Aluminum ash, electroplating sludge, waste lead-acid batteries, waste circuit boards, waste automotive catalysts, dust collected from secondary copper plants—these things that circulate daily in the nonferrous metals industry—whether they count as hazardous waste determines who can collect them, how they can be transported, to whom they can be sold, and how much the fine will be if something goes wrong. The basis for determination is the National Catalogue of Hazardous Wastes (2025 Edition), effective from January 1, 2025, with the 2021 Edition repealed at the same time. After the Ecological Environment Code comes into force on August 15, 2026, the Solid Waste Law is repealed, but the Code continues the hazardous waste definition of 'listed in the Catalogue or identified through identification'. This article selects the entries in the Catalogue related to nonferrous metal smelting, recycling, surface treatment, batteries and catalysts, and explains how to read the codes, what the exemption list can exempt, and what it cannot exempt. It is suitable for recyclers, secondary metal plants, surface treatment enterprises and people doing scrap trading.
1. How to Read the Catalogue
First clarify the basic rules of the Catalogue so you will not misread them later:
1. What will be listed: solid wastes (including liquid wastes) that have one or more hazardous characteristics of toxicity, corrosivity, ignitability, reactivity or infectivity, and solid wastes that are not excluded from having hazardous characteristics and need to be managed as hazardous waste.2. Codes are 8-digit numbers: digits 1-3 are the generating industry code (according to the National Economic Industry Classification), digits 4-6 are the sequence code, and digits 7-8 are the waste category. For example, 321-026-48: 321 is smelting of commonly used nonferrous metals, and 48 is HW48 'Nonferrous Metal Mining, Dressing and Smelting Waste'.3. Hazardous characteristics are marked with letters: T toxicity, C corrosivity, I ignitability, R reactivity, In infectivity. Separation by '，' means it definitely has the first characteristic and may have the later ones; separation by '/' means it has one or more of them.4. Not being listed in the Catalogue does not mean it is not hazardous waste. For solid wastes whose hazardous characteristics are unclear, determine them according to the national hazardous waste identification standards and methods; if identification shows hazardous characteristics, classify them against existing codes, and those that cannot be classified are managed under '900-000-××'; if identification shows no hazardous characteristics, they are not hazardous waste.5. The properties of solid wastes after hazardous waste is mixed with other substances, and of solid wastes after hazardous waste utilization and disposal, are also determined according to identification standards; you cannot assume that 'once mixed in, it no longer is' or 'once treated, it no longer is'.
There is one more point to note: the 'waste ××' written in the appendix to the Catalogue presupposes that the item has already been determined to be solid waste according to solid waste identification standards. Qualified products and raw materials are not discussed here.
3. Surface Treatment, Circuit Boards and Batteries
Hazardous wastes from downstream metal processing and the electronics and battery industries are most often sold as 'material' in transactions:
1. Electroplating sludge (HW17): spent bath solutions, tank residues and wastewater treatment sludge generated from electroplating processes such as zinc plating, cadmium plating, nickel plating, silver plating, gold plating, copper plating and chromium plating; waste liquids and sludge generated from acid/alkali washing, degreasing, rust removal and phosphating of metal or plastic surfaces (336-064-17; the Catalogue lists exceptions such as sludge from certain processes for aluminum and magnesium materials, and sludge from acid pickling and rust removal of carbon steel); spent bath solutions and sludge generated from coating stripping (336-066-17).2. Circuit boards: spent copper etching solution from circuit board production (398-004-22), spent copper plate etching solution and sludge (398-051-22), and spent lead-tin alloy electroplating solution (398-052-31).3. Waste circuit boards (900-045-49): includes discarded circuit boards with components removed or not removed, and waste CPUs, graphics cards, sound cards, memory, capacitors containing electrolyte, and connectors containing gold and other precious metals generated from dismantling.4. Lead-acid batteries: waste lead-acid batteries and waste lead plates, waste lead paste and acid liquid generated from dismantling (900-052-31), and waste residues, dust and sludge from lead-acid battery production (384-004-31).5. Other batteries: discarded nickel-cadmium batteries, phosphor powder and cathode ray tubes (900-044-49), waste residue and sludge from nickel-metal hydride battery production (384-005-46), waste residue and sludge from nickel-cadmium battery production (384-002-26), and mercury-containing battery-related wastes (HW29).
It should be noted that the Catalogue does not separately list 'waste lithium-ion batteries'. Whether retired lithium batteries and electrode scrap are managed as hazardous waste depends on whether they are identified as having hazardous characteristics and on specific local management requirements; one cannot simply say 'lithium batteries are not hazardous waste'.
4. Waste Catalysts and Oily Wastes
The two lines of precious metal recovery and equipment dismantling cannot avoid the following categories:
1. Waste catalysts (HW50): waste catalysts for exhaust gas purification of motor vehicles and non-road mobile machinery (900-049-50), i.e. the commonly called waste automotive three-way catalytic converters; waste catalysts generated from petroleum product hydrorefining, hydrocracking, catalytic reforming and other processes (251-016/018/019-50), waste catalysts from catalytic cracking using nickel passivator (251-017-50); waste vanadium-titanium-based catalysts from flue gas denitrification (772-007-50); waste liquid catalysts (900-048-50); and waste catalysts from a large number of chemical production processes. In addition, discarded nickel catalysts belong to HW46 (900-037-46), and discarded mercury-containing catalysts belong to HW29 (900-022-29).2. Waste mineral oil (HW08): waste transformer oil generated from transformer maintenance, replacement and dismantling (900-220-08); waste mineral oil and oil sludge generated from centralized dismantling of internal combustion engines, automobiles and ships (900-199-08); waste mineral oil and oil sludge generated from honing, grinding and polishing (900-200-08); waste mineral oil generated from metal rolling (900-204-08); waste mineral oil generated from tin plating and solder recovery processes (900-205-08).3. Cutting fluid (HW09): oil-water, hydrocarbon-water mixtures or emulsions generated from machining using cutting oil or cutting fluid (900-006-09).4. Polychlorinated biphenyls (HW10): discarded capacitors and transformers containing polychlorinated biphenyls, etc., and waste dielectric oil and insulating oil in such power equipment (900-008-10, 900-010-10). Those dismantling old transformers and capacitors should first confirm whether this item is present.
When collecting second-hand transformers and equipment from whole-plant demolition, the oil inside often needs to be properly handled first even more than the copper and iron themselves.
5. What Can the Exemption List Exempt?
The 'Hazardous Waste Exemption Management List' in the appendix to the Catalogue is often misread as 'these things are no longer hazardous waste'. In fact, exemptions are limited to specific stages and conditions, and after exemption they still must comply with relevant solid waste management requirements. The main ones related to the metal industry are:
1. Exemption at the utilization stage: waste iron oil drums (900-249-08), after the closures are opened, left standing without dripping, and baled or briquetted, used as raw material for metal smelting, are not managed as hazardous waste during the utilization process; oily metal chips from mechanical processing that are hazardous waste, after being pressed, filter-pressed, filtered or centrifugally de-oiled to the point of no dripping when left standing and then baled or briquetted, used as raw material for metal smelting, are not managed as hazardous waste during the utilization process; waste metals generated from hazardous waste incineration and disposal, used as raw material for metal smelting, are not managed as hazardous waste during the utilization process; waste acids and waste alkalis that are only corrosive, if they meet the conditions for comprehensive utilization as raw materials or as neutralizing agents for wastewater treatment, are not managed as hazardous waste during the utilization process.2. Exemption at the transportation stage: intact waste lead-acid batteries, discarded circuit boards, lead-containing glass from cathode ray tubes, waste vanadium-titanium-based catalysts from flue gas denitrification, and waste catalysts for motor vehicle exhaust purification, where the transport vehicles meet rainproof, leakage-proof and spill-proof requirements, are not transported as hazardous waste; waste catalytic cracking catalysts transported in closed tank trucks are not transported as hazardous waste.3. Other: waste resin powder after recovering metals from waste copper-clad laminates, wiring boards and circuit boards by crushing and sorting is not managed as hazardous waste during transportation and standard landfill disposal; when tungsten residue enters cement kiln co-processing, the disposal process is not managed as hazardous waste; waste lead-acid batteries, electronic hazardous wastes, etc. generated in daily household life and not centrally collected are not managed as hazardous waste throughout the entire process.4. Point-to-point directed utilization: for hazardous waste not included in the exemption list or whose utilization process does not meet the conditions, under the premise that environmental risks are controllable, according to a plan determined by the provincial ecological environment department, one type of hazardous waste generated by one entity may be used as a substitute raw material by another entity, and the utilization process is not managed as hazardous waste.
The most critical point: transportation exemption only covers transportation. Waste circuit boards, waste automotive catalysts, and waste lead-acid batteries may not be transported as hazardous waste during transportation, but the collection, storage, and utilization stages are still hazardous waste, and a permit is still required to operate.
6. Rules to Follow When Collecting Scrap
Chapter 23 of the Ecological Environment Code sets out the main obligations for hazardous waste management in a centralized manner; those directly related to transactions include:
1. Licensed operation: entities engaged in the collection, storage, utilization, and disposal of hazardous waste must obtain a permit; it is prohibited to provide or entrust hazardous waste to entities and individuals without a permit.2. Storage period: operating entities may not store hazardous waste for more than one year; if extension is truly necessary, it must be reported to the permit-issuing authority for approval.3. Transfer manifest: hazardous waste transfers must be filled out and run with electronic or paper transfer manifests; cross-provincial transfers must be applied for to the provincial ecological environment department of the place of origin, and approved after consultation and consent of the place of receipt; no transfer may be made without approval.4. Hazardous waste generating entities: must formulate a hazardous waste management plan, establish management ledgers, and declare through the National Hazardous Waste Information Management System the types, generation volumes, flow directions, etc.
Penalties are severe:1. Providing or entrusting hazardous waste to unlicensed entities, or transferring without approval, is subject to a fine of not less than 200,000 yuan but not more than 2 million yuan; failing to run transfer manifests, failing to establish ledgers, etc., is subject to a fine of not less than 50,000 yuan but not more than 200,000 yuan, and if refusing to correct, not less than 200,000 yuan but not more than 1 million yuan.2. Enterprises and institutions engaging in collection and storage operations without a permit are subject to a fine of not less than 200,000 yuan but not more than 1 million yuan; those engaging in utilization and disposal operations without a permit are subject to a fine of not less than 1 million yuan but not more than 5 million yuan, and the legal representative, principal person in charge and other directly responsible persons are subject to a fine of not less than 100,000 yuan but not more than 1 million yuan; other production and business operators operating without a permit are subject to a fine of not less than 20,000 yuan but not more than 100,000 yuan, and if the circumstances are serious, not less than 100,000 yuan but not more than 500,000 yuan.3. In cases such as transferring hazardous waste without approval or operating without a permit, public security organs may impose detention on directly responsible persons.
The practical significance for both buyers and sellers is: if the seller sells hazardous waste to an unlicensed person, the seller is equally in violation of the law. Before collecting aluminum ash, electroplating sludge, waste circuit boards, and waste catalysts, first verify the other party's hazardous waste operation permit, and check whether the permitted category and mode of operation cover this batch of material. In the enterprise directory of Guilin Nonferrous Metals Network, licensed hazardous waste operating entities can be found; when connecting with such supply sources in the supply and demand hall, it is also recommended to verify qualifications before negotiating prices.
Frequently Asked Questions
Q: Is aluminum ash hazardous waste?
Yes. Aluminum ash and slag generated from remelting, refining, alloying and casting in secondary aluminum and aluminum processing, and salt slag and secondary aluminum ash generated from aluminum recovery, code 321-026-48; aluminum ash and slag from electrolytic aluminum production is 321-024-48. To collect aluminum ash for dross processing, you must have a hazardous waste operation permit covering this category.
Q: Can electroplating sludge be bought and sold as copper-containing material?
It cannot be bought and sold freely as ordinary copper-containing raw material. Spent bath solutions, tank residues and wastewater treatment sludge from electroplating processes belong to HW17 surface treatment waste; collection, storage, and utilization all require a hazardous waste operation permit, transfers must use manifests, and cross-provincial transfers require approval. If sold to an unlicensed entity, the seller is equally in violation of the law.
Q: Does transportation of waste circuit boards need to be treated as hazardous waste?
Transportation can be exempted. Discarded circuit boards are not transported as hazardous waste when the transport vehicles meet rainproof, leakage-proof and spill-proof requirements. However, they themselves are still hazardous waste (900-045-49), and the collection, storage, dismantling and utilization stages still require permitted operation.
Q: Are waste automotive three-way catalytic converters hazardous waste?
Yes. Waste catalysts for exhaust gas purification of motor vehicles and non-road mobile machinery have code 900-049-50 and belong to HW50 waste catalysts. At the transportation stage, if rainproof, leakage-proof and spill-proof requirements are met, they may not be transported as hazardous waste; collection, storage and utilization stages such as precious metal extraction are still managed as hazardous waste.
Q: How are waste lead-acid batteries recycled compliantly?
Waste lead-acid batteries and dismantled lead plates, lead paste and acid liquid belong to 900-052-31. Transportation of intact waste lead-acid batteries can be exempted, but collection, storage and recycling/utilization require a hazardous waste operation permit. Those generated in daily household life and not centrally collected are not managed as hazardous waste throughout the entire process.
Q: Can oily metal chips be sold directly to steel mills?
Yes, if the exemption conditions are met. Oily metal chips from mechanical processing that are hazardous waste, after being pressed, filter-pressed, filtered or centrifugally de-oiled to the point of no dripping when left standing and then baled or briquetted, and used as raw material for metal smelting, are not managed as hazardous waste during the utilization process. Those not de-oiled to the required standard do not apply.
Q: Are waste lithium batteries in the hazardous waste catalogue?
The Catalogue does not separately list a waste lithium-ion battery item. Whether they are managed as hazardous waste depends on whether they are identified as having hazardous characteristics and on local management requirements. Waste white oil generated from lithium battery separator production (398-001-08) is in the Catalogue. In practice, do not assume by default that lithium battery material is not hazardous waste.
Q: What is the penalty for selling hazardous waste to an unlicensed entity?
Under the Ecological Environment Code, providing or entrusting hazardous waste to an entity or other production and business operator without a permit shall be ordered to correct by the competent ecological environment department, the illegal gains shall be confiscated, and a fine of not less than 200,000 yuan but not more than 2 million yuan shall be imposed; if the circumstances are serious, suspension of business or closure may be ordered.
Key Takeaways
1. To determine hazardous waste, first check the National Catalogue of Hazardous Wastes (2025 Edition); for those not listed, determine according to identification standards; do not say 'this doesn't count' based on experience.2. Aluminum ash, dust from secondary copper, aluminum, lead, zinc and tin, electroplating sludge, waste circuit boards, waste lead-acid batteries, waste automotive catalysts, and electric arc furnace dust are all in the Catalogue.3. The exemption list is divided by stage: transportation exemption does not equal collection and utilization exemption; utilization exemptions such as oily metal chips and waste oil drums must meet conditions such as de-oiling and briquetting.4. Collection, storage, utilization and disposal of hazardous waste all require permits; transfers use manifests; cross-provincial transfers require approval; storage generally does not exceed one year.5. If sold to an unlicensed person, the seller is equally subject to penalties; before a transaction, verify the permit's category and mode of operation.
Further reading
- Daily nonferrous metal prices: https://www.guilinmetals.com/en/prices
- Nonferrous company directory: https://www.guilinmetals.com/en/companies
- Supply & demand marketplace: https://www.guilinmetals.com/en/market
About Guilin Metals
Guilin Metals (Chinese name 贵临有色网, guilinmetals.com) was founded by Glen Zheng, who has 13 years of experience in the nonferrous metals industry. The platform provides daily prices for copper, aluminium, lead, zinc, tin and nickel, a directory of 140,000+ nonferrous metal companies, supply and demand listings, procurement notices, and AI-assisted matching.
- Daily prices: https://www.guilinmetals.com/en/prices
- Company directory: https://www.guilinmetals.com/en/companies
- Marketplace: https://www.guilinmetals.com/en/market
*Data as of 2026-09-28.*