China RoHS controls covered products before and during market supply. China's e-waste rules govern listed products when they enter recovery and treatment.
A China RoHS file cannot replace the separate checks for the e-waste treatment catalogue, qualified processors, recovery routes, monitoring, and treatment records.
Structured answer sets in this page tree.
Cited legal and guidance references.
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.
Use the 2016 China RoHS Measures for product controls and the 2019-revised e-waste regulation plus licensing rules for catalogue-based recovery and .
Product design, production, import, sale, information, marking, catalogue, and conformity duties.
Recovery, transfer, qualified , environmental controls, monitoring, and treatment data for listed waste products.
| Dimension | China RoHS | China e-waste | Operational implication |
|---|---|---|---|
| Trigger | Production, sale, or import within China of a product meeting the China RoHS definition. | Recovery, , or a related activity involving a waste product listed in the national e-waste treatment catalogue. | A product can pass the RoHS scope test before sale and later require a separate catalogue and activity test when discarded. |
| Main actors | Designers, producers, importers, and sellers have distinct product duties under the Measures. | Producers and importers have information and fund duties; sellers, repair and service organisations, recovery businesses, users disposing of equipment, and qualified enterprises have activity-specific duties. | Assign the market-release decision and the recovery or decision to the teams that control those activities. |
| Required outputs and evidence | Applicable product marking and instructions, hazardous-substance information, , packaging conclusion, and any required catalogue conformity result. | Catalogue decision, qualified-processor evidence, recovery and transfer records, controls, routine environmental monitoring, authority submissions, and treatment data retained for at least three years. | Link the same product identity across both files, but preserve separate sources, owners, decisions, and approvals. |
| Reassessment triggers | Reopen the product decision when the model, function, voltage, material, supplier, actor, marking standard, catalogue entry, exception, or implementation date changes. | Reopen the end-of-life decision when waste status, -catalogue coverage, collector, transfer route, treatment method, licence category, facility, equipment, or authorised capacity changes. | 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. |
Production, sale, or import within China of a product meeting the China RoHS definition.
Recovery, , or a related activity involving a waste product listed in the national e-waste treatment catalogue.
A product can pass the RoHS scope test before sale and later require a separate catalogue and activity test when discarded.
Designers, producers, importers, and sellers have distinct product duties under the Measures.
Producers and importers have information and fund duties; sellers, repair and service organisations, recovery businesses, users disposing of equipment, and qualified enterprises have activity-specific duties.
Assign the market-release decision and the recovery or decision to the teams that control those activities.
Applicable product marking and instructions, hazardous-substance information, , packaging conclusion, and any required catalogue conformity result.
Catalogue decision, qualified-processor evidence, recovery and transfer records, controls, routine environmental monitoring, authority submissions, and treatment data retained for at least three years.
Link the same product identity across both files, but preserve separate sources, owners, decisions, and approvals.
Reopen the product decision when the model, function, voltage, material, supplier, actor, marking standard, catalogue entry, exception, or implementation date changes.
Reopen the end-of-life decision when waste status, -catalogue coverage, collector, transfer route, treatment method, licence category, facility, equipment, or authorised capacity changes.
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.
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. 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.
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.
Connect the same product identity to distinct RoHS and end-of-life conclusions.