---
title: "China E-Waste Law FAQ"
canonical_url: "https://www.sorena.io/artifacts/apac/china-e-waste-law/faq"
source_url: "https://www.sorena.io/artifacts/apac/china-e-waste-law/faq/items"
author: "Sorena AI"
description: "China e-waste FAQ covering treatment-catalogue scope, actor duties, qualified treatment, operator records, and the boundary with China RoHS."
published_at: "2026-07-05"
updated_at: "2026-07-25"
keywords:
  - "China e-waste"
  - "WEEE"
  - "Waste electrical and electronic products"
  - "Product compliance"
---
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# China E-Waste Law FAQ

China e-waste FAQ covering treatment-catalogue scope, actor duties, qualified treatment, operator records, and the boundary with China RoHS.

*FAQ* *China*

## China E-Waste Law FAQ

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 Waste Electrical and Electronic Product Treatment Catalogue, and is the activity legally defined treatment rather than repair or refurbishment? Then identify each actor. The answers below separate producer and importer duties, collection and transfer duties, qualified treatment, operator records, and China RoHS.

## Definitions

### Waste Electrical and Electronic Product Treatment Catalogue

The catalogue is the national list that brings specified discarded product categories within the State Council e-waste regulation. The 2014 edition, effective since 1 March 2016, contains 14 categories and category-specific definitions or limits. A product's electrical or electronic function does not by itself establish coverage.

**Why it matters here:** Use the full catalogue entry for the exact model. Catalogue coverage is the first scope test before assigning recovery, transfer, treatment, or qualification duties.

Sources:

- [Waste Electrical and Electronic Product Treatment Catalogue (2014 Edition)](https://www.ndrc.gov.cn/xxgk/zcfb/gg/201502/W020190905485475610247.pdf?ref=sorena.io)
- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Article 3](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io)

### Treatment under the e-waste regulation

**Term:** Treatment

Treatment means dismantling; extracting substances for raw material or fuel; using physical or chemical change to reduce waste quantity or hazardous constituents; or final placement in an environmentally compliant landfill. It excludes repair, refurbishment, and reuse as second-hand goods after repair or refurbishment.

**Why it matters here:** A collector needs the treatment qualification only if it performs one of the regulated treatment activities. Commercial descriptions such as recycler, recovery provider, or circularity partner do not decide the legal classification.

Sources:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Article 2](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io)

### Electrical and electronic product producer

**Term:** producer

The regulation assigns the producer duties relating to product pollution control, design and material choices, hazardous-substance and recovery information, and encouraged collection. The regulation separately names the consignee or agent for imported products rather than treating every seller or brand owner as the producer.

**Why it matters here:** Identify the China entity that actually performs the legally named role. Producer collection is encouraged, not stated as a general mandatory take-back duty, and treatment-fund collection stopped on 1 January 2024.

Sources:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Articles 7 and 10-11](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io)
- [Announcement on cessation of the Waste Electrical and Electronic Product Treatment Fund](https://szs.mof.gov.cn/zt/mlqd_8464/zcgd/202401/t20240118_3926323.htm?ref=sorena.io)

### Import consignee or its agent

**Term:** import consignee or agent

For imported electrical and electronic products, the regulation names the consignee or its agent alongside domestic producers for the product pollution-control, design, material, and product-information duties. The legal entity named in the import transaction must be identified from the actual customs and contractual facts.

**Why it matters here:** Do not assign import duties from a brand name alone. Record the consignee or agent for the shipment and keep that role separate from seller, collector, and treatment-enterprise roles.

Sources:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Articles 7 and 10](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io)

### Qualified treatment enterprise

**Term:** treatment enterprise

A treatment enterprise is an enterprise authorized to treat catalogue-listed waste electrical and electronic products. Its qualification certificate specifies the legal person, treatment facility, covered categories, main equipment and operating parameters, capacity, validity period, issue date, and certificate number.

**Why it matters here:** Collected covered waste must reach a qualified treatment enterprise unless the collector holds the qualification for its own treatment. Verify every relevant certificate field before shipment or treatment.

Sources:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Articles 6, 11-12 and 22](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io)
- [Qualification Licensing Measures, Articles 11 and 16](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io)

### Former waste electrical and electronic product treatment fund

**Term:** treatment fund

The regulation created a treatment fund financed by domestic producers and import consignees or agents to subsidize eligible treatment. A later four-ministry announcement stopped collecting the fund on 1 January 2024 and ended the former fund subsidy for products treated from that date. Central special funding replaced that support route; it is not a continuing producer or importer levy.

**Why it matters here:** Do not list treatment-fund payment as a current operational duty for periods from 1 January 2024. Historical liabilities and records for earlier periods remain a separate question.

Sources:

- [Announcement on cessation of the Waste Electrical and Electronic Product Treatment Fund](https://szs.mof.gov.cn/zt/mlqd_8464/zcgd/202401/t20240118_3926323.htm?ref=sorena.io)
- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Article 7](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io)

### China RoHS hazardous-substance regime

**Term:** China RoHS

China RoHS is the product-facing regime under the Measures for the Administration of the Restricted Use of Hazardous Substances in Electrical and Electronic Products. It addresses hazardous-substance restriction, marking and disclosure, environmental protection use periods, and conformity assessment for products in the applicable compliance-management catalogue.

**Why it matters here:** China RoHS and the e-waste regulation can apply to the same model, but they answer different questions. A China RoHS file does not prove end-of-life catalogue coverage, treatment qualification, or batch treatment.

Sources:

- [Measures for the Administration of the Restricted Use of Hazardous Substances in Electrical and Electronic Products](https://www.miit.gov.cn/jgsj/zfs/gzdt/art/2020/art_26714a290ac8407fb6df9eb816c2596f.html?ref=sorena.io)

## Browse sub-FAQ modules

### [How is China e-waste different from China RoHS?](/artifacts/apac/china-e-waste-law/faq/how-is-china-e-waste-different-from-china-rohs.md)

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

- 2 items

### [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.

- 2 items

### [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.

- 2 items

Browse all indexed questions: [/artifacts/apac/china-e-waste-law/faq/items](/artifacts/apac/china-e-waste-law/faq/items.md)

## All FAQ items

*Page 1 of 1. Showing 6 of 6 items.*

### [Short answer](/artifacts/apac/china-e-waste-law/faq/how-is-china-e-waste-different-from-china-rohs.md#short-answer)

*Module: [How is China e-waste different from China RoHS?](/artifacts/apac/china-e-waste-law/faq/how-is-china-e-waste-different-from-china-rohs.md)*

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.

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](/artifacts/apac/china-e-waste-law/faq/how-is-china-e-waste-different-from-china-rohs.md#what-to-keep-as-evidence)

*Module: [How is China e-waste different from China RoHS?](/artifacts/apac/china-e-waste-law/faq/how-is-china-e-waste-different-from-china-rohs.md)*

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.

### [Short answer](/artifacts/apac/china-e-waste-law/faq/what-records-should-a-producer-keep-for-e-waste-recovery-and-disposal.md#short-answer)

*Module: [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)*

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.

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 3, 7, 10, 11, 12, 16 and 17 establish catalogue scope, producer and importer duties, transfer to qualified treatment, monitoring, reporting, and the treatment enterprise's minimum three-year retention duty.
- [Qualification Licensing Measures for Waste Electrical and Electronic Product Disposal](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - Articles 11, 16, 19 and 20 identify the certificate fields, prohibit treatment outside the certificate, and require monitoring reports and treatment data.

### [What to keep as evidence](/artifacts/apac/china-e-waste-law/faq/what-records-should-a-producer-keep-for-e-waste-recovery-and-disposal.md#what-to-keep-as-evidence)

*Module: [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)*

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.

- Scope: identify the product family and model, record whether it appears in the applicable national treatment catalogue, and keep the catalogue version used for the decision.
- Producer or importer duties: keep the approved product or instruction content showing hazardous-substance information and recovery or treatment instructions, plus the evidence used for any applicable treatment-fund calculation and payment.
- Roles and route: identify the producer, importer consignee or agent, seller, repairer, collector, transporter, and treatment enterprise involved. Record which party takes custody at each handoff.
- Qualification check: keep a copy or official record of the treatment qualification certificate and match its legal person, facility address, product categories, equipment and operating parameters, capacity, and validity period to the planned work.
- Contracts and handoffs: keep collection and treatment contracts, shipment or transfer records, quantities, dates, product categories, receiving-facility identity, and any treatment confirmation available under the contract.
- Operator records: require the treatment enterprise to retain its basic treatment data for at least three years and its monitoring reports for more than three years. Use contract access or audit terms if the producer needs copies or verification, because those statutory records belong to the operator.
- Reassessment: reopen the file when the catalogue or product specification changes, the product becomes waste through a new route, the collector or treatment enterprise changes, the certificate is amended or expires, the facility or treatment category changes, capacity rises, records conflict, or an authority identifies a deficiency.

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 10-12 allocate product-information, collection, qualified-treatment and transfer duties; Articles 16-17 place monitoring, reporting and basic-data retention on the treatment enterprise.
- [Qualification Licensing Measures for Waste Electrical and Electronic Product Disposal](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - Articles 11, 16, 19 and 20 support the certificate-content check, the ban on treatment outside the certificate, monitoring-report retention for more than three years, and periodic treatment-data reporting.

### [Short answer](/artifacts/apac/china-e-waste-law/faq/when-does-a-disposal-operator-need-a-waste-electrical-product-qualification-permit.md#short-answer)

*Module: [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)*

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.

Sources for this answer:

- [Qualification Licensing Measures for Waste Electrical and Electronic Product Disposal](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - Articles 2, 7-11 and 16 establish catalogue scope, applicant conditions, the three-working-day publication period, minimum ten-working-day comment period, 60-day review period, certificate contents, and the prohibition on unqualified or out-of-scope treatment.
- [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, 6, 12, 22 and 34 define treatment and catalogue scope, require qualification, govern collectors, prohibit unqualified treatment, and describe the provincially approved centralized-site route.

### [What to keep as evidence](/artifacts/apac/china-e-waste-law/faq/when-does-a-disposal-operator-need-a-waste-electrical-product-qualification-permit.md#what-to-keep-as-evidence)

*Module: [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)*

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.

- Confirm that the exact discarded product is listed in the applicable Treatment Catalogue.
- Classify the operator's activity as collection, repair, refurbishment, second-hand resale, or treatment.
- If treatment is planned, confirm that the operator obtained the qualification before work starts; an application receipt or public notice is not a permit.
- Match the certificate's legal person, facility address, product categories, equipment and operating parameters, capacity, validity period, and certificate number to the work.
- Check the issuing authority's announcement or records and any available supervision information; do not rely on a transferable certificate because transfer, rental, lending, forgery, and alteration are prohibited.
- Require the operator to reapply through the original procedure before adding a product category, building a new treatment facility, rebuilding or expanding an existing facility, or treating more than 20% above the capacity stated on the certificate.
- For a change of legal-person name, legal representative, or domicile, confirm that the operator applied to the original issuing authority within 15 working days after the business-registration change.
- Keep contracts and handoff records that prohibit out-of-scope treatment and onward transfer to an unqualified party.

Sources for this answer:

- [Qualification Licensing Measures for Waste Electrical and Electronic Product Disposal](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - Articles 11-13 and 16 specify certificate contents, the 15-working-day change procedure, the four reapplication triggers including the more-than-20% capacity threshold, and prohibited certificate or treatment conduct.

*Apply the requirement*

*Placement: Before primary sources*

## Prepare the qualified disposal evidence file

Keep the catalogue decision, actor analysis, treatment certificate check, handoff trail, and operator records together.

- [Map official sources to evidence](/solutions/research-copilot.md): Keep each FAQ answer with the exact catalogue, actor, certificate, fund-period, and record evidence that supports it.
- [Review the China route](/contact.md): Check the China E-Waste Law scope decision and unresolved launch questions with Sorena.


---

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