This is the English edition. The article body below is the publisher's English rendering of the original Chinese article; figures, license numbers and institutional names follow the original.

The National Hazardous Waste Inventory (2025 Edition) was published on November 26, 2024 and took effect on January 1, 2025. Under the inventory, waste printed circuit boards fall under "HW49 Other Wastes" with waste code 900-045-49 and are classified as hazardous waste.

Two Mandatory Requirements

  • Operations require a permit. Article 80, Paragraph 2 of the Solid Waste Pollution Prevention and Control Law is explicit: it is prohibited to engage in the collection, storage, utilization, or disposal of hazardous waste without a permit or in violation of permit provisions.
  • No handover to unlicensed parties. It is prohibited to provide or entrust hazardous waste to entities or other producers and operators that do not hold a permit for collection, storage, utilization, or disposal activities.

Penalties

Under Article 114, Paragraph 1 of the Solid Waste Pollution Prevention and Control Law, entities that engage in the collection, storage, utilization, or disposal of hazardous waste without a permit shall be ordered to correct by the ecological environment authority, fined between RMB 1 million and RMB 5 million, and — upon approval by the people's government with approval authority — ordered to suspend or close operations. Legal representatives, principal persons in charge, directly responsible supervisors, and other responsible individuals face fines of RMB 100,000 to RMB 1 million. Illegal discharge, dumping, or disposal of more than three tons of hazardous waste is subject to criminal liability.

Practical Tips

Home appliance repair shops, data center operators, and similar businesses generate small quantities of waste circuit boards on their own. Before obtaining a hazardous waste collection permit, such entities must not collect or store waste circuit boards themselves; they should entrust disposal to a unit licensed for waste circuit board operations and retain transfer vouchers. Storage must comply with the Standard for Pollution Control on Hazardous Waste Storage (GB 18597—2023) and identification signage requirements.

Three Generation Scenarios with Different Compliance Starting Points

Waste circuit boards appear in very different settings, and the trigger points for compliance obligations differ accordingly:

  • Manufacturers — offcuts and defective boards from circuit board processing and final assembly are hazardous waste generated in production; they must be included in the hazardous waste management plan, with generation, storage, and transfer volumes logged batch by batch.
  • Repair and decommissioning service providers — motherboards, power boards, and control boards replaced during service. These parties often handle equipment of multiple brands and categories, making mixed storage and over-extended storage periods the most common problems.
  • Data center and office renovations — boards retired along with entire batches of servers and network equipment; volumes are concentrated and large per event, typically requiring one-time clearance and manifest handover.

What the three scenarios share is this: generators do not need an operation permit, but must hand waste circuit boards to a licensed entity. The differences lie in how ledgers are kept and clearance is scheduled, not in the obligations themselves.

Four Points of Documentation from Generation to Disposal

Hazardous waste is tracked end to end by paperwork from generation to final disposal. If any link is missing, the generator cannot prove compliance:

  • Management plan and declaration — prepare a hazardous waste management plan annually and declare the types, quantities, and flows of waste generated to the local ecological environment authority.
  • Compliant storage — temporary storage sites must meet impermeability, leak-proofing, and signage requirements, with storage periods constrained by the permit and local regulations.
  • Transfer manifest — apply the hazardous waste transfer manifest system upon delivery; the categories, codes, and quantities on the manifest must match reality.
  • Disposal certificate recovery — the certificate issued by the licensed entity after disposal is the only valid proof a generator can show during environmental inspections and ESG disclosure.

The most common practical failure is not "failing to find a licensed entity" but a mismatch between manifest quantities and the ledger. This is checked in virtually every special inspection and is the easiest place for defects to appear.

Sources

Henan Provincial Department of Ecology and Environment, "A Letter to Operators of Waste Electrical and Electronic Equipment Recycling and Processing Province-wide": sthjt.henan.gov.cn; Tianjin Jinghai District Ecological Environment Bureau administrative penalty decision (Jin Jing Huan Fa [2026] No. 027): tjjh.gov.cn.