The Environment Agency are making changes to their approach in regulating the Waste Electrical & Electronic Equipment (WEEE) Regulations 2013 (as amended). These changes will come into effect for the 2025 compliance year and have been agreed by all UK environment agencies. 

What is changing?  

Legal entities who are not established in the UK and who place EEE on the UK market via indirect selling only will no longer be classed as producers of EEE in the UK. Instead, the first legal entity to place the EEE on the UK market who is also established in the UK will need to register as a producer, report the EEE and finance the obligation for these products.  

How is this different? 

In some cases, legal entities established outside the UK who only sell indirectly have previously been allowed to register voluntarily as EEE producers and finance the obligation instead of the UK-based importer or distributor. This will no longer be possible because these organisations do not meet the definition of producer set out in the UK WEEE Regulations. 

Why have the UK environment agencies decided to make this change?  

• To bring the policy in line with the definition of “producer” in the UK WEEE Regulations and ensure the correct legal entity registers as the EEE producer.  
• To improve clarity for UK-based distributors and importers. These parties must report any EEE they import if: 

  • it is in scope, and;

  • they are the first person to place it on the UK market on a professional basis.  

• To enable enforcement action to be taken where producers do not comply as the UK environment agencies do not have jurisdiction in overseas countries.  
• To reduce the risk of double-counting imported EEE placed on the UK market. 
• To simplify verification of producer data. 

Definition of EEE producer / established in the UK 

The UK Waste Electrical and Electronic Equipment Regulations 2013 (as amended) state a producer must be one of the following: 

1. Established in the United Kingdom and manufacturing EEE under their own name or trademark, or has EEE designed or manufactured and markets it under their own name or trademark within the United Kingdom; 
2. Established in the United Kingdom and reselling within the United Kingdom; under their own name or trademark, or equipment produced by other suppliers, however, a reseller is not regarded as the “producer” if the brand of the producer appears on the equipment; 
3. Established in the United Kingdom and places on the market, on a professional basis, EEE from a country other than the United Kingdom;  
4. Sells EEE by means of distance communication directly to private households or to users other than private households in the United Kingdom, and is established in a country other than the United Kingdom.