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China E-Waste Law e-waste recovery and disposal requirements

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

Start with catalogue scope and the legal definition of , then apply the duties, deadlines, evidence, exceptions, and change triggers for the actor that performs each role.

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Author
Sorena AI
Published
Jul 5, 2026
Updated
Oct 15, 2026
4 sections6 primary sources
Overview

China's e-waste framework applies to recovery, , and related activities for discarded products within the . It does not impose the same duty on every actor: scope the model against the full catalogue entry, classify the activity, identify who performs each role, and route covered treatment to a qualified enterprise.

Section 1

What China e-waste rules require in practice

China's framework combines a catalogue trigger, multi-channel collection, centralized qualified , role-specific duties, and environmental supervision. The regulation created a , but collection stopped on 1 January 2024. Except for a provincially approved under Article 34, an enterprise may perform covered treatment only after obtaining the .

The regulation and licensing measures have applied since 1 January 2011. The regulation was revised on 2 March 2019; that revision date is historical context, not a future implementation deadline. Regional development plans are revised every five years, and a plan revision triggers authority review and certificate replacement for operators that intend to continue and pass the review.

  • Match the discarded product to the full catalogue category definition and limits, then decide whether the activity is rather than excluded repair, refurbishment, or second-hand reuse. Representative boundaries include refrigerator volume <=800 litres, room-air-conditioner cooling output <=14,000 W, washing capacity <=10 kg, electric-water-heater capacity <=500 litres, gas-water-heater heat load <=70 kW, and printer or copier format smaller than A2 at <=80 pages per minute.
  • Identify producer/import, seller/repair, collector, and -enterprise duties separately.
  • Use a whose certificate covers the relevant legal person, facility, waste category, equipment, operating parameters, capacity, and validity period. Except for the narrow Article 34 route for a provincially approved meeting its stated pollution-control and planning conditions, covered without the qualification is prohibited.
  • For operations, maintain pollution controls, emergency measures, competent personnel, routine environmental monitoring, and a data-information system with required reporting and public disclosure. Keep the operator's routine monitoring separate from the authority's supervisory monitoring, which the licensing measures require at least once every six months. has applied since 1 March 2026 and replaced HJ 527-2010.
  • Do not import waste electrical or electronic products whose import is prohibited by the state; collection, storage, transport, and must also follow applicable environmental-protection and sanitation rules.
  • A must keep its basic data for at least three years. The licensing measure also requires monitoring reports to be kept for at least three years.
  • Unqualified can lead to shutdown or closure, confiscation of illegal proceeds, and a CNY 50,000-500,000 fine. Missing required product information, data systems or reports, basic-data retention, or routine monitoring has separate correction orders and possible fines.
Section 2

Practical compliance steps

Map each requirement to the actor that performs it. Producers, import consignees, or their agents address design, material, and product-information duties. Their former -fund payment process applies only to periods before 1 January 2024. Sellers, repairers, and after-sales providers display recovery and treatment information. Collectors provide convenient collection and must transfer covered waste to a qualified unless they hold the . Since 15 August 2026, Environmental Code Article 978 requires electrical and electronic product producers, in accordance with state rules, to establish and publicly disclose a waste-product recovery system matched to product sales volume and fulfil recovery and utilization responsibilities.

For a , certificate conditions are operating boundaries. A changed legal-person name, legal representative, or registered address requires an amendment application to the original issuing authority within 15 working days after the business-registration change. Adding a product category, building a new facility, altering or expanding an existing facility, or treating more than 20% above certified capacity requires a new application through the original procedure.

  • Producer or importer: use designs and materials that support resource use and less-harmful and provide the required hazardous-substance content and recovery information. The former fund-payment process is relevant only to periods before 1 January 2024. Producers must also establish and publicly disclose the Article 978 recovery system.
  • Seller, repairer, or after-sales provider: display recovery and information prominently at the business premises.
  • Collector: provide convenient collection and transfer covered waste to a qualified unless the collector itself is qualified to treat it.
  • Institution, group, enterprise, or public-service unit: use a qualified and follow applicable asset-write-off and state-secrecy procedures.
  • : operate within the certificate; maintain facilities, pollution controls, environmental management, an annual monitoring plan, routine emissions monitoring, and data systems; report and publish required information; and retain basic data and monitoring reports for at least three years. Cooperate with written and on-site supervision; do not treat the authority's supervisory monitoring as a substitute for the operator's own monitoring.
  • ending operations: control pollution at the site, properly handle untreated waste, apply for cancellation within 20 days after taking those measures, support the authority's on-site inspection, and complete the required environmental investigation, risk assessment, and any necessary remediation.
  • All collectors, storers, transporters, and actors: follow applicable environmental-protection and sanitation requirements.
Section 3

Evidence to keep before launch or change approval

The binding records in these instruments fall mainly on the : its data-information system, periodic reports to the issuing authority, public disclosure, basic data retained for at least three years, annual monitoring plan, and monitoring reports retained for at least three years.

For other actors, a catalogue scope note, role matrix, certificate copy, contract, shipment record, receipt, and change log are practical evidence. These instruments do not prescribe one universal compliance file or handoff form.

  • Catalogue entry and model-specification mapping.
  • Activity classification and actor-role matrix.
  • For producers, retain the recovery-system design, sales-volume basis, public disclosure, responsible owner, and implementation evidence.
  • certificate and verification record.
  • Contract, shipment, receipt, quantity, and destination evidence.
  • -enterprise data, reports, disclosures, monitoring plan, and retained monitoring reports.
  • Exception with its legal basis and approval, corrective-action record, and change-review record for catalogue, model, activity, entity, facility, category, equipment, capacity, certificate, and downstream-route changes.
Section 4

Boundary with nearby China regimes

The regulation refers to product pollution-control rules and required hazardous-substance content and recovery information, but it does not replace the separate analysis. Nor does a decide every hazardous-waste, transport, import, performance, or funding question.

Use the same verified model and material facts where relevant, but keep separate conclusions for product restrictions, catalogue scope, , downstream waste classification, and fund administration.

  • Assuming every electrical or electronic product is in the catalogue.
  • Confusing the Regulation's encouraged collection provision with the separate binding producer recovery-system duty under Environmental Code Article 978.
  • Treating a recycler label, collection invoice, or sustainability claim as proof of qualified .
  • Treating the former producer/importer fund payment as a current duty after collection stopped on 1 January 2024, or treating the cessation announcement as removing the remaining catalogue, qualification, monitoring, reporting, and recordkeeping duties.
Put the requirement into practice

Prepare the qualified disposal evidence file

Assign each China e-waste duty to the entity that performs the role and retain the supporting records.

Research workflow
Map official sources to evidence

Keep the catalogue scope, activity classification, qualification boundary, HJ 527-2026 controls, and operator records together.

Explore next step
Talk to Sorena
Review the China route

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

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Primary sources

References and citations

Regulation on Recovery and Disposal of Waste Electrical and Electronic Products
mee.gov.cn5 citations
Referenced sections
  • 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.
  • Articles 2-7 and 10-19 establish scope, the treatment definition, collection and qualified-treatment systems, fund duties, actor duties, monitoring, reporting, and basic-data retention; Articles 27-32 state the relevant information, unqualified-treatment, data, and monitoring consequences.
  • Articles 10-19 allocate the product, display, collection, institutional-holder, treatment, monitoring, reporting, and general environmental duties by actor.
Show 2 more
  • Articles 16-17 require routine monitoring, treatment-data reporting, and retention of basic treatment data for at least three years.
  • Articles 3, 7, and 10-12 distinguish catalogue scope, fund duties, pollution-control information, encouraged collection, and qualified treatment.
Qualification Licensing Measures for Waste Electrical and Electronic Product Disposal
mee.gov.cn4 citations
Referenced sections
  • Sets detailed treatment qualification, certificate, operating, monitoring, reporting, supervision, and enforcement requirements.
  • Articles 3, 7, 11, 14, 16, 19, and 20 establish the five-year regional-plan cycle, review after plan revision, operator conditions, certificate boundaries, unqualified-treatment prohibitions, operator and supervisory monitoring, monitoring-report retention, reporting, and public disclosure.
  • Articles 12-16 define certificate amendment, reapplication, replacement, termination, and prohibited treatment.
Show 1 more
  • Articles 19-20 require an annual monitoring plan, monitoring reports retained for at least three years, a data-information system, reporting, and public disclosure.

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