What is changing?
Legal entities that are not based in the UK and only place electrical and electronic equipment on the UK market through indirect sales will no longer be categorised as producers of electrical and electronic equipment in the UK. Instead, the first legal entity that places the EEE on the UK market and is also established in the UK must register as a producer, register the EEE and fulfil the obligations for these products.
Direct sales = sales to end consumers (private or commercial) and indirect sales = sales to persons other than end consumers, e.g. dealers or importers.
How was it regulated before?
In some cases, legal entities based outside the UK that only sell indirectly were previously allowed to register voluntarily as producers of electrical and electronic equipment and take on the obligation instead of the importer or distributor based in the UK.
When am I a producer without a registered office in the UK?
Without being established in the UK, a company would be considered a producer if it sells electrical and electronic equipment by means of distance communication technology directly to private households or to users other than private households in the UK and is established in a country other than the UK.
Established in the UK means that a legal entity has some physical presence in the UK, for example through a place of business or an office or branch where it conducts its business.
As a general rule, this means that all non-UK companies based in the UK are registered at Companies House and have a Foreign Company (FC) number and a Branch (BR) number for each UK branch.
What do I need to consider now?
- If you have not yet informed take-e-way that you only sell indirectly, please contact us as soon as possible. Your registration will then not be renewed for 2025.
- If you sell directly and indirectly and have already notified take-e-way of this, your registration will be renewed. From January 2025, please only report the quantities that you sell directly to end users.
- Please also inform your customers (importers) that you will no longer assume the obligation from 2025. We would be delighted if you would recommend take-e-way to your customers as a reliable service provider.
If you would like to register in the UK as a producer of WEEE, batteries or packaging, or if you have any questions about extended producer responsibility (EPR), please contact our advisory service at beratung@take-e-way.de or +49/40/750687-0.
get-e-right GB is your authorised representative in the UK and supports you in all areas of product compliance and EPR, such as the UKCA Declaration of Conformity.
For information on our international compliance services in connection with the placing on the market of electronic devices, batteries/rechargeable batteries and packaged products or packaging, please click here: https://www.take-e-way.com/international-compliance/
