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

The Regulation distinguishes treatment 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 Treatment 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'.

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, treatment-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 treatment 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.

Create one register entry for each shipment or controlled batch. Give it a stable identifier and link the customer release, collection, transport, receipt, treatment, 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 treatment enterprise to maintain a data-information management system, 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.

Set a notice period that gives the customer time to stop shipments and reassess the route. The statutory filing deadlines below apply to the treatment 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.

A signed contract, certificate copy, collection receipt, or sustainability statement does not prove that a specific batch received qualified treatment. 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. HJ 527-2026 has applied since 1 March 2026 and covers pollution control and environmental management for storage, dismantling, and the use or disposal of treatment outputs. Hazardous waste, transport, occupational safety, state-secret handling, asset write-off, and local rules may add controls for a particular waste stream.