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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. China RoHS 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.

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Sorena AI
Published
Jul 5, 2026
Updated
Jul 24, 2026
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Sorena AI
Published Jul 5, 2026
Updated Jul 24, 2026
Overview

China e-waste rules govern recovery and qualified treatment after a product in the national treatment catalogue becomes waste. China RoHS 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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Question 1

Short answer

China's e-waste Regulation applies to recovery, treatment, and related activities for discarded products listed in the national Waste Electrical and Electronic Product Treatment Catalogue. 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, information, and treatment-fund duties under that Regulation.

China RoHS 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 environmental protection use period. Products placed in the separate Compliance Management Catalogue must also meet the applicable substance limits and conformity-assessment system from the relevant implementation date.

The catalogues are not interchangeable. Inclusion in the China RoHS Compliance Management Catalogue 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.

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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 China RoHS 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.
  • China RoHS 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.
  • China RoHS product file: keep evidence for hazardous-substance controls, required marking or instructions, environmental protection use period, packaging, and any applicable Compliance Management Catalogue 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.
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