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China E-Waste Law E-waste recycler contract and records template

Contract schedule and records register for checking China e-waste treatment qualifications, handoffs, treatment data, and changes.

Use this template to define a collector's and treatment enterprise's roles, match each covered waste stream to the correct qualification certificate, and retain evidence from handoff through treatment. It is a drafting aid, not an official or mandatory contract form.

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Sorena AI

Published

Jul 5, 2026

Updated

Jul 24, 2026

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Cited legal and guidance references.

Publication metadata

Sorena AI

Published Jul 5, 2026

Updated Jul 24, 2026

Overview

Use this template when contracting for collection, storage, transport, repair, refurbishment, or of waste electrical and electronic products in China. State each service separately. If the vendor or a subcontractor will perform treatment, match that work to the legal person, facility, product category, equipment, operating parameters, capacity, and validity on its certificate before the first handoff. This is a drafting aid, not a statutory contract form or legal advice.

Section 1

1. Define the parties, products, and services

The Regulation distinguishes from collection and repair. Treatment includes dismantling; extracting substances for raw material or fuel; physical or chemical processes that reduce the amount of waste or its hazardous constituents; and final placement in a compliant landfill. Repair, refurbishment, and resale as second-hand goods after repair or refurbishment are excluded from that definition.

The Regulation applies to products in the Waste Electrical and Electronic Product Catalogue. The 2014 catalogue, effective since 1 March 2016, contains 14 classes and gives product-specific definitions and limits. Attach the applicable catalogue class and scope rationale to the contract rather than relying on a broad label such as 'electronics'.

Customer: legal name, China entity, sites, contract owner, environmental owner, and the person allowed to approve a waste handoff.
Vendor: exact legal-person name, registered address, -facility address, service sites, contract contact, and record contact.
Product schedule: catalogue class, product definition and limit, model or asset description, expected condition, forecast quantity, and known hazardous or confidential features.
Service schedule: identify collection, storage, transport, repair, refurbishment, dismantling, material or fuel extraction, other physical or chemical , and final disposal separately.
Responsibility map: state which party controls each handoff, retains each record, reports an incident, and approves any downstream enterprise.

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, and distinguish collection from qualified treatment.

Section 2

2. Attach and test the treatment qualification

For every party that will treat covered waste, attach the qualification certificate and record the certificate number, issuing authority, issue date, validity period, legal person, legal representative, registered address, -facility address, covered product categories, main facilities and equipment, operating parameters, and treatment capacity. Match these fields to the services and forecast waste streams.

The Licensing Measures prohibit without a qualification, treatment outside the certificate, and providing or entrusting covered waste to an unqualified unit or individual for treatment. The contract should therefore require prior written approval for any downstream treatment party and prohibit treatment until the customer has completed the same certificate check for that party.

Qualification schedule: reproduce the certificate fields and identify the copy or authority announcement used for verification, verification date, and verifier.
Operating-boundary clause: require all to stay within the stated facility, category, equipment, parameters, capacity, and validity period.
Downstream- clause: name each approved treatment enterprise and facility; require prior approval and evidence before adding or changing one.
Status clause: require prompt notice of expiry, amendment, fresh application, replacement, suspension, withdrawal, cancellation, lost eligibility, or an authority restriction.
Access clause: require the vendor to provide the records reasonably needed to verify the covered handoff and without claiming that the customer replaces regulatory supervision.
Stop-work clause: define who blocks a shipment or when qualification evidence is missing, inconsistent, expired, or outside scope.

Sources for this answer

Measures for Qualification Licensing for Waste Electrical and Electronic Product Treatment

Articles 11 and 16 list the certificate contents and prohibit unqualified treatment, treatment outside the certificate, and entrusting treatment to an unqualified party.

Section 3

3. Use a shipment-to-treatment records register

Create one register entry for each shipment or controlled batch. Give it a stable identifier and link the customer release, collection, transport, receipt, , outputs, residual destinations, exceptions, and approvals. Name the customer record owner and the vendor record owner. The completed record should show what happened to the specific waste stream and which qualified facility performed the treatment.

These customer-facing fields are recommended contract and audit controls, not a government-issued template. The binding rules separately require the enterprise to maintain a , report basic treatment data and related information to the city-level ecology and environment authority, retain basic treatment data for at least three years, conduct routine environmental monitoring, and retain monitoring reports for at least three years.

Release: record identifier, customer entity and site, product or asset description, catalogue class, quantity and unit, release date, and approving person.
Handoff: collector and transporter, pickup date, origin, destination, vehicle or transport reference where applicable, receiving facility, receipt date, accepted quantity, and discrepancy.
: qualified legal person and facility, certificate number, treatment date, method, equipment or line where relevant, input quantity, and operator record reference.
Outputs: recovered materials, products sent for further use or disposal, residual waste, quantity and unit, destination party and facility, handoff date, and supporting record.
Exceptions: rejection, loss, damaged load, route change, unplanned subcontracting request, incident, authority action, or mismatch; record the owner, decision, corrective action, and closure evidence.
Retention: preserve the contract, scope decision, certificate check, register entry, receipts, evidence, output records, notices, approvals, and review history for the agreed period. Separately require the treatment enterprise to retain basic treatment data and monitoring reports for at least three years.

Sources for this answer

Measures for Qualification Licensing for Waste Electrical and Electronic Product Treatment

Articles 19-20 require an annual monitoring plan, routine pollution monitoring, monitoring-report retention for at least three years, and a data-information management system with periodic reporting and public disclosure.

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 4

4. Add change notices and review triggers

Set a notice period that gives the customer time to stop shipments and reassess the route. The statutory filing deadlines below apply to the enterprise; the contract can require earlier notice. State that affected shipments remain blocked until the customer records a new approval against the changed certificate and route.

Do not draft a clause that treats corporate-group status, a certificate for another facility, or a pending application as permission to treat. The existing certificate must cover the legal person, facility, category, equipment, parameters, capacity, and period in use.

Within 15 working days after business-registration changes to the legal-person name, legal representative, or registered address, the enterprise must apply to the original issuing authority to amend the qualification.
A fresh application under the original procedure is required before adding a category, building a new treatment facility, altering or expanding an existing facility, or processing more than 20% above the capacity on the certificate.
After a regional -plan revision, the original issuing authority reviews enterprises that intend to continue and replaces certificates for those that still qualify.
On planned termination, the enterprise must control pollution at the site, properly handle untreated waste, and apply for cancellation within 20 days after taking those measures; the authority performs an on-site inspection before cancellation.
Customer review triggers should also include product-scope changes, new waste characteristics, downstream-party changes, route changes, incidents, authority inspections or sanctions, and missing or inconsistent records.

Sources for this answer

Measures for Qualification Licensing for Waste Electrical and Electronic Product Treatment

Articles 12-15 govern certificate amendments, circumstances requiring a fresh application, replacement after a regional-plan revision, and termination and cancellation.

Section 5

5. State what the contract does not prove

A signed contract, certificate copy, collection receipt, or sustainability statement does not prove that a specific batch received qualified . Keep the contract controls linked to the shipment and treatment records.

The qualification and this template do not replace the facility's technical environmental duties. has applied since 1 March 2026 and covers pollution control and environmental management for storage, dismantling, and the use or disposal of outputs. Hazardous waste, transport, occupational safety, state-secret handling, asset write-off, and local rules may add controls for a particular waste stream.

Keep China RoHS substance declarations and product marking separate from end-of-life qualification and evidence.
For assets involving state secrets, follow the applicable state-secrecy rules; the general e-waste contract does not determine the approved handling route.
For a state organ, social organization, enterprise, or public institution disposing of covered assets, confirm whether the national asset write-off procedures referenced by the Regulation apply.
Use case-specific legal and environmental review where the product is outside the catalogue, produces hazardous waste, the facility cannot complete treatment, or local requirements are unclear.

Sources for this answer

Regulation on the Administration of the Recovery and Treatment of Waste Electrical and Electronic Products

Articles 13, 15, and 19 address asset write-off, state-secret handling, treatment standards, prohibited obsolete processes, and environmental and sanitation duties for recovery, storage, transport, and treatment.

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 contract controls, qualification checks, handoff records, treatment evidence, and change reviews to named owners.

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Map official sources to evidence

Research Copilot connects the official citation, decision, owner, retained evidence, and change history.

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Talk to Sorena

Review the China route

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

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Primary sources

References and citations

HJ 527-2026 Technical specification for pollution control of waste electrical and electronic equipment treatment

mee.gov.cn

Referenced sections

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.

Measures for Qualification Licensing for Waste Electrical and Electronic Product Treatment

mee.gov.cn

Referenced sections

Articles 12-15 govern certificate amendments, circumstances requiring a fresh application, replacement after a regional-plan revision, and termination and cancellation.

Regulation on the Administration of the Recovery and Treatment of Waste Electrical and Electronic Products

mee.gov.cn

Referenced sections

Articles 13, 15, and 19 address asset write-off, state-secret handling, treatment standards, prohibited obsolete processes, and environmental and sanitation duties for recovery, storage, transport, and treatment.

Waste Electrical and Electronic Product Treatment Catalogue (2014 edition)

ndrc.gov.cn

Referenced sections

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.

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