We use privacy-by-default, cookieless analytics.

Optional analytics cookies are used only if you accept them.

Read our Terms of Use and Privacy Policy.

QuestionChina

What records should a producer keep for e-waste recovery and disposal? Direct answer

Keep the 's product-scope, product-information, collection, and downstream-routing evidence, plus records only for periods before collection stopped on 1 January 2024. Separately verify that the treatment enterprise holds a qualification covering the actual work.

The three-year statutory record rule applies to the treatment enterprise's . The cited regulation does not set one universal retention period for a 's supporting file.

Back to main artifactReview sources
Author
Sorena AI
Published
Jul 5, 2026
Updated
Jul 24, 2026
2 sections4 primary sources
Overview

Keep the 's product-scope, product-information, collection, and downstream-routing evidence. Keep records only for historical periods before fund collection stopped on 1 January 2024. Separately obtain evidence that the treatment enterprise holds a qualification covering the actual work. The three-year statutory record rule applies to the treatment enterprise's , not to every producer file.

Search this module

Find a question or answer quickly

2 of 2 questions
Question 1

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.

Question 2

What to keep as evidence

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.
  • or importer duties: keep the approved product or instruction content showing hazardous-substance information and recovery or treatment instructions. For producers, retain evidence of the recovery system and public disclosure required from 15 August 2026 under Environmental Code Article 978. For periods before 1 January 2024, also keep the evidence used for any applicable calculation, declaration, payment, and reconciliation.
  • Roles and route: identify the , 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 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 and monitoring reports for at least three years. Use contract access or audit terms if the 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.
Operationalize the requirement

Prepare the qualified disposal evidence file

Sorena AI helps turn the answer to "What records should a producer keep for e-waste recovery and disposal?" into assigned controls and retained evidence.

Research workflow
Map official sources to evidence

Research Copilot connects the official citation, decision, owner, retained evidence, and change history.

Explore next step
Talk to Sorena
Review the China route

Check the China E-Waste Law scope decision and unresolved launch questions with Sorena.

Explore next step
Primary sources

References and citations

Announcement on cessation of the Waste Electrical and Electronic Product Treatment Fund
szs.mof.gov.cn3 citations
Referenced sections
  • Current official source for the 1 January 2024 end of fund collection and the former subsidy for products newly treated.
  • 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.
  • Supports limiting fund records to periods before collection stopped on 1 January 2024.
Qualification Licensing Measures for Waste Electrical and Electronic Product Disposal
mee.gov.cn3 citations
Referenced sections
  • Administrative licensing measures for certificate contents, permitted operations, monitoring reports, data reporting, supervision, and certificate changes.
  • Articles 11, 16, 19 and 20 identify the certificate fields, prohibit treatment outside the certificate, and require monitoring reports and treatment data.
  • Articles 11, 16, 19 and 20 support the certificate-content check, the ban on treatment outside the certificate, monitoring-report retention for at least three years, and periodic treatment-data reporting.
Regulation on Recovery and Disposal of Waste Electrical and Electronic Products
mee.gov.cn3 citations
Referenced sections
  • Binding regulation for catalogue scope, producer and importer duties, qualified treatment, operator monitoring and data records, and the minimum three-year retention period for basic treatment data.
  • 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 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.
Environmental Code of the People's Republic of China
mee.gov.cn2 citations
Referenced sections
  • Binding law adopted on 12 March 2026; Articles 978 and 1242 establish the producer recovery-system and public-disclosure duty from 15 August 2026.
  • Articles 978 and 1242 establish the producer recovery-system and public-disclosure duty from 15 August 2026.

Related guides

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.

When does a disposal operator need a waste electrical product qualification permit?

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.

China e-waste compliance checklist

Checklist for covered product scope, qualified disposal partner review, disposal records, and downstream evidence.

China e-waste deadlines and compliance calendar

China e-waste treatment permit deadlines, change triggers, monitoring dates, record-retention periods, and historical milestones.

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.

China e-waste penalties and enforcement exposure

China e-waste fines and permit consequences by actor, violation, enforcement authority, and required correction.

Show all related guides (12)

China e-waste recovery and disposal requirements

China e-waste requirements for product lifecycle roles, qualified treatment, downstream evidence, and operator records.

China e-waste treatment qualification workflow

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

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

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

Contract schedule and records register for checking China e-waste treatment qualifications, handoffs, treatment data, and changes.

Producer and disposal operator duties

How producers, sellers, recyclers, and disposal operators should separate e-waste responsibilities and records.