We have been advised on behalf of the Office for Product Safety and Standards (OPS&S, formerly known as Regulatory Delivery) which is the new regulator for the distributor obligations under the WEEE regulations, to make sure we kindly remind our members of the following WEEE obligations as a “Distributor”:

Under the UK Waste Electrical and Electronic Equipment (WEEE) regulations 2013 (including amendments) a distributor is defined as “any person in the supply chain who makes an item of EEE available on the market but a distributor may also be a producer”. Make available on the market means “any supply of a product for distribution, consumption or use on the market of a Member State in the course of a commercial activity, whether in return for payment or free of charge”.

Therefore, even if you are fulfilling your obligations as a producer (as you may import, manufacture or rebrand EEE within the UK),  you may also be a distributor (including selling on-line or providing free of charge) of consumer or dual use EEE (guidance available here: https://www.gov.uk/guidance/business-to-consumer-b2c-and-business-to-business-b2b-eee-and-weee-how-to-correctly-identify) and we recommend that you ensure you are also fulfilling your distributor obligations.

As a distributor of consumer or dual use EEE you must offer take back on a one for one, like for like basis, meaning when a new product is purchased an equivalent piece of EEE can be returned. Alternatively, if you are supplying EEE to consumers you can join the UK’s Distributor Takeback Scheme (DTS) where you make a payment to support Household Waste Recycling Centres (HWRCs) and can then advertise the list of HWRCs to your customers.