---
title: "How is China e-waste different from China RoHS?"
canonical_url: "https://www.sorena.io/artifacts/apac/china-e-waste-law/faq/how-is-china-e-waste-different-from-china-rohs"
source_url: "https://www.sorena.io/artifacts/apac/china-e-waste-law/faq/how-is-china-e-waste-different-from-china-rohs"
author: "Sorena AI"
description: "China e-waste rules govern catalogued products at end of life. China RoHS governs hazardous-substance controls, marking, disclosure, and catalogue-based conformity assessment."
published_at: "2026-07-05"
updated_at: "2026-07-24"
keywords:
  - "China e-waste"
  - "WEEE"
  - "Waste electrical and electronic products"
  - "Product compliance"
---
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---

# How is China e-waste different from China RoHS?

China e-waste rules govern catalogued products at end of life. China RoHS governs hazardous-substance controls, marking, disclosure, and catalogue-based conformity assessment.

*Question* *China*

## 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.

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.

## 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.

Sources for this answer:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - 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.
- [Measures for Restriction of Hazardous Substances in Electrical and Electronic Products](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - 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.
- [Waste Electrical and Electronic Product Treatment Catalogue (2014 edition)](https://www.ndrc.gov.cn/xxgk/zcfb/gg/201502/t20150213_961116.html?ref=sorena.io) - 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.

## 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.

Sources for this answer:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - Supports the separate Treatment Catalogue test, actor analysis, qualified-treatment route, and operator records.
- [Measures for Restriction of Hazardous Substances in Electrical and Electronic Products](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Supports the separate China RoHS scope, voltage limits, exclusions, marking, environmental protection use period, catalogue, and conformity-assessment analysis.

## Primary sources

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - Binding regulation for end-of-life Treatment Catalogue scope, actor duties, qualified treatment, monitoring, reporting, and records.
- [Measures for Restriction of Hazardous Substances in Electrical and Electronic Products](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Administrative measures for China RoHS product scope, hazardous-substance controls, marking, environmental protection use period, catalogue management, and conformity assessment.
- [Waste Electrical and Electronic Product Treatment Catalogue (2014 edition)](https://www.ndrc.gov.cn/xxgk/zcfb/gg/201502/t20150213_961116.html?ref=sorena.io) - Official announcement and linked catalogue for the 14 e-waste classes, their definitions and limits, and the 1 March 2016 effective date.

## Topic Guides

- [China e-waste compliance checklist](/artifacts/apac/china-e-waste-law/checklist.md): Checklist for covered product scope, qualified disposal partner review, disposal records, and downstream evidence.
- [China e-waste deadlines and compliance calendar](/artifacts/apac/china-e-waste-law/deadlines-and-compliance-calendar.md): China e-waste treatment permit deadlines, change triggers, monitoring dates, record-retention periods, and historical milestones.
- [China E-Waste Law FAQ](/artifacts/apac/china-e-waste-law/faq.md): China e-waste FAQ covering treatment-catalogue scope, actor duties, qualified treatment, operator records, and the boundary with China RoHS.
- [China e-waste penalties and enforcement exposure](/artifacts/apac/china-e-waste-law/penalties-and-fines.md): China e-waste fines and permit consequences by actor, violation, enforcement authority, and required correction.
- [China e-waste recovery and disposal requirements](/artifacts/apac/china-e-waste-law/requirements.md): China e-waste requirements for product lifecycle roles, qualified treatment, downstream evidence, and operator records.
- [China e-waste treatment qualification workflow](/artifacts/apac/china-e-waste-law/disposal-qualification-license-workflow.md): Decide whether a China e-waste treatment qualification is required, apply through the correct authority, and control certificate changes.
- [Covered products and e-waste recovery scope](/artifacts/apac/china-e-waste-law/covered-products-and-recovery-scope.md): How to document product family scope for China waste electrical and electronic product recovery and disposal without guessing catalogue coverage.
- [E-waste disposal operator qualification checklist](/artifacts/apac/china-e-waste-law/e-waste-disposal-operator-qualification-checklist.md): Verify China e-waste catalogue scope, treatment activity, facility-specific qualification, capacity, monitoring, downstream handoffs, and change triggers.
- [E-waste recycler contract and records template](/artifacts/apac/china-e-waste-law/e-waste-recycler-contract-and-records-template.md): Contract schedule and records register for checking China e-waste treatment qualifications, handoffs, treatment data, and changes.
- [Producer and disposal operator duties](/artifacts/apac/china-e-waste-law/producer-and-disposal-operator-duties.md): How producers, sellers, recyclers, and disposal operators should separate e-waste responsibilities and records.
- [What records should a producer keep for e-waste recovery and disposal?](/artifacts/apac/china-e-waste-law/faq/what-records-should-a-producer-keep-for-e-waste-recovery-and-disposal.md): Separate the producer's own China e-waste evidence from records that the qualified treatment enterprise must keep for at least three years.
- [When does a disposal operator need a waste electrical product qualification permit?](/artifacts/apac/china-e-waste-law/faq/when-does-a-disposal-operator-need-a-waste-electrical-product-qualification-permit.md): An enterprise needs a treatment qualification before treating products in China's e-waste Treatment Catalogue, subject to the Regulation's narrow centralized-site provision.

*Operationalize the requirement*

*Placement: Before primary sources*

## Prepare the qualified disposal evidence file

Sorena AI helps turn the answer to "How is China e-waste different from China RoHS?" into assigned controls and retained evidence.

- [Map official sources to evidence](/solutions/research-copilot.md): Research Copilot connects the official citation, decision, owner, retained evidence, and change history.
- [Review the China route](/contact.md): Check the China E-Waste Law scope decision and unresolved launch questions with Sorena.


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