Guidance

Electrical and electronic equipment (EEE): producer responsibilities

If you put EEE on the UK market you must follow rules on both the EEE you sell and the EEE that becomes waste (WEEE).

From:
Environment Agency
Published
1 May 2014
Last updated
6 July 2023 — See all updates

EEE producers must play a part in protecting natural resources and managing waste EEE in the best way for people and the environment.

EEE producer: definition

You’re a producer of EEE in the UK if you:

  • manufacture and sell EEE under your own brand in the UK
  • resell equipment made by someone else under your own brand (if the maker’s brand appears on the equipment they are the producer)
  • import EEE on a commercial basis into the UK
  • are established outside of the UK and supply EEE directly to the UK market by distance selling (for example online, mail order, by phone)

To decide if your product is EEE see guidance on how to correctly identify EEE.

You’re not a producer if you buy an item of EEE abroad and bring it into the UK for your own use.

EEE producers: what you must do

You must register as a producer annually. How you do this depends on how much EEE you put on the UK market in the previous calendar year (also known as a compliance year).

If you place less than 5 tonnes of EEE on the UK market in a compliance year, you can register direct with your environmental regulator as a small producer.

If you place more than 5 tonnes of EEE on the market, you must join a producer compliance scheme (PCS). The PCS takes on your obligations to finance the collection, treatment, recovery and environmentally sound disposal of household WEEE collected in the UK.

You must also take on distributor responsibilities if you sell EEE direct to householders in the UK.

EEE producers must also:

  • mark products with the crossed out wheeled bin symbol and a date mark
  • provide information on reuse and environmentally sound treatment of the products and components (includes materials, dangerous substances and preparations) within one year of putting them on the market
  • make sure that distributors you supply have your producer registration number
  • keep records for at least 4 years of the amount of EEE put on the market by category

Producers should aim to improve product design to facilitate recycling and reuse of components and materials.

See the restriction of the use of certain hazardous substances (RoHS) in electrical and electronic equipment: compliance and guidance.

Register as a small producer

Register on the National Packaging Waste Database (NPWD).

You will be asked for your business location and the system will identify the relevant regulator:

  • Environment Agency (England)
  • Natural Resources Wales (Wales)
  • Northern Ireland Environment Agency (Northern Ireland)
  • Scottish Environmental Protection Agency (Scotland)

You must register by 31 January every year or within 28 days of placing EEE on the market for the first time.

When you register you need to tell us how much EEE you placed on the market in the previous calendar year by category. See guidance on how to:

You will also need to tell us whether it’s household (also known as business to consumer - B2C) or non-household (also known as business to business - B2B). See the guidance on how to correctly identify B2C and B2B EEE and WEEE.

You can use a third party to register you and submit your data. You can use a PCS as a third party and not register as a member but it will not take on your legal responsibilities. Or you can choose to register as a full compliance scheme member.

If you find you place 5 tonnes or more EEE on the market during a compliance year and you’ve registered as a small producer you must notify the relevant environmental regulator and join a compliance scheme within 28 days.

You can apply for approval to become a PCS where you will be the only member.

You may also have a producer obligation to finance the cost of collection, treatment, recovery and environmentally sound disposal of non-household EEE arising from end-users.

Join a PCS

If you placed more than 5 tonnes of EEE on the UK market you must join a PCS. You must do this by 15 November each year. If you enter the UK EEE market after 15 November you must join a PCS within 28 days of placing the EEE on the UK market. You must also be a member of a PCS in the compliance year immediately following the last compliance period which you put more than 5 tonnes of EEE on the market in the UK.

See a list of approved PCSs. Check their service meets your needs. If you put both household and non-household EEE on the market you can join two schemes, one for each. Or you can join one scheme for both.

The PCS will charge fees for its services. This includes fees for collection and treatment costs of WEEE on your behalf.

You must give your PCS information about your business. You must provide the amount of EEE you placed on the UK market by category as requested by the scheme. See guidance on how to:

What the PCS does on your behalf

The PCS takes on your obligations to finance the collection, treatment, recovery and environmentally sound disposal of household and non-household WEEE collected in the UK.

Household WEEE

A PCS is given a collection target for its whole membership for each compliance year. Each producer is responsible for financing a portion of that target based on its market share in each of the 14 product categories of EEE it sells. The PCS reports the information needed by the relevant environmental regulator every 3 months.

Non-household WEEE

The PCS takes on your financial obligations for non-household WEEE arising in each compliance period from:

  • EEE a producer placed on the market on or after 13 August 2005
  • EEE that was placed on the market before 13 August 2005, regardless of the producer, which the user is replacing with equivalent new EEE

This applies unless alternative arrangements have been made between the producer and the business end-user.

See the guidance on how to correctly identify business to consumer (B2C) and business to business (B2B) EEE and WEEE.

The PCS reports the information needed by the relevant environmental regulator once per year.

Non UK based producers

Before putting EEE on the UK market, producers based in other countries must either appoint an authorised representative based in the UK or join a UK approved PCS. This must be done in time for the relevant compliance period.

UK based producers that put EEE onto the market of other member states can appoint an authorised representative based in that state rather than registering as a producer there.

Enforcement and compliance

If you do not register as a small producer or join a PCS you are committing an offence and may face enforcement action.

Legislation and regulations

See:

More information on how to comply

See:

Published 1 May 2014
Last updated 6 July 2023 + show all updates

  1. Added a link to new guidance 'Report the amount of EEE you place on the market'.

  2. Updated to include government department guidance (BIS) and regulatory guidance in one place as part of the Defra Smarter Guidance project.

  3. First published.

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