Verify catalogue scope, treatment activity, the facility-specific qualification certificate, monitoring controls, downstream handoffs, and change triggers before approving a China e-waste route.
Use before the first shipment and after any certificate, facility, category, equipment, capacity, ownership, or operating change.
Structured answer sets in this page tree.
Cited legal and guidance references.
Before sending a catalogued waste product for treatment, verify the treatment enterprise's qualification certificate against the enterprise, facility, product category, equipment, operating parameters, capacity, and validity period. First confirm that the discarded model falls within the national Treatment Catalogue and that the planned activity is treatment rather than collection, repair, or refurbishment. A recycler label, collection licence, invoice, or sustainability claim does not replace this check.
The State Council Regulation applies to discarded products within the national Waste Electrical and Electronic Product Treatment Catalogue. Treatment includes dismantling, extracting material for raw material or fuel, changing physical or chemical characteristics to reduce the waste or its hazardous constituents, and final placement in a compliant landfill. Repair, refurbishment, and resale after repair or refurbishment are excluded. Collection alone does not require the treatment qualification, but an unqualified collector must transfer covered waste to a qualified treatment enterprise.
China prohibits treatment without the required qualification and prohibits providing or entrusting catalogued waste to an unqualified person for treatment. The certificate records the legal-person name, representative and address, treatment-facility address, covered product categories, main facilities and equipment with operating parameters, treatment capacity, validity period, issue date, and certificate number.
The licensing measures also require suitable treatment and storage areas, equipment, pollution controls, a data-information system, environmental-management measures, emergency arrangements, and qualified safety, quality, and environmental personnel. If the operator cannot fully treat a waste or output, its application must include a proper reuse or disposal plan.
Read the certificate fields and compare them with the contract, shipment destination, forecast volume, and site that will perform treatment. The certificate review should identify a clear pass, a mismatch requiring correction, or an unresolved item that blocks the shipment.
A change to the legal-person name, legal representative, or registered address requires the operator to apply for a certificate change within 15 working days after the business-registration change. Added product categories, a new facility, reconstruction or expansion of an existing facility, or treatment exceeding certified capacity by more than 20% requires a new application under the original procedure.
The measures prescribe certificate content, operating controls, monitoring, and data reporting. They do not prescribe a customer due-diligence form. Keep a dated review record so the business can show which certificate and route it relied on. Record one of three outcomes: approved within scope, blocked because of a confirmed mismatch, or pending until the operator or authority resolves an evidence gap.
For each shipment, connect the discarded product category and quantity to the origin, destination facility, receiving enterprise, certificate, receipt, and treatment record. Mark commercial audit material as supporting evidence rather than an official permit.
This checklist verifies the treatment qualification. It does not establish China RoHS product compliance, a hazardous-waste licence, transport compliance, or eligibility for treatment-fund subsidies.
If dismantling produces hazardous waste or another regulated output, assess that downstream route under the applicable waste rules instead of assuming the e-waste treatment certificate covers every later activity.
Article 34 of the State Council Regulation separately allows a provincially approved centralized treatment site with the required pollution-control facilities, standards compliance, and planning alignment. An industrial-park address or shared pollution-control system does not by itself prove that approval.
Assign the certificate review, shipment controls, and retained evidence to named owners.
Research Copilot connects the official citation, decision, owner, retained evidence, and change history.
Check the China E-Waste Law scope decision and unresolved launch questions with Sorena.