Following new guidance from the UK’s Environment Agencies, overseas companies who are not established in the UK placing EEE on the UK market via indirect selling only will no longer be obligated as EEE producers from the 2025 Compliance Year.
Previously, some non-UK companies selling EEE products indirectly to the UK market could register as EEE producers in place of the local UK-based importers and/or distributors. This change has been made in an attempt to align policy with the producer definitions set out in the UK WEEE regulations.
As a reminder, producers that may be affected are encouraged to consider the following definitions:
- ‘Established in the UK’ – any business which has a degree of physical present in the UK. This can be a branch, office, or any other place where business takes place. You can find more information on the uk website.
- ‘Indirect Selling’ – you are selling only via UK importers and/or distributors (i.e., you do NOT sell directly to end-users).
What do I need to do if I am impacted by the changes above?
Any company based overseas and indirectly selling to the UK market will no longer be required to register as a producer from the 2025 Compliance Year. You will therefore need to de-register with your EEE Producer Compliance Scheme, or the Environment Agency depending on your type of registration.
If you are a company based overseas selling both directly and indirectly, you should continue to register and report EEE which you sell directly to UK end-users. Any EEE sold indirectly should now be reported by the first UK-based entity to place it on the market (i.e., importer, distributor, retailer).
If your company is based in the UK, and you have EEE which was previously declared by an indirect seller established outside of the UK, you will now need to report these volumes, and are encouraged to liaise with your Compliance Scheme and/or the Environment Agency to determine if any resubmissions are needed for past periods.
If you are selling to the UK market and are unsure of your requirements, please contact us for support or additional information at CGlobal-Sales@landbellgroup.com.
Published October 16, 2024
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