Start with two questions: is the discarded product in the national treatment catalogue, and is the activity legally defined treatment rather than repair or refurbishment?
Then identify each actor. Producers and importers, sellers and repairers, collectors, and treatment enterprises have different duties and evidence.
Start with two questions: is the discarded product in the , and is the activity legally defined rather than repair or refurbishment? Then identify each actor. The answers below separate and importer duties, collection and transfer duties, qualified treatment, operator records, and .
Browse sub-FAQs
Choose the question set you need
These focused FAQ modules break this artifact into narrower answer sets so teams can move straight to the right source-backed guidance.
Most China e-waste rules questions start with scope
The Regulation applies to recovery, , and related activities for discarded electrical and electronic products listed in the national . Catalogue coverage is therefore a product-specific threshold; do not treat every electrical product as covered without checking the applicable catalogue entry.
means dismantling; extracting materials for use as raw materials or fuel; changing physical or chemical characteristics to reduce the amount of waste or reduce or eliminate hazardous constituents; or final placement in an environmentally compliant landfill. Repair, refurbishment, and resale as second-hand goods after repair or refurbishment fall outside that definition, although repaired goods have separate safety and second-hand marking requirements.
After scope, assign roles. A and an have design, material, and product-information duties under the Regulation. The former stopped being collected on 1 January 2024, so fund payment is not a current duty for later periods. Sellers, repairers, and after-sales providers must display recovery and information at their business premises. Collectors that lack a treatment qualification must transfer covered waste to a qualified . Treatment enterprises need the qualification and must meet operating, monitoring, reporting, and recordkeeping rules.
Is the exact product family in the applicable official catalogue?
Is the activity collection, repair, refurbishment, resale, or legally defined ?
Which entity is the , , seller or repairer, collector, transporter, and ?
Does the qualification certificate cover the actual legal person, facility, category, equipment and parameters, capacity, and validity period?
Which statutory records and practical chain-of-custody evidence will show what happened?
For a product-specific decision, retain the catalogue entry and version, the role analysis, the qualification check, and the handoff evidence. Keep statutory operator records separate from recommended customer due diligence: the , not every , must keep basic treatment data and monitoring reports for at least three years.
and the e-waste Regulation can both apply to one product. China RoHS governs hazardous-substance controls, marking, environmental protection use period, and the conformity-assessment route for products in its compliance-management catalogue. The e-waste Regulation governs catalogued products when they become waste, while also requiring or importer information about hazardous substances and recovery or .
Which discarded products fall under China's e-waste regulation?
The regulation applies when the discarded product matches an entry in the . The 2014 edition, effective since 1 March 2016, lists 14 categories: refrigerators, room air conditioners, range hoods, washing machines, electric and gas water heaters, printers, copiers, fax machines, televisions, monitors, microcomputers, mobile communication handsets, and telephone sets. Several entries contain boundaries: refrigerators are limited to volume <=800 litres, room air conditioners to cooling output <=14,000 W, washing appliances to dry-clothes capacity <=10 kg, and printers and copiers to a format smaller than A2 at <=80 pages per minute. Check the complete entry and model facts rather than relying on the category name.
Does repair or refurbishment require a qualification?
Not by itself. The regulation excludes repair, refurbishment, and reuse as second-hand goods after repair or refurbishment from . Treatment instead includes dismantling, extracting substances for raw material or fuel, physical or chemical hazard-reduction processes, and compliant final landfill placement. If one return stream splits, document which units were repaired and which were dismantled or otherwise treated. A collector or repairer that also performs treatment needs the qualification for that treatment activity.
Must a take back every covered product?
The State Council regulation encourages a to collect discarded products itself or through sellers, repairers, after-sales providers, or collectors; it does not state a general mandatory producer take-back duty. Separate duties still apply: producers and the named must meet the product pollution-control, design, material, and information requirements, while collected covered waste must reach a qualified .
Is the or importer still required to pay the ?
No current fund collection applies for periods from 1 January 2024. The four-ministry cessation announcement stopped collection on that date and ended the former fund subsidy for products treated from that date. The State Council regulation still contains the original fund framework, but the later announcement controls the current collection position. Historical liabilities and records for periods before 2024 require a separate period-specific check.
When does a collector need a qualification?
Collection alone does not trigger the qualification. A collector needs the qualification if it dismantles covered products, extracts substances for material or fuel use, applies physical or chemical processes to reduce waste or hazardous constituents, or performs final landfill placement. A collector without that qualification must transfer collected covered waste to a qualified .
What should be checked on a qualification certificate?
Match the certificate to the actual legal person and -facility address, then check the covered catalogue categories, main facilities and equipment, operating parameters, treatment capacity, validity period, issue date, and certificate number. A certificate for another facility or group company does not establish permission. Adding a category, building a new facility, altering or expanding a facility, or operating more than 20% above certified capacity requires a fresh application under the original procedure.
How does a apply, and how long does the authority have?
The enterprise applies in writing to the ecology and environment authority for the city divided into districts where the facility is located. It must show lawful establishment, enterprise legal-person and general value-added-tax taxpayer status, consistency with the regional treatment development plan, suitable sites, storage and treatment equipment, pollution controls, data systems, emergency arrangements, and qualified personnel. After accepting the application, the authority must publicize the relevant information within three working days, allow at least ten working days for public comment, verify comments, review the file, conduct an on-site inspection, and decide within 60 days. Treatment cannot begin until the qualification is issued.
When must a qualification be amended, replaced, or cancelled?
A changed legal-person name, legal representative, or registered address must be submitted to the original issuing authority for amendment within 15 working days after the business-registration change. Adding a category, building a new facility, altering or expanding an existing facility, or treating more than 20% above certified capacity requires a fresh application under the original procedure. After a regional treatment-plan revision, the authority reviews operators that intend to continue and replaces certificates for those that still qualify. On closure, the operator must control site pollution, handle untreated waste, apply for cancellation within 20 days after taking those measures, and complete the required site environmental investigation and risk assessment.
Does an industrial park or shared recycling site avoid the qualification requirement?
No. Article 34 creates a narrow route for a centralized site approved by a provincial people's government. The site 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. An industrial-park address, recycling cluster, or shared facility does not establish this exception.
What must an institution do when discarding covered equipment?
An organ, organization, enterprise, public institution, or similar unit must hand covered discarded equipment to a qualified and follow the applicable state asset-write-off procedure. Equipment involving state secrets follows separate secrecy rules. The institution should retain the asset identity, approval or write-off record, qualified destination, transfer and receipt evidence, and any required secrecy handling without treating those practical records as a nationally prescribed handoff form.
What can happen if covered or operator records do not comply?
Unqualified can lead to an order to stop operations or close, confiscation of illegal proceeds, and a CNY 50,000-500,000 fine. A that lacks the required data-information system, fails to report, reports false information, or misses the basic-data retention period can be ordered to correct and may be fined up to CNY 50,000. The same correction order and possible fine up to CNY 50,000 apply when the enterprise lacks or does not carry out routine environmental monitoring. Separate licensing-measure consequences apply to treatment outside certificate terms and failures to complete required amendment, replacement, or cancellation procedures.
Which records must a keep?
A must operate a data-information management system, report basic data and related information to the local city-level ecology and environment authority, and retain the basic treatment data for at least three years. Under the licensing measures, it must also follow an annual monitoring plan, conduct routine emissions monitoring, and keep monitoring reports for at least three years. Contracts, shipment records, receipts, and certificate checks are useful chain-of-custody evidence, but the two instruments do not prescribe one universal customer handoff form.
How is the e-waste regulation different from ?
addresses hazardous-substance controls, marking, the environmental protection use period, and conformity assessment for products in its compliance-management catalogue. The e-waste regulation uses a separate catalogue and governs recovery and treatment when listed products become waste. One model can require both analyses, but a China RoHS declaration does not prove e-waste catalogue coverage, treatment qualification, or the route taken by a discarded batch.
Which Chinese authority handles recovery, qualifications, and supervision?
Responsibility is divided. The State Council ecology and environment authority coordinates recovery and policy and supervises treatment, while the State Council commerce authority manages recovery. For an operator application, the ecology and environment authority for the city divided into districts where the treatment facility is located issues the treatment qualification. County-level and higher ecology and environment authorities supervise treatment operations, and the licensing measures require supervisory emissions monitoring at least once every six months. Finance, market regulation, tax, customs, and other authorities retain the responsibilities assigned to them; a city-issued treatment qualification does not replace their separate approvals or controls.
Check the exact product against the applicable catalogue.
Classify the activity as collection, repair, refurbishment, second-hand resale, transport, or .
Assign each legal entity's , importer, seller, repairer, collector, transporter, and role.
Match the qualification certificate to the actual operator, facility, category, process, capacity, and validity period.
Retain contracts and chain-of-custody records that connect collection to the qualified route.
Confirm who holds the statutory data and monitoring reports and how the contracting party can obtain evidence when needed.
Articles 5-20 support the city-level licensing authority and application route, certificate scope, changes, valid operations, operator and supervisory monitoring, monitoring-report retention, and treatment-data reporting.
Articles 2-6, 10-17, 22-24, 27-32, and 34 support the scope sequence, authority responsibilities, actor duties, the institutional-holder route, qualified treatment, application conditions, the centralized-site exception, monitoring, data reporting, retention, and enforcement consequences.