China RoHS controls covered products before and during market supply. China's e-waste rules govern listed products when they enter recovery and .
A China RoHS file cannot replace the separate checks for the e-waste catalogue, qualified processors, recovery routes, monitoring, and treatment records.
Run both analyses when a covered product is supplied in China and may later become waste. China RoHS answers whether the product's design, materials, information, marking, , and catalogue conformity route are compliant. The e-waste rules answer whether a listed waste product is recovered and treated through the required route. Keep the triggers, actors, decisions, and evidence separate.
Regulatory boundary
Product hazardous-substance controls are not disposal controls
Use the 2016 China RoHS Measures for product controls and the 2019-revised e-waste regulation plus licensing rules for catalogue-based recovery and .
Production, sale, or import within China of a product meeting the China RoHS definition and not within an applicable exclusion identified by the Measures or MIIT implementation guidance.
Articles 2-3 define treatment, exclude repair and refurbishment from that definition, and make the national treatment catalogue the regulation's scope trigger.
A product can pass the RoHS scope test before sale and later require a separate catalogue and activity test when discarded.
Producers and import consignees or their agents have product-information duties. The -fund payment duty in Article 7 stopped applying when fund collection ceased on 1 January 2024. Sellers, repair and service organisations, recovery businesses, users disposing of equipment, and qualified treatment enterprises have activity-specific duties.
Articles 7 and 10-19 assign producer, import-consignee or agent, seller, repair, service, recovery, disposal, and treatment-enterprise duties; Article 7's fund-payment text is subject to the later cessation announcement.
Catalogue decision, qualified-processor evidence, recovery and transfer records, controls, routine environmental monitoring, authority submissions, and treatment data retained for at least three years.
Reopen the product decision when the model, function, voltage, material, supplier, actor, scope-exclusion facts, marking standard, catalogue entry, exception, or implementation date changes.
Articles 11-16 require licence changes or a new application for specified changes, including added treatment categories, new or altered facilities, and treatment exceeding authorised capacity by more than 20%.
A product revision can affect both files, while a -facility change may affect only the e-waste route. Record which decision was reopened and why.
Trigger
China RoHS
Production, sale, or import within China of a product meeting the China RoHS definition and not within an applicable exclusion identified by the Measures or MIIT implementation guidance.
Articles 2-3 define treatment, exclude repair and refurbishment from that definition, and make the national treatment catalogue the regulation's scope trigger.
Operational implication
A product can pass the RoHS scope test before sale and later require a separate catalogue and activity test when discarded.
Main actors
China RoHS
Designers, producers, importers, and sellers have distinct product duties under the Measures.
Producers and import consignees or their agents have product-information duties. The -fund payment duty in Article 7 stopped applying when fund collection ceased on 1 January 2024. Sellers, repair and service organisations, recovery businesses, users disposing of equipment, and qualified treatment enterprises have activity-specific duties.
Articles 7 and 10-19 assign producer, import-consignee or agent, seller, repair, service, recovery, disposal, and treatment-enterprise duties; Article 7's fund-payment text is subject to the later cessation announcement.
Catalogue decision, qualified-processor evidence, recovery and transfer records, controls, routine environmental monitoring, authority submissions, and treatment data retained for at least three years.
Articles 7-20 detail the facilities, systems, personnel, licensing evidence, monitoring reports, and data reporting expected of treatment enterprises.
Operational implication
Link the same product identity across both files, but preserve separate sources, owners, decisions, and approvals.
Reassessment triggers
China RoHS
Reopen the product decision when the model, function, voltage, material, supplier, actor, scope-exclusion facts, marking standard, catalogue entry, exception, or implementation date changes.
Articles 11-16 require licence changes or a new application for specified changes, including added treatment categories, new or altered facilities, and treatment exceeding authorised capacity by more than 20%.
Operational implication
A product revision can affect both files, while a -facility change may affect only the e-waste route. Record which decision was reopened and why.
1
Section 1
Decide which rule applies to the activity
The China RoHS Measures apply to electrical and electronic products produced, sold, or imported in China when they meet the Measures' function-and-rated-voltage definition and no applicable exclusion identified by the Measures or MIIT implementation guidance applies. They assign duties to designers, producers, importers, and sellers for materials and processes, packaging, hazardous-substance information, marking, and the additional catalogue-based restriction and conformity route.
The 2019-revised e-waste regulation applies to recovery, , and related activities for waste products listed in the national Waste Electrical and Electronic Product Treatment Catalogue. Its treatment rules do not cover repair, refurbishment, or the resale of a repaired or refurbished product as second-hand goods.
The regimes overlap at product information and lifecycle planning. The e-waste regulation requires producers and importers to provide hazardous-substance content and recovery or information, while China RoHS Articles 13-15 specify product substance information and use-period marking. That overlap does not merge the two legal routes.
The China RoHS Measures took effect on 1 July 2016. The e-waste regulation took effect on 1 January 2011 and was revised in 2019; the -qualification licensing measures also took effect on 1 January 2011. These dates identify the legal instruments, but the current product catalogues, licence scope, facility changes, and later standards still need to be checked for the specific product and activity.
Product or regulatory team: record the China product definition, China activity, actor, applicable marking standard, RoHS catalogue status, implementation date, exception, and conformity result.
Recovery team: record whether the discarded product is in the e-waste catalogue, who collected it, and the qualified treatment enterprise that receives it.
enterprise: maintain the required qualification, routine environmental monitoring, data-information system, submissions to the local authority, and treatment data for at least three years.
Link both files to the same model or product family, but do not treat a RoHS mark, conformity result, or as permission to collect or treat waste.
Articles 2-3 and 9-18 establish China RoHS scope, actor duties, product information, use-period marking, catalogue management, and conformity assessment.
Articles 2-7, 10-17, and 22-24 establish the treatment definition, catalogue trigger, recovery and treatment system, actor duties, processor qualification, monitoring, data system, and three-year record period.
Articles 2-10 detail the scope, 1 January 2011 commencement, facility and management conditions, application, public notice, document review, site inspection, and licensing decision for treatment enterprises.
2
Section 2
Keep the release file and end-of-life file distinct
Before market release, the China RoHS file should support the exact product, revision, actor, substance-information presentation, , packaging conclusion, and any applicable catalogue restriction and conformity result.
When the product becomes waste, the end-of-life file should support catalogue coverage, the recovery chain, transfer to a qualified enterprise, treatment method, environmental controls, monitoring, and required treatment data. Organisations disposing of their own listed equipment should also keep transfer and asset write-off evidence where applicable.
A repaired or refurbished unit intended for second-hand sale needs a separate product-safety and second-hand marking analysis. The e-waste regulation excludes that activity from its definition, but it requires repaired products sold as second-hand goods to meet applicable mandatory health and safety specifications and to be visibly identified as second-hand.
Do not send recovered catalogue products to an unqualified person or enterprise for .
Do not assume that all electrical or electronic waste falls within this specific catalogue-based regulation; confirm the current catalogue entry and apply other waste and environmental rules where relevant.
Do not use a RoHS conformity result to approve a dismantling, material-recovery, or disposal method.
Articles 2-3 and 11-19 distinguish treatment from repair or refurbishment, require qualified treatment routes, address second-hand sales, and set treatment, monitoring, data, and environmental duties.
Articles 2-3 define treatment, exclude repair and refurbishment from that definition, and make the national treatment catalogue the regulation's scope trigger.
Articles 7 and 10-19 assign producer, import-consignee or agent, seller, repair, service, recovery, disposal, and treatment-enterprise duties; Article 7's fund-payment text is subject to the later cessation announcement.
Articles 11-17 and 22-24 establish qualified transfer and treatment, monitoring, data systems, three-year record retention, and processor licensing.
Official processor-qualification, licensing, supervision, monitoring, and reporting rules.
Articles 2-10 detail the scope, 1 January 2011 commencement, facility and management conditions, application, public notice, document review, site inspection, and licensing decision for treatment enterprises.
Articles 11-20 cover licence contents and changes, reapplication triggers, closure controls, prohibited unqualified treatment or transfer, supervision, monitoring reports, and data reporting.
2019-revised State Council regulation for catalogue-based recovery and treatment duties. Its Article 7 fund-payment framework must be read with the later cessation of fund collection.
Articles 2-7, 10-17, and 22-24 establish the treatment definition, catalogue trigger, recovery and treatment system, actor duties, processor qualification, monitoring, data system, and three-year record period.
Articles 2-3 and 11-19 distinguish treatment from repair or refurbishment, require qualified treatment routes, address second-hand sales, and set treatment, monitoring, data, and environmental duties.
Binding joint announcement that stopped collection of the treatment fund from 1 January 2024 and replaced new treatment subsidies with central special-fund support.
Articles 7-20 detail the facilities, systems, personnel, licensing evidence, monitoring reports, and data reporting expected of treatment enterprises.
Articles 11-16 require licence changes or a new application for specified changes, including added treatment categories, new or altered facilities, and treatment exceeding authorised capacity by more than 20%.
Primary source for the China RoHS side of the comparison.
Articles 2-3 and 9-18 establish China RoHS scope, actor duties, product information, use-period marking, catalogue management, and conformity assessment.