Are electronic cigarette waste classified as hazardous waste? How should it be disposed of in a compliant manner?

The impact of electronic cigarettes on human health has always been the primary issue affecting the development of the electronic cigarette industry. The environmental protection issues brought about by electronic cigarettes have also drawn increasing attention from governments around the world, especially disposable electronic cigarettes. Many countries, such as the United Kingdom, France, Australia, Belgium, and New Zealand, have either already implemented or are planning to issue bans on the production and sale of disposable electronic cigarettes due to environmental concerns.
Since 2021 when electronic cigarettes were incorporated into the unified tobacco regulatory system in China, the tobacco bureau, as the regulatory body for electronic cigarettes, has not yet formulated relevant regulations on the disposal and destruction of electronic cigarettes. The absence of specific regulatory provisions does not mean there is no regulation. The disposal and destruction of electronic cigarettes should comply with national laws and regulations on waste treatment and environmental protection. For enterprises with international ODM business, they also need to meet the review requirements of foreign customers.
I. Analysis of the Nature of Electronic Cigarette Waste
The laws and regulations governing the disposal of electronic cigarette waste mainly include the "Environmental Protection Law", "Solid Waste Pollution Environment Control Law", and "Management Measures for the Transfer of Hazardous Wastes". According to relevant laws and regulations, whether the waste from electronic cigarettes is classified as general industrial solid waste or hazardous waste, that is, "solid waste" or "hazardous waste", has completely different disposal requirements and procedures. Electronic cigarettes are mainly composed of batteries, e-liquid, vaporizers, control chips, as well as plastic parts such as casings and mouthpieces. The factor that affects the classification of their waste is only the battery and e-liquid.
1. Waste batteries are "solid waste" rather than "hazardous waste"
The batteries used for heating in electronic cigarettes are mainly rechargeable lithium-ion batteries, and some products are lithium-metal batteries. According to the "Catalogue of Classification and Codes for Solid Waste", waste lithium iron phosphate batteries, waste ternary lithium batteries, and waste cobalt oxide batteries, etc., are classified as recyclable solid waste under the category of industrial solid waste, with the code SW17. Therefore, the discarded batteries belong to general solid waste and do not belong to hazardous waste.
2. E-liquid is "hazardous waste", and containers and packaging for e-liquid also belong to "hazardous waste"
The types of e-liquid (vaporizer) in electronic cigarettes are diverse. The most common formulations mainly include: edible-grade propylene glycol (PG), edible-grade vegetable glycerin (VG), food-grade flavoring, nicotine (tar), and additives.
According to Article 2 of the "National Hazardous Waste List" in 2025, the following solid wastes (including liquid wastes) are listed in this list: (1) Having one or more of the following characteristics of toxicity, corrosiveness, flammability, reactivity, or infectivity; (2) Not excluding having hazardous characteristics that may cause harmful effects on the environment or human health and need to be managed as hazardous waste.
Although they are both "oil", the main components of e-liquid, propylene glycol (PG) and glycerin (VG), are usually not flammable at room temperature and are not flammable substances themselves. However, nicotine (tar) is a highly toxic substance with strong neurotoxicity. According to the rules for determining hazardous waste by mixing specified in the "Hazardous Waste Identification Standards", "hazardous waste with toxicity or infectivity of one or both characteristics mixed with other substances, causing the hazardous characteristics to spread to other substances, the mixed solid waste belongs to hazardous waste". The e-liquid mixed with nicotine (tar) also has hazardous characteristics and should be classified as "hazardous waste". E-liquid specifically belongs to the "HW49" category of "Other Waste", with the sub-item of 900-041-49 "Waste Disposal Containers, Packaging, and Filter Adsorption Media Containing or Contaminated with Toxic or Infectious Hazardous Waste". In practice, many enterprises mistakenly classify e-liquid as "mineral oil" during disposal, mistakenly adding "infectivity" to the hazardous characteristics, which should be corrected. Therefore, when disposing of the smoke oil storage tanks, the finished and semi-finished electronic cigarettes containing smoke oil, due to their nature as containers and packaging materials for storing smoke oil, they all fall under the category of "hazardous waste" when undergoing overall disposal. The hazardous waste code is 900-041-49.
II. Disposal Requirements for Electronic Cigarette Waste
1. Batteries: Lithium-ion batteries generally do not contain toxic or harmful components and have relatively low environmental hazards. The collection, storage, and disposal of used lithium-ion batteries should follow the relevant environmental management and pollution prevention requirements for general industrial solid waste, to prevent environmental pollution. The specific requirements can be referred to the "Technical Policy for Waste Battery Pollution Prevention" issued by the Ministry of Environmental Protection in 2016. Electronic cigarette manufacturers can sell used batteries to environmental protection enterprises specializing in recycling, and achieve the recycling and reuse of the batteries through professional processing.
2. Smoke Oil and Its Containers: For smoke oil, smoke oil storage tanks, finished and semi-finished electronic cigarettes containing smoke oil, these items that are classified as hazardous waste, electronic cigarette enterprises need to entrust environmental protection enterprises with the "Hazardous Waste Operating Permit" for collection, storage, and disposal (the list of certified enterprises in Shenzhen can be found on the website of the Municipal Ecology and Environment Bureau). The collection, transportation, storage, and disposal of these waste items must strictly comply with the regulations for hazardous waste disposal. These waste items generally have no recycling value, and environmental protection enterprises will not purchase them. The final disposal method is usually incineration and destruction. For the disposal of replacement electronic cigarettes, it is recommended to separate the e-cigarettes and other components. The e-cigarettes should be destroyed as hazardous waste, and other components that can be recycled and reused should be recovered and recycled by themselves. For disposable electronic cigarettes, if the smoke oil storage tanks are difficult to disassemble, it is more economical and efficient to choose to destroy them as hazardous waste as a whole.
III. Disposal Process for Electronic Cigarette "Hazardous Waste"
1. Internal Disposal Process: When electronic cigarette enterprises dispose of a large quantity of electronic cigarette materials, semi-finished products, or finished products, they need to follow the internal disposal process. This includes assessing whether the items to be disposed of meet the disposal conditions, approving the scope and method of disposal, selecting suppliers, and signing contracts. For hazardous waste disposal, electronic cigarette enterprises in Guangdong Province should register on the "Guangdong Solid Waste Environmental Supervision Information Platform" and complete the relevant application for hazardous waste and destruction disposal plans. When choosing a hazardous waste disposal supplier, it is necessary to review whether the enterprise holds a "Hazardous Waste Operating Permit" and has disposal experience. The terms of the disposal contract should emphasize that the transfer cannot be entrusted, the destruction must be completed without loss, the safety responsibility lies with the supplier, and clearly specify the corresponding liability for breach of contract.

2. Hazardous Waste Entrusted Disposal: The responsible entity for hazardous waste disposal is the electronic cigarette enterprise. The electronic cigarette enterprise should supervise the transportation and destruction process throughout. The disposal supplier only accepts the entrustment of the electronic cigarette enterprise for transportation and destruction. The ownership of the electronic cigarette waste does not transfer, and the entrusted disposal enterprise only assumes responsibility if there is fault. Therefore, it cannot be considered that handing over the waste to the disposal unit completes the disposal process. (1) After determining the disposal plan, electronic cigarette enterprises in Guangdong Province should fill in the "Hazardous Waste Transfer Form" in advance on the "Guangdong Solid Waste Environmental Supervision Information Platform" under the guidance of the hazardous waste disposal supplier. (2) When transferring the hazardous waste, the electronic cigarette enterprise and the entrusted disposal supplier should jointly count and sign for the transfer to avoid errors in the variety and quantity of the items. (3) The electronic cigarette enterprise should verify the transportation vehicle, review its qualifications, and monitor the transportation trajectory of the vehicle through the hazardous waste system. In practice, it is recommended that the electronic cigarette enterprise dispatch a dedicated person to escort the vehicle and supervise the transportation and destruction process, especially for semi-finished and finished products, to prevent loss during transportation and ensure that all waste is sent to the professional hazardous waste destruction and incineration kiln for destruction, and to prevent it from flowing back to the market. Video records of loading and destruction should be taken at the scene. (4) After the destruction is completed, the electronic cigarette enterprise should promptly obtain the disposal form and video materials from the entrusted disposal enterprise. 3. Post-disposal follow-up work: After the disposal of electronic cigarette waste is completed, the electronic cigarette enterprises shall conduct corresponding inventory management, asset management, financial and tax processing based on the disposal procedures and records. If it involves electronic cigarette products, electronic cigarette raw materials (such as nicotine and e-liquid), or other tobacco products, they should also promptly register with the "National Unified Electronic Cigarette Trading Management Platform" and upload relevant supporting documents.