Q1 What are my Compliance options as a retailer?
Retailers, known as distributors under the Waste Electrical and Electronic Equipment (WEEE) regulations,
of household Electrical or Electronic Equipment (EEE) have to ensure that
WEEE from private households can be returned free of charge on a one-for-one basis
(where they purchase equivalent EEE that fulfills the same function) for recycling.
Distributors have two options in order to comply with these legal obligations:
- offer free in store take back
- join the Distributor Take back Scheme (DTS)
Distributors with an EEE sales area of 400m² or more must:
- offer free in-store take back of very small WEEE (with dimensions of less than 25cm)
- join the Distributor Take back Scheme (DTS)
If more than 25% of stores meet the 400m² criteria the DTS member
will be required to pay an additional 25% of applicable DTS membership fees.
Q2 What is free in store take back?
Retailers who have not joined the DTS have to ensure that WEEE from
private households can be returned to them free of charge, on a
one-for-one basis. This is providing that the WEEE returned is of
equivalent type to, and has fulfilled the same function as the new EEE that is purchased.
For example, an old video player can be returned when purchasing
a new DVD player, regardless of the brand and where the old one was originally purchased.
Retailers taking back WEEE must return it for recycling by contacting a
producer compliance scheme, and delivering it to them for treatment.
The new WEEE regulation introduced in 2013 brought the introduction of
an additional obligation on larger distributors.
“A distributor who supplies new EEE from a retail premises
with a sales area relating to EEE of at least 400m² must provide for
the collection of very small WEEE free of charge to the end user of
the EEE with no obligation to buy EEE of an equivalent type.
Such collection must take place at the retail premises or in its immediate proximity.”
The DTS member alternative to this is to make an additional payment of 25% of the total fees.
Q3 What is the DTS?
The DTS is a government approved scheme operated by Valpak Retail WEEE Services Ltd
Q4 How much does the DTS cost to join?
Q5 What do I need to do to become a member?
You will need to register here
Q6 When do I need to register?
If you are currently distributing EEE and do not wish to offer Take back
you should register for the DTS as soon as possible after 1 January 2020.
The regulatory authorities have allowed a period of grace for returning members
to complete their registration until 31 March 2020.
If you wish to join after this date you can still complete registration and make payment
in order to be considered a member and opt out of offering in store take back.
Q7 I am a returning Band A member, how do I offset some of my DTS membership costs?
If you have at least one physical store then you can choose to join the DTS
8 months (to the end of August 2020) or
12 months (to the end of December 2020).
If you choose the shorter membership then your fees will be reduced accordingly but
you will be required to offer in-store take back from 1 September 2020.
Q8 How do I know my registration with the Distributor Take back Scheme (DTS) has been successful?
Once you have completed registration, you will be asked for payment
if you are a Band B or C member. Band A members will receive a fee estimate and
will receive their invoice for payment before 31st March 2020.
You will receive a confirmation email when registration is complete.
Once Valpak have received payment you will then be considered a full member of the DTS.
In the case of Band A members those who complete registration will be considered
full members of the DTS however if payment is not made by the deadline stated
on the invoice then their membership will be invalid.
Q9 Can I charge customers for returning waste electrical and electronic equipment (WEEE) to me?
No, if you have not joined the Distributor Take back Scheme (DTS)
you must provide means for your customers to return old electrical and electrical equipment (EEE)
to you free of charge, upon purchasing a new piece of EEE on a one for one, like for like, basis.
If you are a member of the DTS you should direct customers to their nearest suitable
Local Authority collection site as shown on
As outlined in Q2, from 2014 larger retailers must also offer to take back
all small WEEE from consumers whether or not a purchase has been made.
Q10 Can I charge for collection of waste electrical and electronic equipment (WEEE) on delivery?
Yes, if you are offering collection on delivery you can charge for the logistical costs of the service,
but this should be related to the actual costs of the service.
The only circumstance where you cannot charge is, if you are not a DTS member and
do not allow WEEE to be deposited at your premises or other convenient collection point.
In this instance you should not charge for collection.
You cannot charge your customer for the cost of treatment, a 'recycling fee'.
The cost of treatment of the item will be met by the producers.
Q11 If I am offering collection on delivery of waste electrical and electronic equipment (WEEE),
what do I do with the WEEE I collect?
Distributors have to ensure that any WEEE collected through either in store take back,
collection on delivery or any other means, is treated and disposed of in an environmentally sound manner.
Distributors are generally not allowed to dispose of collected WEEE at Civic Amenity sites
(unless the site allows commercial waste), regardless of membership to the DTS.
Instead distributors should contact a Producer Compliance scheme and deliver the WEEE to them,
to be treated at the cost of the producer.
It is likely that the Producer Compliance schemes will ask for the WEEE to be delivered to an
Approved and Accredited Treatment Facility (AATF),
distributors will need to fund the transport of WEEE to the AATF or location specified by the Producer Compliance scheme.
to see the Public register of producer compliance schemes.
Please also be aware that if you are transporting waste you will be required to meet
any applicable requirements under relevant waste legislation,
including, but not limited to, waste Duty of Care.
Further information and guidance can be found on GOV.UK, including
Waste Duty of Care: Code of practice
and Hazardous Waste Rules.
Q12 If I join the Distributor Take back Scheme (DTS), how long am I exempt from providing free in store take back?
By joining the DTS you will be exempt from having to offer in store take back depending on Band and membership choice:
- Band A with physical retail stores: 31st August 2020 or 31st December 2020 depending on membership
- Band B with physical retail stores: 31st December 2020
- Band A & B online/distance sellers only: 31st December 2021
- Band C members: 31st December 2021
Q13 What if I have no annual sales turnover of electrical and electronic equipment (EEE) to declare (e.g. I am a new company)?
If you are unable to provide details of your annual turnover from EEE sales,
you will need to make a reasonable assumption in order to provide
an estimate of what you expect your annual turnover from EEE sales to be/have been.
Please contact Valpak at DTS@valpak.co.uk
before beginning the registration process.
Q14 What if I am giving electrical and electronic equipment (EEE) away as a promotional gift ?
Your annual turnover from EEE sales should be based on the value of equipment
you have supplied, not just that you have sold. Therefore you should assume
a reasonable sales value for the promotional items. If you are also required
to provide information regarding the number of items of EEE sold, promotional items
should be included with the number of units.
Q15 If I join the Distributor Take back Scheme (DTS), how will I inform my customers of where to take their waste electrical and electronic equipment (WEEE)?
As a member of the DTS, distributors will have to inform their customers of
the availability of facilities for the return of WEEE.
These are called the Consumer Information Obligations (CIOs).
The DTS will assist its members in meeting their CIOs through
providing information and promotional material through its recycle-more via
the DTS members area and
Q16 Where can I find information on what is considered household and non household electrical equipment
“WEEE from private households” means WEEE which comes from private households and
WEEE which comes from commercial, industrial, institutional and other sources which,
because of its nature and quantity, is similar to that from private households. Waste from EEE
likely to be used by both private households and users other than private households shall in
any event be considered to be WEEE from private households
for more details please visit this web page.
Q17 What is dual use?
Products designed for both household and non-household use are considered dual use equipment.
Equipment that is considered to be dual use must be reported as business to consumer (B2C) equipment.
Q18 Do Local Authorities have to accept any equipment from businesses at DCF’s?
No. The decision on whether to accept business waste of any sort on to LA CA sites is
for the authority and so it is under no obligation to accept any WEEE from
business users regardless of the type of equipment.
If they do accept so called “dual use” equipment then it should be collected along with similar WEEE from households
If they also choose to allow normal business WEEE on to their sites
(commercial freezers for example) then this should be collected and treated separately.
The alternative for an end holder of WEEE from private households
(which would include “dual use” equipment) is to return the equipment
to their nearest Producer Compliance Scheme collection point for
free of charge treatment, under regulation 52.
The end holder would be responsible for the costs to transport
the equipment to the collection point and also responsible to ensure that
this is completed in line with applicable legislative requirements,
for example Waste Duty of Care, ensuring the waste carrier is suitably licensed etc.
Different Producer Compliance Schemes have different collection points,
therefore the holder would need to contact them to find their nearest collection point.
A list of Producer Compliance Schemes can be found
Q19 Do obligated distributors only have to take back WEEE from householders or
should they now also take back from business end users?
Any distributors, whether they sell B2C or dual use EEE and who are not DTS members
must offer take back of WEEE from private households which now includes dual use WEEE.
Provided they do not have stores over 400m² EEE sales area then they only need to offer
take back on a one for one and like for like basis and only when the holder has purchased new equipment.
There is no obligation on distributors (whether newly obligated or not) to suddenly have to
take back large quantities of dual use equipment unless they have at the same time
supplied similar quantities of new equipment of a similar type.
This includes offering take back of dual use WEEE from businesses as the
“WEEE from private households” definition now includes this material,
but only on a one for one, like for like basis.
Therefore, if a small business is buying a new domestic fridge for their office
from a retailer who is not a DTS member the retailer should offer to take back
the old one but only when the new purchase is made.
Similarly, if a business is buying 100 new laptops that are dual use
from a non-DTS supplier then the supplier would again be expected to
offer to take 100 old ones back, although this would probably be covered by their supply contract.
In any event distributors do not need to offer take back of any business WEEE
which is still clearly intended for business use only, i.e. not dual use.
In any case DTS members do not need to offer take back, although of course
they may choose to do so if they wish for other reasons.
Q20 Does membership of the DTS and fulfilling the associated Consumer Information Obligations (CIOs) mean I have fulfilled all my obligations as a seller of EEE?
No, aside from distributor responsibilities which are applicable when
selling EEE direct to householders in the UK, you may also have responsibilities
as a producer of electrical equipment. If you are manufacturing or selling EEE
under your own brand in the UK, resell equipment made by someone else
under your own brand, import EEE on a commercial basis or are established outside the UK
and supply EEE directly to the UK market via distance selling e.g. online
then you are likely to be a producer and have additional legal responsibilities.
Please refer to this government website
which details responsibilities for producers of EEE including registration with a producer compliance scheme.
Q21 What EEE is in scope? And what EEE sales do I include in my registration?
From 1st January 2019 the WEEE Regulations apply to all electrical and electronic equipment
unless it fits into an exclusion or exemption.
For example, household luminaires and light bulbs are now in scope
whereas previously they were excluded (for example, table lamps).
Distributors registering for the DTS need to include all EEE sales in their DTS registration.
Further guidance on items in scope can be found