China E-Waste Law E-waste disposal operator qualification checklist
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.
Before sending a catalogued waste product for treatment, verify the '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 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.
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Section 1
What this guide helps you decide
The State Council Regulation applies to discarded products within the national Waste Electrical and Electronic Product . 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 , but an unqualified collector must transfer covered waste to a qualified .
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.
Confirm that the discarded model is within a treatment-catalogue category and that the planned work is treatment, not only collection, transport, repair, or refurbishment.
Obtain the certificate from the legal person that operates the destination treatment facility.
Match the planned product category, facility, equipment, operating parameters, and volume to the certificate.
Check the certificate's validity period, issuing authority, issue date, and number; record how and when the copy was verified.
Trace any subcontracted or onward treatment step because the operator may not entrust treatment to an unqualified party.
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.
Legal-person name, representative, registered address, and treatment-facility address match current records.
Covered product categories and treatment capacity cover the planned waste stream and forecast volume.
Main facilities, equipment, operating parameters, pollution controls, storage areas, and data systems match the certificate, application conditions, and actual site.
The operator has an annual monitoring plan, performs routine emissions monitoring, and retains monitoring reports for at least three years as the licensing measure requires.
The operator does not onward-entrust treatment to an unqualified party.
The contract requires notice of certificate amendment, reapplication, replacement, suspension, withdrawal, or termination before affected waste is accepted or treated.
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.
Product and activity scope decision.
Certificate copy and dated verification record.
Contract and approved destination facility.
Shipment, receipt, quantity, and treatment records.
Current monitoring plan and monitoring reports retained for at least three years.
Operator notices, regulator records made available to the business, and corrective-action evidence.
This checklist verifies the . 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.
Accepting a corporate-group certificate when another legal person or facility performs the treatment.
Checking the category but not the certified facility, equipment, parameters, capacity, or validity period.
Treating a collection invoice, audit report, or environmental claim as the certificate.