WEEE Takeback Requirements and the Distributor Takeback Scheme (DTS)

Since the regulations were introduced, retailers must either provide in-store takeback or join the Distributor Takeback Scheme (DTS). DTS membership removes the requirement for in-store takeback, instead funding Local Authority and research projects while allowing retailers to direct consumers to local amenity sites.

The WEEE Regulations state: “A distributor who supplies new EEE to a person will ensure that WEEE from private households can be returned to them free of charge and on a one-to-one basis by that person.” 

Since the regulations were introduced, retailers have been required either to implement systems that allow this or to join the Distributor Takeback Scheme (DTS).

By joining the DTS, retailers do not have to receive takeback in store and instead pay into a scheme that funds Local Authority and research projects to increase WEEE recycling rates in the UK. As DTS members, retailers could direct consumers to their Local Authority amenity site.

What Is Changing? 

From 2021 onwards, retailers in the DTS with more than £100,000 in annual electrical sales and at least one physical store have been required to offer in-store takeback of old electrical items on a like-for-like basis. This requirement remains in place. 

From 2024, online-only retailers are required to provide compliant takeback arrangements. Online marketplaces may now also be treated as “producers” where they facilitate sales of EEE from non-UK suppliers and are therefore subject to registration, reporting, and funding obligations. 

Any EEE-selling retailer that is not currently part of the DTS must already be providing takeback for consumers. 

The Secretary of State has mandated that vape sales are excluded from DTS membership. This means all retailers selling vapes, regardless of turnover or store size, must provide in-store takeback for used vapes in line with the WEEE Regulations. This applies even where vape sales fall below the £100,000 DTS threshold. Retailers may still join the DTS for other types of EEE where eligible. 

What Do Retailers Need to Do? 

The regulations set out several requirements that retailers must meet on an ongoing basis. 

Provide the Takeback System 

Retailers with physical stores must offer free, like-for-like in-store takeback when a consumer purchases a new item from them. Proof of purchase may reasonably be requested when waste electricals are handed over. 

Like-for-like refers to the function of the item. For example, a consumer buying a DVD player may return an old VHS player, regardless of where it was originally purchased or its brand. 

For retailers selling vapes, the takeback obligation applies universally. All vape-selling premises must accept used vapes in-store when a customer purchases a new vape. 

Retailers are encouraged to explore additional collection routes such as takeback upon delivery for large appliances. 

Provide Information to Consumers 

Retailers must provide clear information on: 

• What takeback systems are available 
• The consumer’s role in supporting reuse, recycling, and recovery 
• Environmental and human-health impacts of hazardous substances in EEE 
• The meaning of the crossed-out wheelie bin symbol 
• The UK’s requirement to minimise disposal of WEEE as unsorted municipal waste 
• Online sellers must ensure equivalent WEEE information is displayed for customers purchasing remotely 

Record Keeping 

Retailers must record the number of units returned under these regulations and retain this information for at least four years. Only unit counts are required for this purpose, although all standard duty-of-care requirements for waste treatment must also be met. 

Online marketplaces or fulfilment houses assessed as “producers” must also maintain records of EEE placed on the market and WEEE handled. 

Anything Else? 

Retailers with dedicated electronic sales space of 400 m² or more must offer free in-store takeback for very small WEEE (items under 25 cm on their longest side) regardless of whether a new purchase is made. 

Retailers should monitor the amount of WEEE stored onsite. Under NWFD4, retailers may store up to 30 cubic metres of WEEE for up to 3 months before it must be collected. 

Used vapes, due to their integrated lithium batteries, must be stored safely in appropriate fire-resistant containers and kept separate from general WEEE streams. 

Phase 7 of the Distributor Takeback Scheme (2024–2026) 

Phase 7 runs from 1 January 2024 to 31 December 2026. Funds raised will continue to support Local Authority projects aimed at increasing WEEE collections, with monitoring of outcomes throughout the phase. 

Because vape sales are now excluded from the DTS, all retailers selling vapes must provide in-store takeback for vapes, regardless of turnover. Businesses may still join the DTS for other EEE categories where their non-vape electrical sales fall below the £100,000 threshold. 

Retailers with at least one physical store and less than £100,000 per year in electrical sales, as well as online-only or distance sellers of any size, may join the DTS for Phase 7 until 31 December 2026. 

Distance sellers with a physical location may voluntarily join the DTS (in addition to providing takeback at the physical site) to demonstrate participation in a WEEE collection system for online consumers. 

Further Support 

For queries regarding the DTS or registration process, contact Valpak Retail WEEE at:

• Email: DTS@valpak.co.uk
• Telephone: 03450 682 572 

Businesses should also monitor Defra’s ongoing WEEE consultations for anticipated reforms covering future takeback requirements and collection systems.