Be Seen Go Green

I sell  directly to household users. Am I a distributor?

• Yes.

I sell Electrical & Electronic Equipment only to Offices users. Am I a distributor?

• Yes, but some distributor obligations do not apply in relation to sales of non-household EEE.
  However your customers may ask you for information about the registered producer of
  the EEE, and that producer may ask you for information about non-household
  customers and sales so that they can report their sales correctly. Please note sole traders and partnerships are classed as consumers.

I only sell second-hand equipment. Am I a distributor?

• Distributor obligations only apply in relation to the provision of EEE that has not been
  previously placed on the UK market. However you will still require {permits, licences] to operate

I sell only ex-demonstration, mail-order returns, open-box or surplus EEE. Am I distributor?

• Yes, ex-demonstration, “open box” EEE and mail-order returns are regarded as new
  EEE and therefore normal distributor obligations apply.

I provide Electrical & Electronic Equipment incidentally to my main business (credit card rewards, loyalty bonus, and advertising). Am I a distributor?

• Yes. If you provide EEE to household users on a commercial basis, then you are a
  distributor.

If I allow take-back, do I have to allow consumers to bring back any Waste Electrical & Electronic Equipment?

• Consumers may bring back items of equipment which they are replacing with an
  equivalent new product on a like-for-like basis. If you offer take-back you must do this
  for all types of EEE you sell. So, for example, a consumer buying a new microwave
  oven would be entitled to take-back of one old microwave oven as WEEE. You would
  not be expected to take back a completely different type of equipment, for example a
  washing machine for a DVD player.

What is “equivalent” Waste Electrical & Electronic Equipment?

• Distributors are expected to adopt a reasonable interpretation of equivalence. For
  example, a customer should be allowed to bring back an old video cassette recorder
  when purchasing a new DVD player/recorder, as even though this is not strictly a like-for-
  like replacement, the new product is intended to fulfil the same function.

How long after a purchase should I give consumers to bring back their Waste Electrical & Electronic Equipment?

• The WEEE Regulations do not lay down a minimum period for which take-back should
  be offered. However, given that it is unlikely that customers will carry WEEE with them
  while shopping, distributors are should accept WEEE within a reasonable period following a sale (e.g. 28 days). You may wish to endorse the sales receipt to govern
  deferred in-store take-back of WEEE

Are faulty items returned to me classed as Waste Electrical & Electronic Equipment?

• No. Items intended for repair and return to use are not regarded as waste. However,
  once it becomes clear that items are beyond repair and hence are to be discarded they
  should be regarded as WEEE. From this point they should be dealt with in accordance
  with the WEEE Regulations.

Can I charge customers if I offer collection-on-delivery services?

• It remains at the discretion of retailers whether to charge or not for any collection on
  delivery services that they provide to consumers, but any such services would not fulfil
  your take-back obligations.

How do I do take-back if I am a mail order distributor?

• Distance sellers must either join the DTS, offer in-store take-back through one of their
  local stores (where these exist) or provide the customer with an alternative local route
  for free take-back. The distributor must tell customers how they can dispose of WEEE,
  for example via their catalogue, website, sales receipts, or through a leaflet included
  with the purchase.

The producer demands a large product display to show his recycling costs. What should I do?

• The WEEE Regulations give producers the right to display any costs associated with
  recycling historical WEEE. A distributor of EEE may not obscure or remove a sticker on
  the product, but would not be obliged to erect an in-store display with the costs.
  Producers and distributors may negotiate between themselves the appropriate means
  of display.

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