Green Circle Speaks Cross-border] - UK EPR New Policy, What are the requirements for WEEE?

In November 2021, the UK government announced the Environment Bill, which aims to improve air and water quality, tackle waste, improve biodiversity and other environmental improvements. The Act is of great significance to the protection of the environment in the UK.

Extended Producer Responsibility (EPR) Scheme for Packaging, UK Packaging Act, effective February 28, 2023

From February 28, all responsible packaging producers in England, Northern Ireland and Scotland will have to collect information about the number and type of packs they offer in 2023, with Wales soon to follow.

In March this year, the UK government developed its own EPR policy plan in response to the European Extended Producer Responsibility (EPR) policy, with tackling waste as one of its key objectives. This means that sellers to the UK need to start preparing for EPR compliance.

As a seller, it is therefore vital that you understand and comply with the requirements of the UK's EPR policy. This includes taking responsibility for waste, taking steps to dispose of and recycle waste, and ensuring that your business complies with relevant environmental legislation. The UK's EPR policy will have a direct impact on sellers' businesses, so it's important to understand and act on it early.

The UK producer responsibility law EPR covers packaging, electrical and electronic equipment (EEE), batteries and end-of-life vehicles (ELV).

Producer Responsibility (PR) is to ensure that businesses that manufacture, import and sell products are responsible for the environmental impacts of their waste.

According to the requirements of the relevant regulations, companies need to take the following measures:

Minimize the waste generated by the product and promote its reuse;

To ensure that wastes are properly handled and that waste recovery and recycling targets are met;

Reduce environmental impacts by reducing the use of materials and improving reusability and recyclability at the product design stage.

The Waste Electrical and Electronic Equipment (WEEE) Regulations (as amended), enacted in the UK in 2013, form the basis of the legislation. The legislation regulates electrical and electronic equipment (EEE) and aims to reduce the amount of waste electrical and electronic equipment (WEEE) that is incinerated or landfilled. Therefore, if you place EEE on the UK market, you must comply with the WEEE Recycling Directive and register it as WEEE, according to the Environment Agency.

Who needs to register for WEEE in the UK?

Any seller placing electrical and electronic equipment (EEE) on the UK market will be considered a producer of 'EEE' and as a producer, sellers will need to be registered for WEEE, with WEEE producers in the UK being categorized as either large producers or small producers.

The distinction is based on the amount of EEE placed on the UK market in the previous natural year (the compliance year), with a cut-off of 5 tons, below which a small producer is considered to be a small producer and above which a large producer is considered to be a large producer.

◆ Small-scale producers: Sellers of electrical and electronic products to the UK market with an annual drop-in volume of 5 tons or less are required to register as a small-scale producer through the official website of the United Kingdom Environment Agency (UKEA).

◆Large Manufacturers: Sellers of electronic and electrical products to the UK market with an annual volume of 5 tons or more are required to join a recycling organization.

Registration must be completed by January 31st of each year or within 28 days of the first placement of an EEE on the market.

When do I need to register my electrical and electronic equipment for WEEE in the UK?

If you meet one of the four scenarios below, you meet the requirement to provide a UK EPR registration number.

  1. Manufactures and markets EEE products in the UK under its own brand name;
  2. Buy the EEE and then rebrand and resell the product to the UK market (if the manufacturer's brand appears on the equipment, they are the producer);
  3. Importation of EEE into the UK on a commercial basis;
  4. Non-UK companies also supply EEE directly to the UK market through online platforms.

Waste Electrical and Electronic Equipment (WEEE) regulations apply regardless of how you sell your products.

The UK WEEE is divided into 14 broad categories:

When will WEEE registration become mandatory in the UK?

January 1, 2023

Does WEEE UK need to authorize local representation?

Yes, authorization of a UK local representative is required.

Manufacturers in other countries must appoint an Authorized Representative (AR) in the UK or join a UK approved PCS.

WEEE Symbol

According to Article 11(2) of the European Union Directive 2002/96/EC (WEEE), electrical and electronic equipment placed on the market by manufacturers after August 13, 2005 must be marked with the "crossed out wheelie bin" symbol.

Small producers will receive a registration number beginning with WEE upon successful registration with the UK Environment Agency. There is no certificate.

What are the consequences of not complying with the UK's WEEE obligations?

If you fail to comply with the Waste Electrical and Electronic Equipment (WEEE) regulations, you could be prosecuted and fined up to £5,000 in the Magistrates Court or an unlimited fine from the Crown Court.

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