--- title: "What records should a producer keep for e-waste recovery and disposal?" canonical_url: "https://www.sorena.io/artifacts/apac/china-e-waste-law/faq/what-records-should-a-producer-keep-for-e-waste-recovery-and-disposal" source_url: "https://www.sorena.io/artifacts/apac/china-e-waste-law/faq/what-records-should-a-producer-keep-for-e-waste-recovery-and-disposal" author: "Sorena AI" description: "Separate the producer's own China e-waste evidence from records that the qualified treatment enterprise must keep for at least three years." published_at: "2026-07-05" updated_at: "2026-07-24" keywords: - "China e-waste" - "WEEE" - "Waste electrical and electronic products" - "Product compliance" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # What records should a producer keep for e-waste recovery and disposal? Separate the producer's own China e-waste evidence from records that the qualified treatment enterprise must keep for at least three years. *Question* *China* ## 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. 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. ## 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. 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 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. ## Primary sources - [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) - 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. - [Qualification Licensing Measures for Waste Electrical and Electronic Product Disposal](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - Administrative licensing measures for certificate contents, permitted operations, monitoring reports, data reporting, supervision, and certificate changes. ## Topic Guides - [China e-waste compliance checklist](/artifacts/apac/china-e-waste-law/checklist.md): Checklist for covered product scope, qualified disposal partner review, disposal records, and downstream evidence. - [China e-waste deadlines and compliance calendar](/artifacts/apac/china-e-waste-law/deadlines-and-compliance-calendar.md): China e-waste treatment permit deadlines, change triggers, monitoring dates, record-retention periods, and historical milestones. - [China E-Waste Law FAQ](/artifacts/apac/china-e-waste-law/faq.md): 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](/artifacts/apac/china-e-waste-law/penalties-and-fines.md): China e-waste fines and permit consequences by actor, violation, enforcement authority, and required correction. - [China e-waste recovery and disposal requirements](/artifacts/apac/china-e-waste-law/requirements.md): China e-waste requirements for product lifecycle roles, qualified treatment, downstream evidence, and operator records. - [China e-waste treatment qualification workflow](/artifacts/apac/china-e-waste-law/disposal-qualification-license-workflow.md): 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](/artifacts/apac/china-e-waste-law/covered-products-and-recovery-scope.md): 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](/artifacts/apac/china-e-waste-law/e-waste-disposal-operator-qualification-checklist.md): 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](/artifacts/apac/china-e-waste-law/e-waste-recycler-contract-and-records-template.md): Contract schedule and records register for checking China e-waste treatment qualifications, handoffs, treatment data, and changes. - [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. - [Producer and disposal operator duties](/artifacts/apac/china-e-waste-law/producer-and-disposal-operator-duties.md): How producers, sellers, recyclers, and disposal operators should separate e-waste responsibilities and records. - [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. *Operationalize the requirement* *Placement: Before primary sources* ## 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. - [Map official sources to evidence](/solutions/research-copilot.md): Research Copilot connects the official citation, decision, owner, retained evidence, and change history. - [Review the China route](/contact.md): Check the China E-Waste Law scope decision and unresolved launch questions with Sorena. --- [Privacy Policy](https://www.sorena.io/privacy.md) | [Terms of Use](https://www.sorena.io/terms-of-use.md) | [DMCA](https://www.sorena.io/dmca.md) | [About Us](https://www.sorena.io/about-us.md) (c) 2026 Sorena AB (559573-7338). 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