Short answer
The Regulation expressly requires the treatment enterprise to operate a data-information management system, report 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 .
The binding duties are role-specific. A , or the consignee or agent for imported products, must meet the applicable product-design and product-information duties. From 15 August 2026, producers must also meet Environmental Code Article 978 by establishing and publicly disclosing the required recovery system, so the producer file should retain evidence of that system and disclosure. The Regulation still states the original framework, but official fund collection and the former subsidy for products newly treated stopped on 1 January 2024. Keep fund calculations, declarations, payments, and reconciliations only for the historical periods in which they applied. The Regulation does not prescribe one producer record template, but the producer should keep the catalogue assessment, approved product or instruction content, and design evidence needed to show how it met its current duties.
If the arranges collection, it should also keep enough contract and handoff evidence to show that recovered products went to an enterprise with the required . This is a practical evidence file, not a prescribed statutory form. Set its retention period from the applicable historical fund, tax, contract, accounting, product, and local regulatory requirements rather than assuming the operator's three-year minimum applies.
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.
Articles 11, 16, 19 and 20 identify the certificate fields, prohibit treatment outside the certificate, and require monitoring reports and treatment data.
Confirms that fund collection and the former subsidy for products newly treated stopped on 1 January 2024, while earlier unpaid eligible treatment remained subject to the historical rules.
Articles 978 and 1242 establish the producer recovery-system and public-disclosure duty from 15 August 2026.