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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.

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.

The Regulation expressly requires the treatment enterprise to operate a data-information management system, report basic treatment data and related information to the local municipal ecology and environment authority, and keep the basic data for at least three years. It does not impose that same three-year rule on every producer.

The binding duties are role-specific. A producer, or the consignee or agent for imported products, must meet the applicable product-design, product-information, and treatment-fund requirements. The Regulation does not prescribe one producer record template, but the producer should keep the catalogue assessment, approved product or instruction content, design evidence, and fund records needed to show how it met those duties.

If the producer arranges collection, it should also keep enough contract and handoff evidence to show that recovered products went to an enterprise with the required treatment qualification. This is a practical evidence file, not a prescribed statutory form. Set its retention period from the applicable fund, tax, contract, accounting, product, and local regulatory requirements rather than assuming the operator's three-year minimum applies.

Build the file around the decision each record proves. An invoice alone may show payment but not catalogue scope, the operator's authority to treat the product category, or the actual handoff and treatment route.

The trigger has two parts. First, the discarded product must be listed in the national Waste Electrical and Electronic Product Treatment Catalogue. Second, the operator must perform treatment: dismantling; extracting material for raw material or fuel; changing physical or chemical characteristics to reduce the waste or its hazardous constituents; or final placement in an environmentally compliant landfill.

Repair, refurbishment, and second-hand reuse after repair or refurbishment are excluded from treatment. A business that only collects covered waste does not need the treatment qualification for collection, but it must send the waste to a qualified treatment enterprise if it does not hold the qualification itself.

The qualification is facility- and activity-specific. The applicant must be an established enterprise that fits the regional treatment development plan, has general VAT taxpayer enterprise-legal-person status, and has suitable sites, storage, treatment and supporting equipment, pollution controls, a data system, environmental-management and emergency measures, downstream plans for material it cannot fully treat, and qualified safety, quality, and environmental personnel. The certificate identifies the legal person, facility address, covered product categories, main equipment and operating parameters, treatment capacity, validity period, issue date, and certificate number. Holding a general recycling business registration or a certificate for a different facility or category does not satisfy those certificate terms.

The enterprise applies in writing to the ecology and environment authority of the city with districts where the facility is located. After accepting the application, the authority must publish the application information within three working days, allow at least ten working days for public comment, review the materials, conduct an on-site inspection, and decide within 60 days after acceptance. A pending application does not authorize treatment.

Article 34 of the Regulation separately permits a provincially approved centralized treatment site. It does not create a general exemption for ordinary recyclers, and the site must have centralized pollution-control facilities, meet applicable discharge and solid-waste technical standards, and comply with planning requirements.

Before treatment starts, match the certificate to the actual operator and work. A certificate copy is not enough if its scope, facility, capacity, or validity does not cover the planned route.