How is China RoHS different from China e-waste rules? Direct 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, environmental protection use period 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 treatment 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 treatment 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.

For China RoHS, the main release actors are designers, producers, importers, and sellers. For e-waste treatment, the key actors include producers, recovery operators, and qualified treatment enterprises. A company may hold duties under both regimes, but the duty must be traced to the correct role and lifecycle stage.

The China RoHS file should record scope, actor, substance and marking conclusions, catalogue status, applicable standard, conformity assessment, and release approval. The e-waste file should record the waste-catalogue trigger, responsible actor, recovery or treatment route, qualified operator where required, environmental records, and approval.

Do not treat the environmental protection use period as a warranty, a mandatory disposal date, or a substitute for e-waste duties. Under the China RoHS Measures, it is the period during normal use in which contained hazardous substances will not leak or suddenly change so as to cause serious environmental pollution or serious harm to people or property.

Reopen the China RoHS file when the model, function, voltage, material, supplier, actor, scope-exclusion facts, standard, catalogue entry, exception, or implementation date changes. Reopen the end-of-life file when waste status, treatment-catalogue coverage, collector, transfer route, treatment method, licence category, facility, equipment, or authorised capacity changes.