Explanation of the Extended Producer Responsibility System

If you are an overseas practitioner engaged in charging products such as chargers, charging cables, and wireless chargers, and plan to commercially launch your products in the Chinese market, you have most likely heard of the term “Extended Producer Responsibility”. Some say it is just paying a recycling and treatment fee, some say it is exactly the same as the EU WEEE system, and others say all products with a USB interface must comply. Most of these statements are inaccurate, and may even lead you to compliance pitfalls.

This article focuses on charging products, and explains China’s Extended Producer Responsibility system thoroughly from the most basic concepts to directly implementable judgment methods — entry-level users can understand the core logic and make preliminary judgments, while readers with certain experience can also find key points to avoid pitfalls and comparison of differences.

I. First, Get the Basics Right: Core Framework of China’s EPR

Extended Producer Responsibility (EPR for short) is essentially a set of environmental protection systems: it requires producers to bear corresponding environmental responsibilities for links such as product design, production, distribution, use, and post-abandonment recycling and treatment within the scope prescribed by law. Specific obligations are determined by applicable laws and regulations, product catalogs, and special rules. But you must not understand it as “a certificate”, “a fee”, or “a one-time registration” — its obligations are not unified, but are triggered respectively by specific laws and regulations, product catalogs, departmental rules, and even local pilot rules.

There are several basic boundaries that you must keep in mind first to avoid going astray at the very beginning:

First, there is no absolute rule that “as long as a product is launched into the Chinese market, all environmental protection costs must be borne”; responsibilities are allocated according to legal identity and product type.

Second, the obligations for charging products must be judged in combination with specific types, sales models, and applicable rules, and it cannot be presumed that all EPR obligations must be fulfilled solely on the grounds that they “belong to electronic products”.

Third, you must never directly apply the logic of overseas systems such as EU WEEE; the core logic of the two is similar, but the specific rules are very different.

Official Regulatory System and Correct Verification Methods

China’s environmental protection regulations have clear levels of legal effect, and lower-level rules cannot conflict with higher-level laws. When you look up rules, you should follow the order from highest to lowest level:

Law: The Law of the People’s Republic of China on the Prevention and Control of Environmental Pollution by Solid Waste is the superior law of the EPR system, that is, the general basis for all relevant rules;
Administrative regulations / departmental rules: For example, the Regulations on the Administration of Recycling and Treatment of Waste Electrical and Electronic Products formulated by the State Council, and departmental rules formulated by relevant departments of the State Council in accordance with laws and administrative regulations;
Catalogs / announcements: For example, the catalog for the treatment of waste electrical and electronic products, and regulatory announcements. Such documents are dynamically adjusted and directly determine whether your product is within the scope of a specific system;
Local pilot rules: Some regions have special pilot requirements, which only apply within the pilot areas;
Standards, group standards, enterprise commitments: Such documents do not automatically generate administrative obligations, and only need to be complied with when explicitly cited by laws and regulations.

In addition to the rules under the framework of the Solid Waste Law, several special environmental protection rules related to charging products should also be taken into consideration, such as China RoHS (Restriction of Hazardous Substances in Electrical and Electronic Products), battery pollution prevention and control regulations, and packaging solid waste management regulations.

When checking rules, you must use official channels, and do not trust the one-sided statements of self-media or third-party institutions. The verification order is based on priority:

First step: Check the National Database of Laws and Regulations to confirm the validity and latest revision status of laws and administrative regulations;
Second step: Check the official websites of national competent authorities (such as the official websites of the Ministry of Ecology and Environment, the Ministry of Industry and Information Technology, and the State Administration for Market Regulation) to verify product catalogs, regulatory announcements, and official policy interpretations;
Third step: If local pilots are involved, check local official channels to confirm local requirements;
Fourth step: If standards are involved, check the National Standards Public Platform to verify the version of applicable standards.

Special reminder: For each query, you must record the query date, page link, document number, and version number, and keep screenshots if necessary, which will be used for subsequent compliance inspection.

It Is Not the Same as the Environmental Protection / Certifications You Are Familiar With

Many people confuse EPR with 3C, RoHS, etc. that they have heard before. In fact, their control scopes are completely different and cannot replace each other:

Common Concept	Core of Control	Relationship with EPR
3C Safety Certification	Electrical safety and electromagnetic compatibility of products	Completely different systems; 3C does not cover environmental protection responsibilities
China RoHS	Toxic and hazardous substances in electrical and electronic products	Related to EPR but not the same system; China RoHS mainly controls the restriction of use, labeling, and conformity assessment of hazardous substances in electrical and electronic products, and its scope of application shall be judged separately according to RoHS rules
Factory Environmental Protection Requirements	Pollution discharge during factory production processes	Only covers the production link, while EPR covers the entire product life cycle
Single Recycling Fee	Only paying treatment fees	EPR includes multiple types of responsibilities such as design, recycling, and information disclosure, not just paying money

How to Draw the Responsibility Boundaries of Different Roles?

The legal subject of responsibility for EPR is determined according to the applicable system and actual operation / import facts. There is a general principle to remember: the two parties to cooperation can allocate commercial responsibilities in the contract (for example, agreeing on who will pay for recycling), but they cannot use the contract to override statutory responsibilities — whoever the law stipulates as the subject of responsibility shall bear the final compliance obligations, and cannot shift the blame through the contract.

The responsibilities of common roles are roughly as follows:

Producer / brand owner: Bears primary responsibility under most systems, such as environmentally friendly product design, implementation of responsibility fulfillment plans, information disclosure, etc.;
Domestic agent / importer: For imported products, they shall bear statutory responsibilities for the import link in accordance with corresponding regulations, but there is no unified rule that “if there is no subject overseas, the importer shall bear all responsibilities”; the specific situation depends on the requirements of corresponding regulations;
Cross-border e-commerce entities: Cannot be generalized; you must first clearly identify all roles such as the declarant, seller, platform, brand owner, and domestic service provider, and then correspond to the responsibility requirements of specific regulations;
Consumers: Only need to discard waste products through formal channels, and do not need to bear enterprise-level responsibilities such as fee payment and system construction;
Treatment enterprises: Must have corresponding legal qualifications, and carry out recycling, dismantling, and treatment work in accordance with regulations.

II. Does Your Charging Product Need to Comply? Judgment Matrix

This part is the most practical; you can check your own product step by step. First, a core conclusion: common independent charging products (such as wall chargers, charging cables, wireless charging pads, power banks) usually do not fall under the Catalog for the Treatment of Waste Electrical and Electronic Products (hereinafter referred to as the “Treatment Catalog”), but not being in the Treatment Catalog does not mean there are no environmental protection obligations. You also need to check other requirements such as China RoHS, packaging management, waste battery management, recycling and disposal, and local pilots. If it is an accessory sold as a gift with a complete machine that is in the catalog, you must also separately judge the obligations of the complete machine and the rules of the accessory itself.

First Pass Two Checks: Determine the General Boundaries

Before making a judgment, first pass two core judgment axes. The first axis is used to judge the obligations of producers, importers, etc. that may be triggered during the stage of product launch into the Chinese market; the second axis is used to judge the rules for recycling, transfer, and treatment of products after they are discarded, and cannot be used as a condition for uniformly excluding obligations during the market launch stage.

First axis: Whether the product is commercially launched into the Chinese market

When making a determination, you need to look at the nature of sales (commercial sales or personal use), transaction mode, product status (brand new or after-sales accessories), and form (complete machine or accessory).

A small amount of inbound goods that are truly personal items, for non-operational personal use, and do not constitute commercial launch, usually do not bear corresponding production and operation responsibilities as enterprise producers or importers; however, obligations for cross-border e-commerce operational sales, general trade import, product safety, transportation, customs, and post-abandonment waste management shall still be checked separately.

If the product is only produced and sold for overseas markets and does not enter the Chinese market at all, naturally there is no need to comply with China’s EPR requirements.

Second axis: Whether the product becomes waste within the territory of China

It depends on the place where the waste is generated and the nature of the waste. If the product is only in transit or transshipment and will not eventually be discarded in China, it usually does not involve responsibilities for waste recycling, transfer, and treatment within China. However, this does not of course exclude product labeling, RoHS, packaging, or other special requirements that may apply during the stage of product launch into the Chinese market.

Compliance Comparison Table for Common Charging Products

After passing the two checks, you can use the table below to make a preliminary judgment on the situation of your product:

Product Type	Usually Falls Under the Treatment Catalog?	Key Requirements to Check
Independent wall-plug charger / power adapter	No	China RoHS tiered requirements, packaging rules; no need to check battery rules if there is no battery
USB / USB-C charging cable / data cable	No	China RoHS tiered requirements; no need to check battery rules for passive products
Wireless charging pad without built-in battery	No	China RoHS tiered requirements, packaging rules; no need to check battery rules
USB hub with charging function	No	China RoHS tiered requirements, packaging rules; no need to check battery rules if there is no built-in battery
Power bank / portable charging device with lithium battery	No	China RoHS tiered requirements, battery-related rules, packaging rules
Non-removable power module built into the complete machine	Subject to the complete machine	RoHS and battery rules are determined based on whether they are sold / imported separately

How to Judge Boundary Products?

There are several types of products that cannot directly apply the above conclusions and need to be judged separately:

Industrial, military, and medical special charging equipment: Shall be judged according to the corresponding regulatory scope and use; some have special environmental protection rules, and cannot directly apply the rules for consumer electronics;
Pure physical adapters without circuits: Need to check the catalog, and cannot directly presume applicability or inapplicability;
Charging accessories for maintenance: Shall be judged according to the sales model and whether they are priced separately, and cannot be directly presumed or excluded;
B2B industrial supporting charging products: Shall be judged according to the use and agreement on waste responsibility.

There are four general principles for boundary judgment:

The core depends on function, use, and sales form, and has nothing to do with the interface type (such as whether it is USB);
The value of the product does not affect the performance of obligations; even a charging cable that costs a few yuan must comply as long as it is within the applicable scope;
The Treatment Catalog is dynamically adjusted, and must be subject to the latest official announcement;
For products with multiple attributes, the rules of corresponding categories shall be checked separately.

III. What Is Mandatory and What Is Advocated? Don’t Confuse Them

Many people’s misunderstandings about EPR come from confusing mandatory obligations, policy advocacy, and voluntary enterprise commitments. Below we clarify these three categories.

Mandatory Obligations: Have Clear Legal Basis and Must Be Fulfilled

Mandatory obligations are not required to be fully fulfilled for all products, but depend on which rules apply to your product. Common mandatory obligations include the following categories:

Treatment Catalog-related systems The first step is to check whether your product is in the latest Treatment Catalog. If it falls under the Treatment Catalog, you shall separately check the specific obligations of producers, importers, sellers, recyclers, and treatment enterprises in accordance with the current Regulations on the Administration of Recycling and Treatment of Waste Electrical and Electronic Products and supporting documents. Special reminder here: The waste electrical and electronic products treatment fund has been suspended since January 1, 2021. Do not regard “paying the treatment fund” as the current natural obligation of products in the catalog. The suspension of the treatment fund only means that paying the fund should no longer be regarded as the current natural obligation; whether the Treatment Catalog system and other statutory obligations apply shall still be subject to current official documents.
China RoHS tiered management requirements This is the special requirement most commonly involved in charging products, mainly including three aspects: first, product labeling and information disclosure, such as labeling the content of toxic and hazardous substances, environmental protection use period, etc.; second, compliance management, products included in the compliance catalog need to meet the requirements and complete conformity assessment; third, evidence retention. For evidence retention, corresponding technical documents, supply chain materials, and conformity assessment evidence shall be established and preserved according to whether the product falls within the scope of China RoHS application, whether it is included in the compliance management catalog, and the conformity assessment method adopted. A single label or a single test report usually cannot replace complete applicability judgment and conformity assessment requirements.
Labeling obligations Corresponding environmental protection labels shall be affixed in accordance with the rules, and unfounded absolute environmental protection slogans shall not be used, such as “100% environmentally friendly”, “zero pollution” and other unsubstantiated statements.
Parallel compliance obligations In addition to the above, you must also comply with environmental protection regulations in related fields such as packaging and batteries, such as excessive packaging issues and lithium battery recycling requirements.
Information disclosure and ledger retention This obligation only applies to products explicitly required by laws, regulations, catalogs, and local pilots, and is not universal for all products. If your product involves statutory obligations, you need to keep full-process records of sales, recycling, and treatment for inspection by regulatory authorities.

Common Misconceptions in Fulfilling Responsibilities

There are several common misconceptions that must be avoided:

There is no universally applicable rule of “choose between paying fees / building your own recycling system”; the ways of fulfilling responsibilities under different systems cannot replace each other;
Products not in the Treatment Catalog do not need to fulfill the special obligations of the Treatment Catalog, but other applicable environmental protection requirements must still be complied with;
Building your own recycling system or entrusting a third party to recycle is only a supplementary way to fulfill responsibilities, and cannot replace mandatory obligations such as statutory declaration and labeling.

Principles of Responsibility Division for Different Sales Models

There is no unified “EPR subject” rule for the subject of responsibility; you must first clarify the actual operation and import facts, and then correspond to the subject of responsibility in specific regulations:

Domestic production and sales: Domestic producers are the primary subjects of responsibility;
General trade import: Domestic importers bear statutory responsibilities for the import link;
Cross-border e-commerce retail import: First identify all roles such as the declarant, seller, platform, brand owner, and domestic service provider, and then correspond to regulatory requirements; the responsibilities of the platform are determined according to e-commerce and customs rules; if it is truly a personal item, for non-operational personal use, and does not constitute commercial launch via direct overseas mail, it usually does not bear corresponding production and operation responsibilities as an enterprise producer or importer, but still needs to comply with customs, transportation and other rules;
Personal use / gift: Non-commercial in nature, no need to bear enterprise-level EPR responsibilities;
Entrusted OEM production: The statutory responsibilities of the brand owner will not be completely transferred due to the contract agreement with the OEM.

Policy Advocacy and Voluntary Commitments: Not Mandatory Requirements

Many people regard policy advocacy content as mandatory obligations; for example, easy-to-disassemble design, improving product durability and repairability, and shared recycling systems are all directions encouraged by policies, but they are not natural statutory EPR obligations.

There are also green design issues that people often hear about, such as unified charging interfaces and the use of recyclable materials. Most of these are currently advocacy directions, and only when there are clear requirements in special regulations do they need to be enforced.

Some environmental protection actions taken by enterprises themselves, such as disclosing recycling targets that exceed statutory requirements, voluntarily carrying out trade-in or recycling rewards, and ESG environmental responsibility disclosure, are all voluntary commitments and are not legally required.

IV. Practical Implementation: Six-Step Compliance Judgment Method

If you want to make a preliminary compliance judgment by yourself, you can follow the six steps below. Each step has clear actions, materials to prepare, and output results. If you encounter complex situations, you need to consult a professional institution.

Step 1: Confirm Sales and Import Models

The core action is to sort out your business model type, such as domestic production, general trade import, or cross-border e-commerce retail import. Materials to be prepared include sales contracts, customs declarations, platform agreements, logistics vouchers, etc., and finally output a Sales / Import Model Sorting Table.

If special models such as leasing, consignment sales, trade-in, and centralized procurement are involved, it is recommended to trigger upgraded consultation and find professionals to confirm.

Step 2: Confirm Product Functions and Catalog Classification

The core action is to check product information against the latest Treatment Catalog and apply the previous matrix for preliminary judgment. Materials such as product specifications, manuals, and HS codes need to be prepared, and a Product Classification and Catalog Applicability List is output.

If the product has cross-border functions, the catalog entries are vague, and you are unsure about the classification, you should find a professional to confirm.

Step 3: Identify Parallel Compliance Rules

The core action is to check whether the product has a battery, what the packaging is like, and whether there are special components, and then verify the corresponding regulations. Materials such as BOM (Bill of Materials), battery specifications, and packaging instructions need to be prepared, and a Parallel Compliance Obligation Inspection Table is output.

If the product contains hazardous chemicals, special batteries, or key regulated packaging, upgraded consultation should be triggered.

Step 4: Confirm Your Own Identity as the Subject of Responsibility

The core action is to correspond to the responsibility requirements in the regulations according to your role in the transaction (such as brand owner, importer, platform). Materials such as business licenses, cooperation agreements, and authorization letters need to be prepared, and a Responsibility Subject Matrix is output.

If the division of responsibilities among multiple parties is unclear, or the overseas entity has no domestic counterpart, you should find a professional to help sort it out.

Step 5: Verify the Latest Requirements of the Competent Authorities

The core action is to query official channels to confirm the validity of the rules according to the verification order mentioned above. Official documents, policy interpretations and other materials need to be prepared, and a Regulation Version Ledger is output — the ledger should clearly record the file name, document number, valid status, query date, applicable products, responsible department, and evidence location for future reference.

If it involves local special pilots or new policies without implementation rules, upgraded consultation should be triggered.

Step 6: Retain Contract and Ledger Evidence

The core action is to organize and preserve full-process records and the qualification documents of cooperation partners. Materials to be prepared include the qualification documents of cooperation partners, waste transfer manifests (if applicable), declaration records, annual reports, etc., and finally output a Compliance Evidence Retention List and Risk Disposal Form.

If there is a lack of ledgers or the cooperation partner cannot provide compliance certificates, you should promptly find a professional to assess the risks.

V. Advanced Pitfall Avoidance: Don’t Step on These Landmines

If you already have a certain foundation of compliance, the following content can help you avoid many easily overlooked pitfalls.

How to Verify the Qualifications of Recycling Partners?

When looking for a recycling partner, you can’t just find any one; you need to check the corresponding qualifications according to the waste properties of the discarded products:

For general renewable resource recycling such as ordinary plastic and metal waste accessories, check whether the business scope of the other party’s business license has relevant items, as well as the filing required by local authorities;
For waste electrical and electronic products within the Treatment Catalog, check whether the other party has the business scope of special treatment qualifications, whether the qualifications are within the validity period, and meet the requirements of catalog supervision;
For hazardous waste treatment, such as waste lithium batteries, mercury-containing devices, etc., check whether the other party has a hazardous waste operation license, and implement hazardous waste transfer management in accordance with regulations.

Here are some general pitfall avoidance tips: Ordinary waste electronic accessories do not naturally require a hazardous waste transfer manifest; whether waste lithium batteries are hazardous waste shall be judged in combination with the source, properties, hazardous waste catalog, and local requirements, and cannot be generalized; unqualified treatment parties cannot prove your compliance, and may also bring environmental and safety risks.

Key Compliance Differences of Different Charging Products

There are several types of special charging products whose compliance requirements are different from ordinary consumer products:

Charging accessories included with the main unit: The obligations of the Treatment Catalog are fulfilled along with the complete machine, and do not need to be treated as catalog products separately; however, requirements such as RoHS, packaging, and recycling shall be determined according to whether the accessories are separately launched on the market and the regulatory objects of the regulations;
Industrial / automotive / medical charging equipment: Shall be judged according to the regulations of the corresponding field, and cannot directly apply the rules of consumer electronics;
Multi-attribute charging products: For example, devices that can charge, transmit data, and have storage functions shall separately check the regulatory requirements corresponding to each function.

Core Differences Between China’s EPR and EU WEEE

Many overseas practitioners have compliance experience with EU WEEE and tend to directly apply it to China. In fact, although the core logic of the two is consistent, the specific rules are very different. The EU WEEE registration number and label cannot be directly used as proof of compliance in China. The core differences can be seen in the comparison below:

Comparison Item	EU WEEE	China EPR
Definition of Producer	Entity that places products on the EU market	Determined by roles under different systems
Registration Mechanism	Usually requires producer registration in accordance with the rules of each member state, and responsibilities can be fulfilled through individual performance or joining a collective Producer Responsibility Organization (PRO); whether it is mandatory to join a PRO depends on member state rules and the way of fulfilling responsibilities	No unified EPR registration; declaration / filing is implemented according to the system
Product Scope	Categories covered by the EU unified catalog	The catalogs of the two sides cover different categories
Recycling Targets	Has EU minimum collection rates and recycling, reuse targets divided by equipment category and stage, implemented by member states through domestic rules	Implemented according to specific systems and catalog regulations
Labeling Requirements	Unified crossed-out trash bin label	Different systems correspond to different labels
Cross-border Responsibilities	Clear platform responsibilities	Distinguished by import mode, platform type, and regulations
Verification Method	Check producer registration and related compliance records	Check announcements of competent authorities, declaration / filing records

How to Judge Violation Risks?

Do not believe generalized statements such as “violating EPR will result in a fine of tens of thousands of yuan”. Violations and penalties must be evaluated in combination with specific acts and corresponding legal provisions, and need to be judged by professionals in accordance with corresponding regulations. The regulations corresponding to common types of violations are roughly as follows:

For violations of solid waste and hazardous waste management requirements, the Law on the Prevention and Control of Environmental Pollution by Solid Waste etc. shall apply;
For violations of RoHS requirements, the corresponding management regulations for RoHS shall apply;
For false environmental protection publicity, relevant regulations on advertising supervision and anti-unfair competition shall apply;
For violations in the import link, relevant regulations on customs and import and export commodity inspection shall apply.

8 Most Common Cognitive Misconceptions

We will collectively clarify the most common misconceptions to prevent you from falling into pitfalls:

Having a recycling label = compliance: The label is only one of the requirements; you also need to fulfill other applicable obligations, such as declaration and ledger retention;
Having 3C / RoHS = EPR responsibilities fulfilled: Different systems have different control scopes and cannot replace each other;
Only local Chinese brands need to comply: Both domestic and overseas products commercially launched into the Chinese market shall fulfill corresponding obligations in accordance with applicable Chinese laws and regulations; this does not mean that all products trigger the same set of EPR registration, fee payment, or recycling system obligations;
Low-value charging cables do not need to comply: As long as they are within the applicable scope, the value of the product does not affect the performance of obligations;
All products with USB are regulated: USB is just an interface type and does not determine product classification; the core depends on function and use;
EPR = paying treatment fees: EPR includes multiple types of responsibilities, the treatment fund has been suspended, and there is no universal fee payment obligation;
Products with batteries need two types of EPR registration: There is no unified EPR registration in China, and you need to check the requirements of specific regulations;
EU WEEE registration number can be used in China: The systems of China and Europe are different, and overseas compliance certificates cannot be directly used universally in China.

VI. Practical Judgments for High-Frequency Scenarios

You can directly refer to the following common scenarios.

How to Dispose of Waste Charging Products? (Consumer Version)

If you are an ordinary consumer and have unused old chargers, charging cables, and power banks, you can dispose of them in the following ways:

Formal disposal channels: official brand recycling channels, brand after-sales outlets, community recycling bins, formal renewable resource recycling points;
Safety precautions: Products with batteries (such as power banks) should not be mixed with household waste to avoid short circuits and fires;
Pitfall avoidance tip: Do not hand them over to unqualified mobile recyclers to prevent environmental pollution caused by illegal dismantling.

How Can Overseas Consumers Choose Compliant Products?

If you are an overseas consumer and want to buy charging products that meet China’s environmental protection requirements, you can judge from the following points:

Check whether the product or packaging is labeled with corresponding marks as required, such as RoHS mark, environmental protection use period, etc.;
Check whether the brand has publicized recycling channels in China;
Do not believe unfounded absolute environmental protection publicity.

When Do You Need to Find a Professional Institution for Confirmation?

If you encounter the following situations, it is recommended not to force a judgment by yourself, but to find a professional compliance institution for confirmation:

The product is at the boundary of the catalog, and the classification is unclear;
The product has multiple attributes, such as charging, battery, and communication / medical functions at the same time;
Adopting special sales models such as cross-border consignment sales, leasing, and trade-in;
Involving a large number of imports, centralized recycling, or hazardous waste treatment;
There are special local pilot policies, and the rules are unclear.

4 Real Scenario Judgment Examples

We use four common real scenarios to help you better understand how to judge:

Example A: Overseas brand imports independent USB-C wall chargers via general trade

Facts: Independently sold wall-plug battery-free chargers, imported in batches via general trade, and sold through all channels in China;
Judgment: Usually does not fall under the Treatment Catalog; need to check China RoHS tiered requirements and packaging rules; since there is no battery, no need to check battery-related rules;
Documents to be verified: Latest Treatment Catalog, RoHS-related regulations, packaging regulations, HS code regulatory requirements;
Conclusion boundary: If there are local EPR pilots, they need to be checked separately; the subject of responsibility is determined according to specific regulations.

Example B: Ordinary USB-C data cable sold as a gift with brand mobile phones

Facts: Passive data cable, included as a gift with the complete machine and not sold separately, produced domestically or included when the complete machine is imported;
Judgment: Data cables usually do not fall under the Treatment Catalog; need to check China RoHS tiered requirements and packaging rules for the complete machine;
Documents to be verified: Proof of whether the complete machine falls under the Treatment Catalog, RoHS requirements, packaging regulations;
Conclusion boundary: Treatment Catalog obligations are fulfilled along with the complete machine; whether there are separate requirements for RoHS, recycling, etc. shall be determined according to regulations.

Example C: Wireless power bank with lithium battery imported via cross-border retail

Facts: Contains lithium battery, sold independently, has both charging and energy storage functions, imported via cross-border e-commerce retail;
Judgment: Usually does not fall under the Treatment Catalog; need to check China RoHS tiered requirements, battery rules, and packaging rules;
Documents to be verified: Treatment Catalog, battery management regulations, cross-border e-commerce import list, RoHS requirements;
Conclusion boundary: There is no unified “dual EPR registration” requirement; the subject of responsibility is determined according to the import mode and regulations.

Example D: Old power adapters replaced during after-sales maintenance

Facts: Discarded after use, from brand after-sales outlets, uniformly recycled by the brand;
Judgment: Usually does not fall under the Treatment Catalog; first judge the waste property (general solid waste or hazardous waste), then check the recycling and treatment requirements;
Documents to be verified: Hazardous waste catalog, local recycling management regulations, treatment party qualification requirements;
Conclusion boundary: If it is hazardous waste, it needs to be handed over to a qualified institution for treatment in accordance with hazardous waste management requirements.

VII. Learning Summary: Core Competencies You Need to Master

After reading this article, you should have these basic competencies:

Able to distinguish the EPR system framework from specific statutory obligations, and will not directly apply the logic of EU WEEE;
Able to preliminarily judge the EPR application scope of charging products through the dual judgment axes of “commercial launch + domestic waste” and the product matrix, and at the same time know that obligations in the market launch stage and responsibilities in the waste treatment stage cannot be confused;
Know that the treatment fund has been suspended, and will not mistakenly think that all products need to pay treatment fees;
Able to distinguish mandatory obligations, policy advocacy, and voluntary commitments, and will not regard green design suggestions as statutory requirements;
Able to verify the qualifications of recycling partners according to waste properties and avoid common compliance risks;
Able to make preliminary compliance judgments through the six-step process, and clarify the output of each step and when to seek professional support;
Able to handle common high-frequency scenario judgments, clarify their own ability boundaries, and know when to seek support from professional institutions.

The Extended Producer Responsibility system seems complicated, but its core logic is actually very clear: first determine whether your product and sales model are within the applicable scope, then find the corresponding specific rules. Do not blindly apply based on experience, nor listen to the one-sided statements of third parties. Everything shall be subject to the latest official documents.