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How is China e-waste different from China RoHS? Direct answer

China e-waste rules govern recovery and qualified treatment after a product in the national treatment catalogue becomes waste. governs hazardous-substance controls for electrical and electronic products placed on the Chinese market.

The two regimes have different scope definitions and catalogues. One product may require both analyses, and one file does not replace the other.

Author
Sorena AI
Published
Jul 5, 2026
Updated
Oct 15, 2026
Overview

China e-waste rules govern recovery and qualified treatment after a product in the national treatment catalogue becomes waste. governs hazardous-substance controls for electrical and electronic products placed on the Chinese market. The two regimes have different scope definitions and catalogues, so one product may require both analyses.

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2 of 2 questions
Question 1

Short answer

China's e-waste Regulation applies to recovery, treatment, and related activities for discarded products listed in the national . The 2014 edition has applied since 1 March 2016 and lists 14 classes, including refrigerators, room air conditioners, washing machines, televisions, monitors, microcomputers, and mobile communication handsets. Several entries contain technical limits, so the class name alone does not settle coverage. The Regulation distinguishes collection from treatment, requires covered waste to reach a qualified treatment enterprise, and regulates the enterprise's certificate, monitoring, data reporting, and record retention. Producers and import consignees or agents also have product-design and information duties. The Regulation still states the original treatment-fund framework, but official fund collection and the former subsidy for products newly treated stopped on 1 January 2024.

has applied since 1 July 2016 to electrical and electronic products produced, sold, or imported in China, subject to its own definition and exclusions. The definition covers equipment and supporting products that rely on current or electromagnetic fields, or generate, transmit, or measure them, at rated voltage up to 1,500 V DC or 1,000 V AC; equipment for electricity generation, transmission, and distribution is excluded. China RoHS governs design and production controls, packaging, hazardous-substance marking, and the . The 2026 and exception list took effect on 28 May 2026 and replaced the first-batch catalogue. Listed products must meet the stated substance-limit timing and enter the conformity-assessment system. GB 26572-2025 is published but does not take effect until 1 August 2027, when it will replace GB/T 26572-2011.

The catalogues are not interchangeable. Inclusion in the does not establish coverage under the e-waste Treatment Catalogue, and the reverse does not complete the China RoHS analysis. Check the exact product and current entry in each applicable catalogue.

Question 2

What to keep as evidence

Link both analyses to the same product family and model, but document the legal tests separately. Run the test when the product is produced, sold, or imported in China. Run the e-waste test when the product is discarded and a recovery or treatment route is planned. This prevents a substance-compliance record from being mistaken for evidence of lawful end-of-life treatment.

  • E-waste scope: keep the applicable Treatment Catalogue entry and the reason the discarded product is or is not covered.
  • E-waste activity and roles: classify collection, repair, refurbishment, resale, transport, and treatment, then identify the legal entity performing each role.
  • E-waste route: keep the treatment qualification certificate check, contracts, handoff records, and available treatment confirmation for covered waste.
  • scope: document whether the product meets the electrical and electronic product definition, including the voltage limits and exclusion for equipment used in electricity generation, transmission, and distribution.
  • product file: keep evidence for hazardous-substance controls, required marking or instructions, , packaging, and any applicable and conformity-assessment conclusion.
  • Shared product information: reconcile the two regimes' hazardous-substance and recovery information so the product, instructions, and compliance evidence do not conflict.
Primary sources

References and citations

miit.gov.cn3 citations
Referenced sections
  • Current official catalogue and exception list, effective from 28 May 2026.
  • Confirms the 28 May 2026 effective date, replacement of the first-batch catalogue, ten controlled substances, catalogue timing, exceptions, and conformity-assessment scope.
  • Supports the current catalogue, listed substances, implementation timing, exceptions, and conformity-assessment scope.
gov.cn3 citations
Referenced sections
  • Administrative measures for China RoHS product scope, hazardous-substance controls, marking, environmental protection use period, catalogue management, and conformity assessment.
  • Articles 2-3, 9-18 and 23 establish China RoHS scope, actor duties, marking, environmental protection use period, Compliance Management Catalogue, conformity assessment, and the 1 July 2016 commencement date.
  • Supports the separate China RoHS scope, voltage limits, exclusions, marking, environmental protection use period, catalogue, and conformity-assessment analysis.
mee.gov.cn3 citations
Referenced sections
  • Binding regulation for end-of-life Treatment Catalogue scope, actor duties, qualified treatment, monitoring, reporting, and records.
  • Articles 2-3 define treatment and Treatment Catalogue scope; Articles 7 and 10-17 allocate producer, importer, collection, qualified-treatment, monitoring, reporting, and retention duties.
  • Supports the separate Treatment Catalogue test, actor analysis, qualified-treatment route, and operator records.
std.samr.gov.cn2 citations
Referenced sections
  • Official standard record for the 1 August 2027 effective date and replacement of GB/T 26572-2011.
  • Confirms that GB 26572-2025 was published on 1 August 2025, takes effect on 1 August 2027, and will replace GB/T 26572-2011.
ndrc.gov.cn2 citations
Referenced sections
  • Official announcement and linked catalogue for the 14 e-waste classes, their definitions and limits, and the 1 March 2016 effective date.
  • The official announcement made the 2014 Treatment Catalogue effective on 1 March 2016 and links the catalogue containing the 14 covered classes and their product-specific definitions and limits.
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