In Europe, legislation about waste of electrical and electronic equipment (WEEE) recovery and recycling has been introduced in 2002, and corresponding legislation in the EU Member States was in place in August 2005 (EU-EC 2003). In the same period, China has been developing WEEE regulation as well. The main contribution to date to the Chinese legislative framework is the ‘Circular Economy Promotion Law of the People’s Republic of China’ that was approved on August 29, 2008, and came into force as of January 1, 2009. Both these legislative systems contain the Extended Producer Responsibility as a core concept, as well as a formal, and, in the case of China, centralised, recovery system. Given the conceptual similarities of legislation on WEEE, but striking differences in the product recovery systems in China and the EU, it is of interest to investigate if the existing recovery and recycling system in China actually fits the new legislation. Currently, there is anecdotal evidence that, in China, much of the WEEE flows into informal recycling channels such as secondhand market and manual recycling workshops. Not much is known otherwise because a formal governance system and official statistics collection do not exist yet. More particularly, the actual WEEE flow in China, or in particular cities, is virtually unknown, as is the relationship between collection, treatment, re-selling and disposal. This paper suggests a Markov chain model that allows for the analysis of the flow of WEEE through the reverse chain from point of collection through to final disposal. We analyse this system in its equilibrium state and investigate the impact of scenarios that reflect key elements of the new WEEE regulation in China. In addition, we offer a qualitative analysis of the various scenarios for the three dimensions of sustainability: people, planet and profit. This research offers specific suggestions to strengthen the Chinese WEEE recovery and recycling system that would bring the actual system more in line with the current policy.