---
title: "We sell electronics and are not registered for take-back"
description: "Under the WEEE Directive 2012/19/EU, whoever first places electrical and electronic equipment on a Member State's market under its own name, or brings it in from another country, is a producer there. Producers register in that Member State's national register, finance the collection and treatment of waste from their products, mark them with the crossed-out wheeled bin and report the quantities they place on the market."
type: "problem"
url: "https://www.conphora.com/solutions/problem/weee-registration/"
markdown: "https://www.conphora.com/solutions/problem/weee-registration.md"
locale: "en"
language: "en"
updated: "2026-10-04"
author: "Conphora compliance team"
publisher: "Conphora"
source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02012L0019-20240408"
tags: ["WEEE", "batteries-electronics"]
license: "Free to quote with attribution and a link to the page"
---

# We sell electronics and are not registered for take-back

Under the WEEE Directive 2012/19/EU, whoever first places electrical and electronic equipment on a Member State's market under its own name, or brings it in from another country, is a producer there. Producers register in that Member State's national register, finance the collection and treatment of waste from their products, mark them with the crossed-out wheeled bin and report the quantities they place on the market.

## Why this happens

The WEEE Directive 2012/19/EU puts the cost of collecting and treating waste electrical and electronic equipment on the producers. Since 15 August 2018 it applies to all electrical and electronic equipment, classified in the six categories of Annex III, with a short list of exclusions (Article 2(1)(b), (3) and (4)). Equipment means anything that depends on electric currents or electromagnetic fields to work properly and is designed for up to 1 000 V AC or 1 500 V DC (Article 3(1)(a)). [1]

Who is the producer depends on the country, not on the factory. A business is the producer in a Member State if it is established there and makes equipment under its own name, resells other suppliers' equipment under its own brand, or places equipment from a third country or another Member State on that market on a professional basis. A business that sells by distance communication into a Member State where it is not established is also a producer there (Article 3(1)(f)). A reseller is not the producer where the producer's brand appears on the equipment. [1]

Each Member State keeps a register of producers to monitor compliance (Article 16(1)). Producers register with the information in Annex X, Part A, keep it up to date, and report the quantities they place on the market and the waste collected and treated, by category, under Annex X, Part B (Article 16(2)). [1]

The financing duty follows the product. Producers finance at least the collection from collection facilities and the treatment, recovery and environmentally sound disposal of household waste from their own products, individually or through a collective scheme, and give a guarantee when placing a product on the market (Article 12(1) and (3)). They mark products with the crossed-out wheeled bin of Annex IX and a mark showing placement after 13 August 2005, preferably according to EN 50419:2022 (Articles 14(4) and 15(2)), and inform treatment facilities about each new equipment type within one year (Article 15(1)). [1]

## How to solve it

1. **Check that your products are in scope** Electrical and electronic equipment is equipment that depends on electric currents or electromagnetic fields to work properly, designed for up to 1 000 V AC or 1 500 V DC. Since 15 August 2018 the directive applies to all such equipment, classified in six categories, except the exclusions listed in Article 2(3) and (4), such as large-scale fixed installations and means of transport other than electric two-wheel vehicles that are not type-approved.
2. **Work out whether you are the producer** You are the producer in a Member State if you are established there and make equipment under your own name, resell other suppliers' equipment under your own brand, or place equipment from a third country or another Member State on that market on a professional basis. A reseller is not the producer when the producer's brand appears on the equipment. Selling at a distance into another country is a separate case.
3. **Register in the national register** Each Member State keeps a register of producers. On registration you give your name and address, national identification and tax number, the categories of equipment, household or non-household use, brand names, how you meet your financing duty and your selling technique, and you keep that information up to date.
4. **Set up the financing of take-back** For household equipment, each producer finances the collection from collection facilities and the treatment, recovery and disposal of the waste from its own products, individually or through a collective scheme. When placing a product on the market, the producer provides a guarantee that this will be financed, for example through a scheme, recycling insurance or a blocked bank account. Business-to-business equipment has its own financing rules.
5. **Mark the products and inform treatment facilities** Mark each product with the crossed-out wheeled bin, preferably in line with EN 50419:2022, and with a mark showing it was placed on the market after 13 August 2005. If size or function does not allow it, print the symbol on the packaging, the instructions and the warranty. Within one year of placing a new type on the market, give treatment facilities free information on its components, materials and dangerous substances.
6. **Report what you place on the market** Report to the register, by category, the quantity of equipment you placed on the national market by weight and the quantities collected, recycled, recovered and disposed of. The Commission sets the format of registration and reporting and the frequency of reporting by implementing act (Article 16(3)).

## What you need to show

- **Registration in the national producer register** — You, or your authorised representative (WEEE Directive Article 16(2)(a)–(b) and Annex X, Part A)
- **Proof of the financial guarantee or scheme membership** — Your collective scheme, insurer or bank (WEEE Directive Article 12(3))
- **Reports on equipment placed on the market** — You, to the national register (WEEE Directive Article 16(2)(c) and Annex X, Part B)
- **Information for treatment and re-use facilities per new equipment type** — You, as the producer (WEEE Directive Article 15(1))

## If you do nothing

- **The guarantee is due when the product is placed on the market** — Member States ensure that each producer provides a guarantee when placing a product on the market showing that the management of all its waste will be financed (WEEE Directive Article 12(3)).
- **Register data is what inspectors check first** — Member States inspect and monitor the implementation of the directive, and those inspections at least cover the information reported in the register of producers (WEEE Directive Article 23(1)(a)).
- **Penalties under national law** — Member States lay down effective, proportionate and dissuasive penalties for infringements of the national provisions adopted under the directive (WEEE Directive Article 22).

## Questions

### We only resell branded products bought in our own country. Are we a producer?

Usually not. A reseller is not the producer if the brand of the producer appears on the equipment (WEEE Directive Article 3(1)(f)(ii)). You are a producer if you bring the equipment in yourself from a third country or another Member State and place it on the market on a professional basis (Article 3(1)(f)(iii)).

### Does one registration cover all EU countries?

No. Each Member State keeps its own register, and a producer is registered in each Member State where it is the producer (WEEE Directive Article 16(1)). National registers link to each other's websites to help with that (Article 16(2)(d)).

### The product is too small for the bin symbol. What then?

In exceptional cases, where size or function requires it, the symbol is printed on the packaging, the instructions for use and the warranty instead (WEEE Directive Article 14(4)).

### Can we show the recycling cost on the price?

Member States may require producers to show purchasers the costs of collection, treatment and disposal at the time of sale, up to the best estimate of the actual costs (WEEE Directive Article 14(1)). Whether it is required depends on national law.

### Are distributors involved in take-back?

Yes. When supplying a new product, distributors ensure that old equipment of equivalent type can be returned to them free of charge on a one-to-one basis, unless the Member State uses the derogation, and shops with at least 400 m2 of electronics sales area take back very small items (no external dimension above 25 cm) free of charge, unless an assessment shows that alternative collection schemes are at least as effective (WEEE Directive Article 5(2)(b) and (c)).

## Regulations involved

WEEE

## Sources

1. [Directive 2012/19/EU on waste electrical and electronic equipment (WEEE) (consolidated text of 8 April 2024)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02012L0019-20240408) — EUR-Lex, 2026-10-04
2. [Directive 2012/19/EU on waste electrical and electronic equipment (Official Journal L 197, 24.7.2012)](https://eur-lex.europa.eu/eli/dir/2012/19/oj) — EUR-Lex, 2026-10-04