Making conforming products is only half the job. If you place electrical and electronic equipment or batteries on the UK market, you also pick up producer-responsibility duties: ongoing obligations to register, report what you sell, help pay for the collection and recycling of your products when they become waste, and mark them so people know not to throw them in the bin.
This guide is for makers, importers and brand-owners of electronic and electrical equipment (SIC divisions 26 and 27). It covers the duties that recur year after year, not the one-off conformity assessment and marking you do before a product first goes on sale. Those product-conformity rules are covered in a separate guide.
These regimes apply UK-wide, including Northern Ireland. The Environment Agency administers them in England, with SEPA in Scotland, Natural Resources Wales in Wales and the Northern Ireland Environment Agency in Northern Ireland.
Work out whether you are a producer
Producer responsibility does not turn on whether you manufacture anything. You usually count as a producer if you do any of the following under your own brand or in your own name: make equipment or batteries in the UK; import them into the UK; or rebrand someone else's product as your own. A business that only assembles or sells finished goods can still be caught, and an importer can carry the duty even though it makes nothing.
Check your position for each regime separately. The same product can pull you into the waste electrical and electronic equipment regime for the device itself and into the battery regimes for any cells it contains. Work this out first, because everything that follows depends on it.
Join a compliance scheme
Most producers meet their duties by joining an approved producer compliance scheme rather than dealing with the regulator directly. The scheme registers you, handles your reporting and arranges the collection and recycling on your behalf, in return for a fee that reflects how much you place on the market. Smaller producers can sometimes register directly with the environmental regulator instead; check the current thresholds, which live in the linked guidance and the snippets above and below, before deciding.
You join a scheme for waste electrical and electronic equipment and, separately, for waste batteries if you place batteries on the market. Allow time before your first reporting period, because scheme membership has to be in place to cover the goods you sell.
Register and report what you place on the market
Once you are in a scheme, the core ongoing duty is to keep accurate records of the equipment and batteries you place on the UK market and to report them on the regulator's timetable. You report the quantities by the relevant categories, and the figures drive both your fees and your share of the recycling that must be financed. Keep the underlying sales and import data so you can stand behind the numbers if the regulator asks.
Finance collection, treatment and recycling
Producer responsibility is, at heart, a duty to pay for what happens to your products at the end of their life. You must finance the collection, treatment, recovery and recycling of waste electrical and electronic equipment and waste batteries in proportion to what you placed on the market. A compliance scheme normally discharges this for you by buying the evidence of recycling that your obligation requires, but the legal duty stays with you as the producer. Battery producers and distributors also have take-back obligations for waste batteries returned by customers.
Mark your products correctly
You must mark the products you place on the market so that users and recyclers handle them correctly. The central symbol is the crossed-out wheeled-bin, which tells people the item must not go in with general waste and should be collected separately for recycling. It appears on electrical and electronic equipment and on batteries.
Batteries carry extra marking on top of the wheeled-bin symbol. Where relevant they must show their capacity and the chemical symbols for the heavy metals they contain (Hg for mercury, Cd for cadmium, Pb for lead), and appliances must be designed so that waste batteries can be removed. These placing-on-market marking and design rules sit alongside the producer-responsibility duties, and the Office for Product Safety and Standards enforces them rather than the environmental regulator.
Unlike conformity assessment, these duties recur. Work through the steps below when you first become a producer, then repeat the reporting and financing every year for as long as you place products on the market.
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1. Decide whether you are a producer
Check, for each regime, whether you make, import or rebrand equipment or batteries placed on the UK market. Treat the device and any batteries it contains separately.
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2. Join the right compliance scheme
Join an approved scheme for waste electrical and electronic equipment and, if you sell batteries, a battery scheme. Confirm whether you are below a small-producer threshold that lets you register directly instead.
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3. Register before your first reporting period
Make sure your registration is live and dated to cover the goods you are already placing on the market, so there is no gap.
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4. Record and report what you place on the market
Keep accurate records by category and submit your returns on the regulator's timetable. Retain the sales and import data behind the figures.
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5. Finance collection and recycling
Pay your scheme fees or buy the required recycling evidence so your share of collection, treatment and recycling is financed. Set up take-back where batteries are involved.
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6. Mark every product
Apply the crossed-out wheeled-bin symbol, and add the capacity and chemical-symbol marking to batteries. Make sure batteries are removable from appliances.
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7. Repeat each year and keep details current
Renew scheme membership, update your figures, and tell the scheme or regulator if your products, volumes or business details change.
What to do next
If you are an importer or a brand-owner rather than the original maker, do not assume the duty sits with someone else. Placing goods on the UK market under your own name usually makes you the producer, so confirm your status and register in good time.
Before you sell into Northern Ireland, check that your scheme membership and registration cover the whole UK, since these regimes apply there too. If you also need to assess and mark a product for conformity before it first goes on sale, follow the separate product-conformity guidance — that is a one-off step, while the duties here continue for as long as you trade. If you are unsure which regimes catch a particular product, confirm it with a compliance scheme or the environmental regulator before your first reporting period.
Official sources
Regulators and statutory guidance on producer responsibility for electronics and batteries