Extended Producer Responsibility in the UK – what to know before starting sales?
Despite Brexit and the significant changes that e-retailers have had to face as a result, the UK remains a frequently chosen expansion destination. Just like in European Union countries, Extended Producer Responsibility regulations apply there as well.
Selling electronic equipment in the UK
When selling directly to end customers in the British market, sellers are obliged to register under the Extended Producer Responsibility scheme. For sales to British distributors, this obligation can be voluntarily assumed on their behalf. Small producers of electrical and electronic equipment (sales up to 5 tons annually) have a simplified registration process, requiring only membership in a British recovery organization. Manufacturers without a presence in the UK need a representative under the Extended Producer Responsibility scheme, which can be a British recovery organization.
WEEE registration takes about 4-8 weeks. After completion, the producer receives a registration number and is entered into the registry. In the UK, there is a retroactivity principle. When submitting a registration application, the quantity of goods sold in the past year must be reported.
Selling batteries and packaging in the UK
Only companies registered with the UK Companies House have an obligation to register for batteries and packaging. Additionally, British companies that have achieved turnover of over £2 million in a calendar year and introduced more than 50 tons of packaging are subject to packaging registration. Regarding batteries, registration obligations apply to British producers introducing over 1 tons of portable batteries in a calendar year.
UKCA or CE – what else should you know before starting sales in the UK?
Brexit in the context of product sales in the British market also meant a change in regulations regarding product conformity declarations (CE marking). The original regulations stipulated that manufacturers could use CE marking until the end of 2024. New regulations were to come into force from 01.01.2025, requiring products to be marked with the UKCA logo and necessitating a new declaration of conformity.
These regulations sparked quite a bit of controversy and opposition from manufacturers. On 01.08.2023, a decision was made to indefinitely extend the use of the UKCA marking. The regulations cover 18 product groups (including toys, electronic equipment, elevators). The full list is available on the ministry’s website: Policy Update: Placing products on the market in Great Britain using UK or EU product markings.