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

Keep the producer's product-scope, information, fund, collection, and downstream-routing evidence. 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 basic treatment data. The cited regulation does not set one universal retention period for a producer's supporting file.

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Sorena AI
Published
Jul 5, 2026
Updated
Jul 24, 2026
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Sorena AI
Published Jul 5, 2026
Updated Jul 24, 2026
Overview

Keep the producer's product-scope, information, fund, collection, and downstream-routing evidence. 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 basic treatment data, not to every producer file.

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Question 1

Short answer

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.

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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.
  • 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.
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