Following guidance issued by the UK environment agency in July 2024, a revised approach to the application of the producer definition under the UK Waste Electrical and Electronic Equipment (WEEE) regulations has applied from the 2025 compliance period onwards.  

The clarification affects companies established outside the UK that place electrical and electronic equipment (EEE) on the UK market exclusively through indirect sales channels. While some non-UK companies had previously been permitted to register voluntarily as UK WEEE producers, this approach is no longer accepted. Instead, producer obligations must since then be assigned to the legal entity that meets the definition of a producer under the UK WEEE Regulations. 

Selling Directly or Indirectly  

The key distinction is whether a company sells directly or indirectly into the UK market. Direct selling refers to sales made directly to end-users, while indirect selling refers to sales made through importers, distributors or resellers. 

 From the 2025 compliance period onwards, non-UK companies that sell EEE into the UK exclusively through indirect sales channels are no longer considered UK WEEE producers. Instead, responsibility shifts to the first UK-established entity placing the products on the UK market. This means that the UK-based entity becomes responsible for:  

• Producer registration 
• Reporting EEE placed on the market 
• Financing the associated WEEE obligations  

Non-UK companies that sell directly to UK end-users can still qualify as producers and remain responsible for their own WEEE obligations.  

Why Was This Clarification Introduced?  

According to the UK environment agency, the revised approach is intended to ensure that producer obligations are assigned to the correct legal entity. It also aims to improve reporting accuracy, reduce the risk of double-counting EEE, simplify audits and support more effective enforcement.  

Online Marketplaces Have Taken on Extended Reporting Obligations  

The second key change concerns online marketplaces. Under the revised framework, online marketplace operators are now responsible for reporting the non-UK volumes sold via their platforms. The aim of this change is to improve data transparency whilst reducing duplicate reporting obligations. For this reason, since August 2025, non-UK businesses selling their products to end consumers in the UK via online marketplaces are no longer responsible for reporting these volumes.  

What Businesses Should Do Now  

If not already done, businesses selling EEE into the UK should review their sales models, reporting structures and contractual arrangements to ensure that producer obligations are assigned to the correct legal entity.  

For companies operating international distribution networks, understanding the distinction between direct and indirect sales is becoming increasingly important to maintain compliance and avoid reporting errors. Do you have any questions? Please do not hesitate to contact us. 

After the first revision of WEEE Directive being published in 2012, European legislators have currently once again been reassessing its effectiveness and came to a clear conclusion: Changes are needed in order to 

• Slow down the growth of WEEE 
• Improve re-use and repair in order to prolong product lifecycles 
• Set incentives for sustainable product design.

The objective is clear: To make the legislation fit for purpose for the future and aligned with the broader ambitions of the circular economy.  

This review intends to reflect the changing realities of the market, including the emergence of new technologies (such as lithium-ion batteries and increasingly miniaturised components), new product categories (such as IoT devices, wearables and e-mobility equipment), as well as evolving waste streams, characterised by growing volumes of small electronic devices, a higher share of battery-containing products, and increasingly complex material compositions. Despite the progress made, nearly half of WEEE is still not properly collected, and only around 40% is effectively recycled. 

Key Questions Shaping the Future Framework 

As the revision process unfolds, the below fundamental questions are being discussed at EU level: 

• How can a better harmonisation and simplification be achieved across the Member States. Should WEEE remain a directive or be transposed into a regulation, as previously done both for Batteries as well as Packaging? 
• With the extraordinary importance for securing secondary raw material and need for critical raw material not being broadly available in Europe: Should WEEE continue as independent legislation or become integral part of the new Circular Economy Act? 

A clear direction from the European Commission is already emerging: greater harmonisation and simplification across the EU to reduce complexity and make EPR compliance easier for producers, especially when coming from the SME sector.

What Changes Can Be Expected? 

While the final shape of the revised WEEE framework is still under development, several key changes are already becoming apparent. The revision is expected to address amongst other the below structural weaknesses and to strengthen the circular economy performance of the legislation, including:

• Higher or revised collection targets for WEEE streams
• Stronger focus on recovering critical raw materials (CRMs), which are currently insufficiently captured in existing systems
• Attempt to harmonise Extended Producer Responsibility (EPR) schemes across Member States
• Improved reporting formats and greater transparency: Reduce national fragmentation through a regulation instead of a directive to ensure aligned implementation of law in all Member States
• Stronger enforcement measures, particularly regarding online sellers and free-riders.

Harmonisation: A Shared Objective 

The idea of simplification and harmonisation is not only driven by policymakers, but also strongly supported by PRONEXA and its PRO network across Europe. It has been a core principle from the beginning, when we were founded more than 10 years ago: Simplify EPR compliance for producers across Europe. Initially focussing on WEEE and Batteries, we now also cover Packaging obligations for our customers in 29 countries, with Switzerland as country number 30 expected to come up with Packaging EPR legislation, soon. 

Although not being able to harmonise legislation by ourselves, we successfully managed to implement a system that allows to handover the existing complexity to a reliable compliance partner, who manages that complexity on your behalf. 

What It Means for Producers 

For producers of electrical and electronic equipment, the upcoming revision of the WEEE Directive is both a challenge and an opportunity. On the one hand, the expected changes will force producers to increasingly amend the well-established linear business models into new circular ones. Common efforts will also be needed to achieve longer product life, easier recovery of material and the setup of functioning markets for secondary raw material. 

Whatever Changes Will Ultimately Be Implemented

• PRONEXA and our PRO network partners are monitoring regulatory developments closely 
• We are guiding producers when adaptations are needed 
• Independent from regulatory changes, we are offering already today a highly harmonised EPR requirements handling 
• Improving data quality and reporting capabilities will be required to adapt to the further requirements to be expected. 

At the same time, companies should consider how product design, recyclability, and material recovery strategies can support future compliance requirements – particularly in light of the growing focus on critical raw materials. 

The message is just as clear for businesses: those who prepare early will be best equipped to navigate the transition and benefit from a more harmonised European system.

Join PRONEXA on this journey and get in touch via the QUICK OBLIGATION CHECK if you would like further advice. 

For manufacturers of electrical and electronic equipment (EEE), the crossed-out wheelie bin symbol is often seen as nothing more than a regulatory formality. In reality, it is a key instrument of EU waste policy, linking product design, consumer behaviour and end-of-life management within the circular economy. 

The symbol is required by Directive 2012/19/EU on waste electrical and electronic equipment (WEEE). Manufacturers placing electrical and electronic equipment on the EU market must ensure that products are marked in accordance with the following provisions: 

• Article 14 of the Directive (information for users) 
• The technical labelling standard EN 50419 

This obligation is not merely administrative in nature. It ensures that environmental information reaches the end user directly at the point where decisions about disposal are made. 

Why Most Symbols These Days Contain a Black Bar 

Many products have a solid black bar under the wheelie bin symbol. This detail has a specific legal meaning: the bar indicates that the product was placed on the EU market after 13 August 2005, the cut-off date specified in the original WEEE Directive, which makes it possible to distinguish between the following products: 

• Historical WEEE that was placed on the market before this date (for which the end user has the responsibility of collection and recycling)
• New WEEE that was placed on the market after this date (for which the producer has all related obligations, being the first one to put the product onto the market in a specific country) 

This distinction remains important for authorities and PROs, as it helps to determine financial responsibility for waste disposal. 

A Direct Means of Communication for End Users 

The crossed-out wheelie bin is one of the EU’s most direct means of communication in the field of environmental protection. It is intended to inform consumers that electrical and electronic equipment must not be disposed with unsorted waste. By stipulating that the label must be visible, legible and durable, the directive ensures that private end users as well as professionals understand that they must: 

• dispose equipment via separate collection systems 
• avoid unsorted and mixed waste 
• return products to authorised WEEE collection points 

This simple visual signal is not a sign that the product and the producer are registered and compliant, a frequent misunderstanding we are facing in our daily operations.

Why the Symbol Is Important For Producers 

From a systems perspective, correct labelling directly contributes to the efficiency of collection and material recovery. In this way, the symbol not only supports compliance with legal requirements, but also operational efficiency along the entire waste management chain. Clear information for end users helps to:

• reduce the amount of WEEE ending up in residual waste 
• increase recovery rates for valuable materials such as copper, aluminium and rare earth elements 
• limit environmental and health risks from hazardous components 
• improve overall collection rates for WEEE, an important performance indicator under EU law 

While authorities carry out awareness campaigns to improve separate collection, product labelling remains the only information permanently affixed to the device itself – it is therefore a fundamental element of the WEEE system. 

Should you require further information about the crossed-out bin icon or your obligations as a producer under EPR regulations, do not hesitate to reach out to us via our Quick Obligation Check.

For years, companies have viewed waste management as a cost factor. Collection targets, reporting requirements, recycling obligations. Under Extended Producer Responsibility (EPR), these were strictly viewed as compliance tasks rather than strategic opportunities. But something has changed. Quietly and steadily, a new paradigm is shifting governments’ view of waste and manufacturers can no longer afford to ignore it. 

Welcome to the age of urban mining, where yesterday’s discarded products become tomorrow’s competitive advantage in the supply chain. This shift is fully in line with the European Green Deal, which places the circular economy, resource efficiency and reduced dependence on fragile raw material imports at the heart of European industrial strategy. 

The Hidden ‘Mines’ in Our Cities 

Every laptop, every battery, every vehicle and every device contains metal and material deposits that are becoming increasingly difficult – and politically risky – to extract from nature. Cobalt from conflict zones, rare earths from geopolitically tense regions and critical raw materials tied to volatile global markets. 

But while the world worries about supply shortages, these very materials lie in our cities, waiting to be recycled. The richest mines are no longer underground, but in drawers, garages and recycling centres. This is the logic that shapes today’s waste regulations. The pressure to recycle is not only ecological, but also strategic. In other words, waste isn’t leaving your value chain. It’s coming back as a resource. 

How Urban Mining Is Practically Implemented 

Three changes are already underway: 

1. Eco-design: products designed for recycling 

Manufacturers are redesigning products so that they can be easily dismantled, sorted and recycled. What used to be considered a cost factor at the end of a product’s life is now becoming an opportunity for material recovery. 

2. Better collection and traceability 
With the introduction of digital product passports, return systems and more transparent collection channels, it will be possible to better track where valuable materials end up after use. This will ultimately enable companies to recover these materials more reliably and reintegrate them into production.

3. New cooperation models 

Producers, compliance systems and recycling companies are working more closely together than ever before. When they share data and plans, this leads to higher recovery rates, lower costs and more stable access to scarce materials. 

Why This Is Important for Companies Right Now 

Companies that still view waste solely as a compliance issue are missing the big picture. Urban mining is becoming an indispensable strategy for 

• reducing dependence on unstable global supply chains,
• lowering material costs, 
• achieving circular economy goals, and 
• strengthening brand and ESG performance. 

Working Together to Make Circularity Happen 

Together, both producers, PROs, and ourselves at PRONEXA can work more closely together to make the circular economy a reality and improve sustainability.

In case of any questions about Urban Mining, your contribution as a Producer and EPR in general contact us today!

There are millions of tons of electrical and electronic devices and batteries in use and each year more are put on the market.

Electrical and Electronic Equipment (EEE) permeates every aspect of our modern lives. It has long become impossible to imagine our everyday lives without batteries: Powerful batteries and accumulators are used in many modern electrical devices. According to forecasts by the European Commission, global consumption of lithium-ion batteries alone will increase 14-fold by 2030. Between 2020 and 2040, the European Commission expects the number of recyclable lithium batteries to increase by a factor of up to 700! But what happens to Waste Electrical and Electronic Equipment (or “WEEE”), batteries and the associated packaging at the end of their service life?

The number one goal is the proper disposal of WEEE, used batteries and packaging. This allows valuable raw materials to be recovered and returned to the production cycle. The circular economy and recycling are therefore also an important aspect of the European Green Deal. Unfortunately, this is not yet something that has been achieved, which means that every sound contribution to improving matters, such as what we do for our customers, is a step in the right direction in view of the constantly increasing volumes of waste.

What Happens to WEEE and Used Batteries?

In Europe, WEEE is the fastest growing waste stream, with growth of 3-5 percent per year. The global WEEE mountain is already forecast to reach 54.7 million tons in 2021, which is more than the total weight of the Great Wall of China, the world’s heaviest man-made object.

According to the Global E-waste Monitor 2020, 53.63 million tons of electronic waste was produced worldwide in 2019 – a 21% increase in just 5 years!

Only 35 percent of this waste is collected and recycled in Take-Back Systems. The other 65 % are either illegally exported or recycled under conditions that do not meet EU standards (this applies to the majority of items), or incorrectly disposed of in household waste. The same lack of care applies to the proper disposal, collection and recycling of batteries.

Compliance – Responsibility for People and the Environment as a Joint European Solution

Proper disposal is not down to voluntary commitment or a sense of responsibility on the part of individual producers; it is a legal obligation. The European Commission drafted the first Europe-wide directive back in 1988. For the first time, a European Directive had been formulated covering the introduction to market, return and environmentally compatible disposal of Electrical and Electronic Equipment, thus establishing the principle of Extended Producer Responsibility (EPR).

Based on the polluter pays principle and product responsibility, producers are required to finance waste collection and recycling – what are known as WEEE costs. The producer is understood not just as the actual manufacturer, but also as whoever places a product on the market for the first time in a given EU member state. Thus, producers as understood by the law also include online retailers (when exporting to foreign end users – both business and private) as well as importers.

Subject to constant adaptation, the current version of the European WEEE Directive (Directive 2012/19/EU for Waste Electrical and Electronic Equipment) came into force on July 4, 2012. For example, the WEEE Directive 2012/19/EU has stipulated relative collection rates as of 2016. These are calculated on the basis of the average amount of Electrical and Electronic Equipment placed on the market in the preceding 3 years. As of 2019, 65 percent of the quantity placed on the market must be collected.

The Directive is a legal framework, but it has been implemented differently at a national level in the member states. Thus, the WEEE Directive forms the basis for the German Electrical and Electronic Equipment Act (“ElektroG”). This incorporates the WEEE Directive 2012/19/EU into German law in the form of German environmental legislation. This decentralised legal situation requires producers to register and meet their producer obligations separately in each country relevant to them. In the same way, there are also national statutory regulations for batteries and for packaging, each of which has to be observed by producers.

The aim of the WEEE Directive is to prevent or reduce the generation of electrical and electronic waste (WEEE) and to ensure environmentally sound disposal. Appropriate measures for waste prevention, take-back and recycling are intended to conserve resources in order to protect the environment and health.

DIRECTIVE 2012/19/EU of July 4, 2012 on waste electrical and electronic equipment (WEEE)

Which Product Categories Are Covered by WEEE?

In Annex I-IV of the EU Directive you can find a non-exhaustive list of the categories of waste electrical and electronic equipment covered, with examples for each product category.

Since 2018, the scope of the WEEE Directive has been adapted and 6 categories have been introduced to replace the previous 10 categories. In addition, the directive was adapted to open scope, meaning that the categories are no longer considered exhaustive. Since 2018 essentially all electrical and electronic equipment is covered by the WEEE Directive.

Who Is Considered a Producer Under the WEEE Directive?

The “producer” in the sense of the WEEE directive is not necessarily the manufacturer of the product, but the legal entity who puts the product the first time on the market in a given country and is therefore regarded as the “producer” of WEEE. This can be the manufacturer, but also (importing) wholesalers or retailers as well as distributors of electrical and electronic equipment.

When a company sells by means of distance selling to (private or professional) end users into other countries in Europe, then this company needs to register in each individual country it is selling to.

The legal status may differ per country depending on the sales and organizational structure, so it is important to analyse the legal status in advance in order to know the exact obligations per country.

Are you unsure whether you are a producer or not? We can provide you with a detailed assessment and step by step guidace on how to fulfil your obligations per country. Get in touch.

What Are Your Obligations as a WEEE Producer?

The WEEE Directive under the EU Waste Management Framework first introduced the principle of Extended Producer Responsibility back in 2012. EPR policies extend a producer’s financial and/or operational responsibility for a product at its end-of-life stage and shifts the waste managemernt costs to producers.

To meet these obligations, producers need to take care of the following topics:

• Registration: As a producer, you must register with the national WEEE authority in each country in which you put electrical and electronic equipment on the market. Once registration is complete, the producer will receive a registration number (at least in most of the European countries) that confirms your registration as a WEEE producer.
• Financing the take-back: The producer is obliged to finance the collection, take-back, recycling and recovery of Waste Electrical and Electronic Equipment (WEEE). To do that, producers can join an existing collective take-back organisation or theoretically set up their own take-back system (due to its requirements of national coverage and the need for contracts with collection and recycling companies, this solution in practical terms is often not feasible). In each EU member state, producers have established take-back systems, so-called “Producer Responsibilities Organizations” (PROs), who are accredited by the government to organise the legally compliant processing of WEEE for their member companies and in most cases work on a non-for-profit basis for their members.
• Information for recyclers and end consumers: Products must be marked with the crossed-out bin symbol to indicate that they must not be disposed of with normal household waste. Consumers should also be informed about the proper disposal of the product. Recyclers and treatment facilities should be informed about the components and materials used in the products.
• Reporting: Producers must regularly report the quantities of electrical and electronic equipment placed on the market in each country to the relevant national authority.
  Mostly this is not done directly, but through the PROs who take over the reporting to the authorities.