qualification **Term:** treatment qualification This administrative qualification authorizes the named enterprise to treat specified catalogue-listed products at the stated facility. The certificate defines the product categories, main facilities and equipment with operating parameters, treatment capacity, validity period, issue date, and certificate number. **Why it matters here:** The certificate is an operating boundary, not a general recycler credential. Treatment outside its terms and entrusting treatment to an unqualified person are prohibited. Sources: - [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Articles 6 and 22-24](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) ### Provincially approved centralized treatment site **Term:** centralized treatment site Article 34 allows a provincial people's government to approve a centralized treatment site. It must have complete centralized pollution-treatment facilities, meet national or local emission and solid-waste pollution-control technical standards, comply with the regulation, and align with industrial-zone, land-use, and urban-rural planning. **Why it matters here:** Article 22 expressly references this narrow exception to its general qualification prohibition. An ordinary industrial park, recycling cluster, or shared facility is not enough without provincial approval and the Article 34 conditions. Sources: - [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Articles 22 and 34](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) ### Enterprise legal person The licensing measures require the applicant to be a lawfully established enterprise with legal-person status and general value-added-tax taxpayer status. The applicant is the entity that will hold the certificate and operate the specified treatment facility. **Why it matters here:** Confirm that the applicant's registered identity matches the facility and the requested operation. A group affiliate's status or certificate does not transfer to another legal entity. Sources: - [Qualification Licensing Measures, Article 7](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) ### General value-added-tax taxpayer status Article 7 of the licensing measures includes general value-added-tax taxpayer status among the applicant eligibility conditions. It is a tax-registration status of the applicant enterprise, separate from the facility, equipment, environmental-management, emergency, and personnel conditions. **Why it matters here:** Include evidence of this status in the application file and verify the current local documentary route with the receiving authority. It does not replace any other Article 7 condition. Sources: - [Qualification Licensing Measures, Article 7](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) ### Reapplication through the original qualification procedure **Term:** fresh application The licensing measures require the enterprise to apply again through the original procedure when it adds a treatment category, builds a new treatment facility, alters or expands an existing facility, or treats more than 20% above the capacity stated on its certificate. **Why it matters here:** These operational changes are not handled as the 15-working-day administrative amendment used for a changed legal-person name, legal representative, or registered address. Do not begin the changed treatment operation under the old certificate. Sources: - [Qualification Licensing Measures, Articles 12-13](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) ### HJ 527-2026 pollution-control specification **Term:** HJ 527-2026 HJ 527-2026 is the current national ecological-environment standard for pollution control in waste electrical and electronic product treatment. It applies to storage, dismantling, and the use or disposal of treatment outputs and includes environmental-management requirements. It took effect on 1 March 2026 and replaced HJ 527-2010. **Why it matters here:** A qualification certificate does not prove compliance with HJ 527-2026. Verify the facility's actual storage, dismantling, output, pollution-control, and environmental-management practices separately. Sources: - [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) ### 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:** China RoHS declarations do not establish end-of-life catalogue scope, permission to treat, or treatment performance. Keep the product assessment separate from this qualification workflow. 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) ## 1. Confirm that the catalogue and treatment tests are met The Regulation applies to waste products listed in the Waste Electrical and Electronic Product Treatment Catalogue. 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. Treatment 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 treatment, or final disposal. - If the operator only collects covered waste, route it to an enterprise whose qualification covers the treatment; do not treat a collection registration or commercial recycling claim as a treatment qualification. - Check other applicable regimes separately. Waste outside this catalogue and hazardous waste generated by treatment can be subject to different environmental controls. Sources for this answer: - [Waste Electrical and Electronic Product Treatment Catalogue (2014 edition)](https://www.ndrc.gov.cn/xxgk/zcfb/gg/201502/t20150213_961116.html?ref=sorena.io) - 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](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - 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. ## 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 treatment facility is located. The applicant must be a lawfully established enterprise legal person with general value-added-tax taxpayer status, 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 treatment 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: treatment 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 treatment until the authority has issued the qualification certificate. Sources for this answer: - [Measures for Qualification Licensing for Waste Electrical and Electronic Product Treatment](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - 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](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - Articles 22-24 establish the qualification requirement, core eligibility conditions, application route, and 60-day decision period after complete materials are received. ## 3. Read the certificate as an operating boundary The certificate states the legal person and legal representative, registered address, treatment-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 treatment, 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 treatment-facility address. - Match every catalogue category in the shipment to a category on the certificate. - Confirm that the planned equipment, operating parameters, and treatment 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, treatment record, and downstream output or residual route together so the handoff can be reconstructed. - Escalate any mismatch or uncertainty before shipment or treatment; 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](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - 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. ## 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 treatment when the existing certificate no longer covers the operation. The treatment 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. - Fresh application under the original procedure: add a treatment 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 treatment 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 treatment, 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](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - 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](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - 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. ## 5. Keep the qualification decision separate from technical compliance The qualification confirms permission to conduct specified treatment 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. HJ 527-2026 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 treatment 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 China RoHS declarations as evidence of end-of-life treatment qualification or performance. - Do not use a collection invoice, sustainability statement, or certificate copy alone as proof that a particular batch received qualified treatment. - Keep the product-scope decision, activity classification, certificate check, contract, handoff evidence, treatment record, and change review as separate but linked records. Related resources: - [China e-waste covered-products and recovery-scope guide](/artifacts/apac/china-e-waste-law/covered-products-and-recovery-scope.md): Apply the catalogue and activity tests before starting this qualification workflow. - [China e-waste recycler contract and records template](/artifacts/apac/china-e-waste-law/e-waste-recycler-contract-and-records-template.md): Translate the qualification boundary into contract fields, shipment records, change notices, and customer evidence. Sources for this answer: - [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) - 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* *Placement: Before primary sources* ## 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. - [Map official sources to evidence](/solutions/research-copilot.md): Keep the application conditions, public-notice record, inspection, certificate fields, and amendment or reapplication trigger together. - [Review the China route](/contact.md): Check the China E-Waste Law scope decision and unresolved launch questions with Sorena. ## Primary sources - [Measures for Qualification Licensing for Waste Electrical and Electronic Product Treatment](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - Binding administrative measures for qualification scope, applicant conditions, procedure, certificate contents, changes, cancellation, supervision, and penalties; effective since 1 January 2011. - [Regulation on the Administration of the Recovery and Treatment of Waste Electrical and Electronic Products](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - Binding State Council regulation for catalogue scope, treatment definition, actor duties, qualification, monitoring, data records, supervision, and penalties; effective since 1 January 2011 and revised in 2019. - [Waste Electrical and Electronic Product Treatment Catalogue (2014 edition)](https://www.ndrc.gov.cn/xxgk/zcfb/gg/201502/t20150213_961116.html?ref=sorena.io) - Official catalogue defining the 14 covered product classes and their scope; effective since 1 March 2016. - [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 storage, dismantling, and treatment outputs; effective since 1 March 2026. ## Related Topic Guides - [China e-waste compliance checklist](/artifacts/apac/china-e-waste-law/checklist.md): Checklist for covered product scope, qualified disposal partner review, disposal records, and downstream evidence. - [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. - [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. --- [Privacy Policy](https://www.sorena.io/privacy.md) | [Terms of Use](https://www.sorena.io/terms-of-use.md) | [DMCA](https://www.sorena.io/dmca.md) | [About Us](https://www.sorena.io/about-us.md) (c) 2026 Sorena AB (559573-7338). 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