---
title: "China RoHS vs China e-waste rules"
canonical_url: "https://www.sorena.io/artifacts/apac/china-rohs-regulation/china-rohs-vs-china-e-waste"
source_url: "https://www.sorena.io/artifacts/apac/china-rohs-regulation/china-rohs-vs-china-e-waste"
author: "Sorena AI"
description: "Compare China RoHS product duties with China's separate recovery, treatment, processor-licensing, and end-of-life evidence requirements."
published_at: "2026-07-05"
updated_at: "2026-07-24"
keywords:
  - "China RoHS vs China e-waste"
  - "hazardous substances"
  - "electrical electronic products"
  - "China RoHS"
  - "China e-waste"
  - "Product compliance"
---
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---

# China RoHS vs China e-waste rules

Compare China RoHS product duties with China's separate recovery, treatment, processor-licensing, and end-of-life evidence requirements.

*Comparison* *China*

## China RoHS and e-waste are separate

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.

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, environmental protection use period, 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.

## Definitions

### Environmental protection use period

The China RoHS Measures define this as the period during which hazardous substances in an electrical or electronic product will not leak or suddenly change, seriously pollute the environment, or seriously harm a user's person or property when the product is used normally according to its instructions. The producer or importer determines the period and marks it under the applicable standard.

**Why it matters here:** This is product information for normal use under China RoHS. It is not a warranty, a mandatory discard date, a processor licence, or proof that the product may enter any particular recovery or treatment route.

Sources:

- [Measures for Restriction of Hazardous Substances in Electrical and Electronic Products](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io)

### Treatment of waste electrical and electronic products

**Term:** treatment

Under the e-waste regulation, treatment includes dismantling waste electrical and electronic products, extracting material for use as raw material or fuel, changing physical or chemical characteristics to reduce the amount or hazardous content of the waste, and final placement in an environmentally compliant landfill.

**Why it matters here:** Repair, refurbishment, and reuse as second-hand goods after repair or refurbishment are outside this treatment definition. A recovery business that carries out treatment must hold the required treatment qualification; otherwise it must transfer the recovered products to a qualified treatment enterprise.

Sources:

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

## 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 treatment.

- **China RoHS**: Product design, production, import, sale, information, marking, catalogue, and conformity duties.
- **China e-waste**: Recovery, transfer, qualified treatment, environmental controls, monitoring, and treatment data for listed waste products.

| Dimension | China RoHS | China e-waste | Operational implication | Sources |
| --- | --- | --- | --- | --- |
| Trigger | Production, sale, or import within China of a product meeting the China RoHS definition. | Recovery, treatment, 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. | [China RoHS Measures](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Articles 2-3.<br>[China e-waste recovery and disposal regulation](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - Articles 2-3 define treatment, exclude repair and refurbishment from that definition, and make the national treatment catalogue the regulation's scope trigger. |
| 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 treatment enterprises have activity-specific duties. | Assign the market-release decision and the recovery or treatment decision to the teams that control those activities. | [China RoHS Measures](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Articles 9-18.<br>[China e-waste recovery and disposal regulation](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - Articles 7 and 10-19 assign producer, importer, seller, repair, service, recovery, disposal, and treatment-enterprise duties. |
| Required outputs and evidence | Applicable product marking and instructions, hazardous-substance information, environmental protection use period, packaging conclusion, and any required catalogue conformity result. | Catalogue decision, qualified-processor evidence, recovery and transfer records, treatment 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. | [China RoHS Measures](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Articles 12-18 establish packaging, product information, use-period marking, catalogue, substance-limit, and conformity-assessment outputs.<br>[China e-waste recovery and disposal regulation](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - Articles 11-17 and 22-24 establish qualified transfer and treatment, monitoring, data systems, three-year record retention, and processor licensing.<br>[China e-waste treatment qualification licensing measures](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - Articles 7-20 detail the facilities, systems, personnel, licensing evidence, monitoring reports, and data reporting expected of treatment enterprises. |
| 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, treatment-catalogue coverage, collector, transfer route, treatment method, licence category, facility, equipment, or authorised capacity changes. | A product revision can affect both files, while a treatment-facility change may affect only the e-waste route. Record which decision was reopened and why. | [China RoHS Measures](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Articles 2-3 and 9-18 identify the product, actor, standard, marking, catalogue, exception, and conformity facts that control the China RoHS decision.<br>[China e-waste treatment qualification licensing measures](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - 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%. |

Sources for Trigger - China RoHS:

- [China RoHS Measures](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Articles 2-3.

Sources for Trigger - China e-waste:

- [China e-waste recovery and disposal regulation](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - Articles 2-3 define treatment, exclude repair and refurbishment from that definition, and make the national treatment catalogue the regulation's scope trigger.

Sources for Main actors - China RoHS:

- [China RoHS Measures](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Articles 9-18.

Sources for Main actors - China e-waste:

- [China e-waste recovery and disposal regulation](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - Articles 7 and 10-19 assign producer, importer, seller, repair, service, recovery, disposal, and treatment-enterprise duties.

Sources for Required outputs and evidence - China RoHS:

- [China RoHS Measures](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Articles 12-18 establish packaging, product information, use-period marking, catalogue, substance-limit, and conformity-assessment outputs.

Sources for Required outputs and evidence - China e-waste:

- [China e-waste recovery and disposal regulation](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - Articles 11-17 and 22-24 establish qualified transfer and treatment, monitoring, data systems, three-year record retention, and processor licensing.
- [China e-waste treatment qualification licensing measures](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - Articles 7-20 detail the facilities, systems, personnel, licensing evidence, monitoring reports, and data reporting expected of treatment enterprises.

Sources for Reassessment triggers - China RoHS:

- [China RoHS Measures](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Articles 2-3 and 9-18 identify the product, actor, standard, marking, catalogue, exception, and conformity facts that control the China RoHS decision.

Sources for Reassessment triggers - China e-waste:

- [China e-waste treatment qualification licensing measures](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - 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%.

## 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. They assign duties to designers, producers, importers, and sellers for materials and processes, packaging, hazardous-substance information, environmental protection use period marking, and the additional catalogue-based restriction and conformity route.

The 2019-revised e-waste regulation applies to recovery, treatment, 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 treatment 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 treatment-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 treatment catalogue, who collected it, and the qualified treatment enterprise that receives it.
- Treatment 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 environmental protection use period as permission to collect or treat waste.

Sources for this answer:

- [Measures for Restriction of Hazardous Substances in Electrical and Electronic Products](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Articles 2-3 and 9-18 establish China RoHS scope, actor duties, product information, use-period marking, catalogue management, and conformity assessment.
- [Regulation on the Administration of the 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 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.
- [Measures for Qualification Licensing for Waste Electrical and Electronic Product Disposal](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - 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.

## 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, environmental protection use period, 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 treatment 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 treatment 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 treatment.
- 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.

Sources for this answer:

- [Regulation on the Administration of the 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 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.
- [Measures for Qualification Licensing for Waste Electrical and Electronic Product Disposal](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - Articles 11-20 cover licence contents and changes, reapplication triggers, closure controls, prohibited unqualified treatment or transfer, supervision, monitoring reports, and data reporting.

*Keep lifecycle decisions separate*

*Placement: Before primary sources*

## Review the China RoHS product file

Connect the same product identity to distinct RoHS and end-of-life conclusions.

- [Map sources to evidence](/solutions/research-copilot.md): Keep each regime's trigger, actor, source, and approval distinct.
- [Review unresolved scope](/contact.md): Check the product and lifecycle boundaries before release.

## Primary sources

- [Measures for Restriction of Hazardous Substances in Electrical and Electronic Products](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Primary source for the China RoHS side of the comparison.
- [Regulation on the Administration of the Recovery and Disposal of Waste Electrical and Electronic Products](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - 2019-revised State Council regulation for catalogue-based recovery and treatment duties.
- [Measures for Qualification Licensing for Waste Electrical and Electronic Product Disposal](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - Official processor-qualification, licensing, supervision, monitoring, and reporting rules.
- [China RoHS Measures](https://www.gov.cn/zhengce/2022-08/23/content_5722699.htm?ref=sorena.io) - Articles 2-3 and 9-18 identify the product, actor, standard, marking, catalogue, exception, and conformity facts that control the China RoHS decision.
- [China e-waste recovery and disposal regulation](https://www.mee.gov.cn/ywgz/fgbz/xzfg/201909/t20190918_734319.shtml?ref=sorena.io) - Articles 11-17 and 22-24 establish qualified transfer and treatment, monitoring, data systems, three-year record retention, and processor licensing.
- [China e-waste treatment qualification licensing measures](https://www.mee.gov.cn/gzk/gz/202112/t20211210_963734.shtml?ref=sorena.io) - 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%.

## Related Topic Guides

- [China RoHS compliance checklist](/artifacts/apac/china-rohs-regulation/checklist.md): Release checklist for China RoHS scope, actor duties, marking, disclosure, the 2026 catalogue, exceptions, conformity assessment, and transition dates.
- [China RoHS deadlines and compliance calendar](/artifacts/apac/china-rohs-regulation/deadlines-and-compliance-calendar.md): China RoHS legal dates, product-release triggers, catalogue timing, and evidence to review before production, import, or sale in China.
- [China RoHS FAQ](/artifacts/apac/china-rohs-regulation/faq.md): Practical China RoHS answers on product scope, actor duties, marking and disclosure, supplier evidence, the 2026 catalogue, the 2027 standard transition, EU RoHS, and e-waste.
- [China RoHS marking and disclosure evidence](/artifacts/apac/china-rohs-regulation/marking-and-disclosure-evidence.md): How to choose and document China RoHS product marks, substance information, environmental protection use period, and catalogue evidence.
- [China RoHS penalties and enforcement exposure](/artifacts/apac/china-rohs-regulation/penalties-and-fines.md): China RoHS Article 19 violations, responsible actors, enforcement boundaries, and why the Measures do not provide one universal fine amount.
- [China RoHS requirements](/artifacts/apac/china-rohs-regulation/requirements.md): China RoHS duties by actor, including product controls, packaging, marking, disclosure, the 2026 catalogue, exceptions, and conformity-assessment transitions.
- [China RoHS supplier declaration template](/artifacts/apac/china-rohs-regulation/china-rohs-supplier-declaration-template.md): A voluntary China RoHS supplier declaration template with fields for part coverage, substances, evidence, exceptions, and change control.
- [China RoHS supplier material declaration checklist](/artifacts/apac/china-rohs-regulation/supplier-material-declaration-checklist.md): A China RoHS checklist for supplier declarations, BOM mapping, substance evidence, catalogue status, and change control.
- [China RoHS vs EU RoHS](/artifacts/apac/china-rohs-regulation/china-rohs-vs-eu-rohs.md): Compare China RoHS and EU RoHS scope, substance limits, exemptions, marking, conformity routes, actors, and evidence without treating one decision as proof of the other.
- [Covered electrical and electronic products under China RoHS](/artifacts/apac/china-rohs-regulation/covered-electrical-electronic-products.md): Apply the China RoHS function, rated-voltage, China-activity, supporting-product, and electricity-system exclusion tests before checking the 2026 catalogue.
- [Does China RoHS cover my electrical or electronic product?](/artifacts/apac/china-rohs-regulation/faq/does-china-rohs-cover-my-electrical-electronic-product.md): Start with the China RoHS legal definition and product facts. Keep a covered-product note before collecting supplier material declarations or preparing marking/disclosure evidence.
- [How is China RoHS different from China e-waste rules?](/artifacts/apac/china-rohs-regulation/faq/how-is-china-rohs-different-from-china-e-waste-rules.md): China RoHS addresses hazardous substances, marking and disclosure before or during market placement; China e-waste rules address recovery and disposal at end of life.
- [Is China RoHS the same as EU RoHS?](/artifacts/apac/china-rohs-regulation/faq/is-china-rohs-the-same-as-eu-rohs.md): No. China RoHS and EU RoHS overlap in substance control but use different scope rules, exclusions, actors, marking and disclosure outputs, conformity routes, and transition dates.
- [What is China RoHS marking and disclosure evidence?](/artifacts/apac/china-rohs-regulation/faq/what-is-china-rohs-marking-and-disclosure-evidence.md): Keep the approved China RoHS mark or instructions, hazardous-substance disclosure, environmental protection use period rationale, technical support, and release approval for the exact model.
- [What supplier evidence should we keep for China RoHS?](/artifacts/apac/china-rohs-regulation/faq/what-supplier-evidence-should-we-keep-for-china-rohs.md): Keep supplier declarations and test evidence traceable to the exact part, material, site, revision, substance conclusion, and finished China model. Supplier data supports, but does not replace, the product-level China RoHS decision.


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