---
title: "Producer and disposal operator duties"
canonical_url: "https://www.sorena.io/artifacts/apac/china-e-waste-law/producer-and-disposal-operator-duties"
source_url: "https://www.sorena.io/artifacts/apac/china-e-waste-law/producer-and-disposal-operator-duties"
author: "Sorena AI"
description: "How producers, sellers, recyclers, and disposal operators should separate e-waste responsibilities and records."
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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# Producer and disposal operator duties

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

*Product* *China*

## China E-Waste Law Producer and disposal operator duties

Use the actor matrix to assign product, display, collection, transfer, qualification, monitoring, reporting, retention, asset-write-off, and secrecy duties to the legal entity that performs each role.

Do not assign China's e-waste duties to a generic 'recycler' or product-compliance owner. Identify the producer, import consignee or agent, seller, repairer, after-sales provider, collector, institutional holder, and treatment enterprise. One company can perform several roles and must meet the duties attached to each. The former treatment fund stopped being collected on 1 January 2024, so current producer and importer work should not include a continuing fund-payment step.

## Definitions

### Electrical and electronic product producer

**Term:** producer

The producer is the actor to which the regulation assigns product design, material, pollution-control information, and encouraged collection duties for electrical and electronic products made in China. Sellers, collectors, and treatment enterprises have separate duties even when they belong to the same corporate group.

**Why it matters here:** Identify the legal entity performing the producer role for the product. Producer collection is encouraged rather than imposed as a general take-back mandate, and treatment-fund collection stopped on 1 January 2024.

Sources:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Articles 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 design, material, pollution-control, and product-information duties. The consignee or agent must be identified from the actual import transaction; a foreign manufacturer, brand owner, distributor, or seller is not automatically the named importer role.

**Why it matters here:** Record the China legal entity responsible for each import. Keep its product-facing duties separate from any collector or treatment role it or a contractor also performs.

Sources:

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

### Waste electrical and electronic product collector

**Term:** collector

A collector provides users with convenient collection services for discarded electrical and electronic products. Collection does not itself authorize dismantling or another regulated treatment activity. A collector that treats covered products needs the treatment qualification; without it, the collector must transfer them to a qualified treatment enterprise.

**Why it matters here:** Classify the contractor's actual work. Storage, transport, repair, refurbishment, dismantling, and material extraction can lead to different duties even when one supplier calls all of them recycling.

Sources:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Article 12](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. The certificate identifies the legal person, treatment facility, covered categories, main equipment and operating parameters, capacity, validity period, issue date, and certificate number.

**Why it matters here:** Verify the actual certificate fields for every treatment destination. The treatment enterprise, not the contracting producer merely because it arranged the service, holds the operator monitoring, data-system, reporting, disclosure, and retention duties.

Sources:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Articles 6 and 15-17](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io)
- [Qualification Licensing Measures, Articles 11, 19 and 20](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io)

### Institutional holder of discarded products

**Term:** institutional holder

This page uses institutional holder for an organ, organization, enterprise, public institution, or similar unit that hands over discarded electrical and electronic products. Article 13 requires such a unit to use a qualified treatment enterprise and to follow applicable state procedures for asset write-off; products involving state secrets follow the separate secrecy rules.

**Why it matters here:** The institutional-holder duty is not a producer duty. Identify who owns the discarded assets and whether asset-write-off or state-secrecy procedures apply before transfer.

Sources:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Article 13](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io)

### Former waste electrical and electronic product treatment fund

**Term:** treatment fund

The regulation created a treatment fund paid by domestic producers and import consignees or agents. A later four-ministry announcement stopped collecting it on 1 January 2024 and ended the former fund subsidy for products treated from that date. Central special funding now supports eligible treatment through a different route.

**Why it matters here:** Do not assign fund payment as a current producer or importer duty for periods from 1 January 2024. Check any pre-2024 liability or record issue against the rules for that historical period.

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)

### Treatment data-information management system

**Term:** data-information system

A treatment enterprise must operate a system holding the basic data and related information for its waste electrical and electronic product treatment. It must report that information to the local city-level ecology and environment authority, make the required information public under the licensing measures, and retain the basic treatment data for at least three years.

**Why it matters here:** This is an operator duty, not a generic customer record. A contracting party should determine what certificate, shipment, receipt, and treatment evidence it can obtain without confusing its due diligence file with the operator's statutory system.

Sources:

- [Regulation on Recovery and Disposal of Waste Electrical and Electronic Products, Article 17](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io)
- [Qualification Licensing Measures, Article 20](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.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:** The e-waste regulation refers to product pollution-control information but does not replace China RoHS. Keep the product assessment separate from collection, treatment qualification, and operator records.

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)

## What this guide helps you decide

Producers and import consignees or their agents have design, material, hazardous-substance, and recovery-information duties. Article 7 created a treatment-fund payment duty, but the later four-ministry announcement stopped collection on 1 January 2024. The regulation encourages producers to collect waste themselves or through specified intermediaries; it does not state a general mandatory producer take-back duty.

Collectors must provide convenient collection services. A collector may treat catalogued waste only with the treatment qualification; otherwise it must transfer that waste to a qualified treatment enterprise. Treatment enterprises carry the certificate, facility, environmental-management, monitoring, data-reporting, disclosure, and retention duties. Organs, organizations, enterprises, and public institutions that discard covered equipment must use a qualified treatment enterprise and follow asset-write-off procedures; equipment involving state secrets follows separate secrecy rules.

- Producer/import role: use designs and materials that support resource use and less-harmful treatment and provide required hazardous-substance content and recovery information. Check fund matters only for periods before collection stopped on 1 January 2024.
- Seller, repair, and after-sales role: display recovery and treatment information prominently at the business premises. This display duty does not by itself make that actor a collector or treatment enterprise; assign those roles only when it performs the corresponding activity.
- Collector role: make collection convenient and transfer collected waste to a qualified treatment enterprise unless the collector holds the necessary treatment qualification.
- Treatment-enterprise role: operate within the certificate's category, facility, equipment, parameter, capacity, and validity boundaries; maintain pollution controls, an annual monitoring plan, routine emissions monitoring, and the data-information system, including required reporting and public disclosure; retain basic treatment data and monitoring reports for at least three years.
- Institutional holder role: use a qualified treatment enterprise, complete the applicable asset write-off, and follow state-secrecy rules where relevant. Keep the asset decision and transfer evidence separate from the operator's statutory treatment records.
- Failure consequence: unqualified treatment can lead to shutdown or closure, confiscation of illegal proceeds, and a CNY 50,000-500,000 fine. Missing product information, operator data controls, or routine monitoring has separate correction orders and possible fines.

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 7 and 10-19 allocate fund, product, display, collection, transfer, institutional-holder, treatment, monitoring, reporting, and retention duties; Articles 27-32 state the relevant information, unqualified-treatment, data, and monitoring consequences.
- [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 7, 11, 16, 19, and 20 define operator conditions, certificate boundaries, unqualified-treatment prohibitions, monitoring, reporting, and disclosure.
- [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) - Stopped fund collection on 1 January 2024 and ended the former fund subsidy for products treated from that date.

## Practical compliance steps

Create a role matrix for the China legal entity and every contractor. A commercial label such as 'recycler' does not show whether the contractor collects, transports, repairs, refurbishes, resells, or performs regulated treatment.

For each transfer, name the actor, activity, product category, quantity, origin, destination, and treatment facility. Collected covered waste must reach a qualified treatment enterprise, and a qualified enterprise may not provide or entrust it to an unqualified party for treatment. The contract can allocate evidence delivery, but it cannot transfer the operator's statutory duties to the customer.

- Record every role performed by the China entity and each contractor; duplicate duties can apply when one entity performs several roles.
- For producer and importer duties, keep product-design, material, and required information evidence with the responsible owner; retain any treatment-fund file only for the relevant pre-2024 period.
- For seller, repairer, and after-sales duties, verify that the required recovery and treatment information is displayed prominently at each relevant business premises. If the same entity also accepts returns, transfers waste, repairs units, or dismantles them, record those additional roles and apply their separate duties.
- For collector duties, document convenient collection and the transfer to a qualified treatment enterprise when the collector is not qualified to treat.
- For treatment duties, verify the certificate and retain the required environmental monitoring and treatment-data records. Amend a changed legal-person name, legal representative, or registered address within 15 working days after the business-registration change.
- Before adding a category, building a facility, altering or expanding a facility, or operating more than 20% above certified capacity, require the treatment enterprise to reapply through the original procedure and refresh the customer approval.
- Reassess the matrix when the catalogue, product, activity, entity, contractor, destination facility, or certificate changes.

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 10-19 support the actor-by-actor allocation and qualified transfer route.
- [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 and 19-20 support certificate review, change controls, prohibited onward treatment, monitoring, data reporting, and disclosure.

## Evidence to keep before launch or change approval

The regulation expressly requires treatment enterprises to report and retain basic treatment data for at least three years. The licensing measures require an annual monitoring plan, routine emissions monitoring, monitoring reports retained for at least three years, periodic treatment-data reporting to the issuing authority, and public disclosure.

The role matrix, scope note, certificate copy, contract, and handoff trail are practical control records rather than official forms prescribed by these two instruments.

- Catalogue and model scope note.
- Actor-role matrix with a named owner for each duty.
- Producer or importer product-information evidence and any fund-process evidence for the relevant pre-2024 period.
- Business-premises display check for sellers, repairers, and after-sales providers.
- Collection, transfer, shipment, receipt, destination, and quantity records. These are practical chain-of-custody controls rather than a universal national handoff form prescribed by the regulation or licensing measures.
- Treatment certificate, required treatment data, disclosures, monitoring plan, and monitoring reports.
- Change log and corrective-action record.

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 10-17 support the role allocation, qualified transfer, environmental monitoring, treatment reporting, and three-year basic-data retention.
- [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 19-20 support annual monitoring plans, monitoring-report retention for at least three years, data reporting, and public disclosure.

## Boundary with nearby China regimes

The producer's e-waste duties refer to national pollution-control requirements and hazardous-substance content information, but the e-waste regulation does not replace the separate China RoHS assessment. A treatment certificate also does not establish every hazardous-waste, transport, or treatment-fund requirement.

Link shared model, material, and actor facts while keeping separate decisions for product compliance, collection, treatment qualification, downstream waste classification, and fund administration.

- Calling producer collection mandatory when Article 11 states that it is encouraged.
- Treating a collector as qualified to dismantle products without checking the treatment certificate.
- Assigning the treatment enterprise's monitoring and reporting duties to the producer merely because the producer arranged the contract.

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 distinguish producer and importer duties, encouraged producer collection, business-premises display, collector duties, and qualified treatment.

*Put the requirement into practice*

*Placement: Before primary sources*

## Prepare the qualified disposal evidence file

Assign product, collection, transfer, treatment, monitoring, and reporting duties to the entities that perform them.

- [Map official sources to evidence](/solutions/research-copilot.md): Keep the actor matrix, producer or importer information, collector transfer, treatment certificate, monitoring, and data records together.
- [Review the China route](/contact.md): Check the China E-Waste Law scope decision and unresolved launch questions with Sorena.

## 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) - Use for waste electrical/electronic product recovery and disposal scope, producer and disposal duties, qualified treatment, recordkeeping, penalties, 1 January 2011 effective date, and 2019 revision.
- [Qualification Licensing Measures for Waste Electrical and Electronic Product Disposal](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - Adds detailed treatment-enterprise qualification, certificate, operating, monitoring, reporting, supervision, and enforcement duties.
- [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) - Current source for the 1 January 2024 end of treatment-fund collection and the former fund subsidy route.

## Related 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.
- [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.
- [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.


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