Short answer
China RoHS applies to covered electrical and electronic products produced, sold, or imported in China, subject to the exclusion in the Measures and additional use-specific exclusions identified in MIIT implementation guidance. It addresses design and materials, applicable substance standards, packaging, hazardous-substance information, marking, seller controls, and a catalogue-based limit and conformity-assessment layer.
The e-waste Regulation applies to products in the Waste Electrical and Electronic Product Disposal Catalogue after they become waste. It establishes recovery and centralised controls, producer information duties, and qualification requirements for treatment operators. Although Article 7 established a treatment-fund payment duty, collection of that fund stopped on 1 January 2024 and central special-fund support replaced subsidies for newly treated products. A China RoHS conclusion does not decide whether the waste-product catalogue or treatment rules apply.
Repair, refurbishment, and resale after repair or refurbishment are outside the e-waste regulation's definition. A repaired product sold as second-hand goods must still meet the applicable mandatory health and safety specifications and be visibly identified as second-hand. If a recovery business dismantles or otherwise treats a catalogue product, it must hold the treatment qualification; without that qualification, it must transfer the recovered product to a qualified treatment enterprise.
Articles 2, 9 to 18, and 23 establish the China RoHS lifecycle stage, covered activities, actor duties, marking and disclosure, catalogue layer, and 1 July 2016 commencement.
Official explanatory guidance. Question 11 identifies additional use-specific China RoHS scope exclusions.
Binding e-waste source for the disposal-catalogue trigger, treatment definition and repair/refurbishment exclusion, second-hand marking, recovery and centralised treatment system, producer and recovery-operator duties, the original treatment-fund framework, treatment qualification, and supervision.
Binding joint announcement that stopped collection of the treatment fund from 1 January 2024 and replaced new treatment subsidies with central special-fund support.