Do I need UK EPR registration as a seller based outside the UK?
Summary
Usually not, if you sell through an online marketplace. The marketplace is the producer for electricals sold to UK households, the UK importer generally is for batteries, and packaging depends on turnover and tonnage. Eldris quotes the UK only for direct supply.
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Usually not, if you sell through an online marketplace. For electricals sold to UK households, the marketplace has been the producer since 12 August 2025, under regulation 2D of the WEEE Regulations 2013. UK battery law has no representative route, so an overseas seller with no UK establishment generally is not the producer; the UK importer is. Packaging depends on turnover and tonnage. Eldris quotes UK registration only if you supply UK customers directly.
Electricals: the marketplace has been the producer since August 2025
Since 12 August 2025, an overseas supplier selling electrical equipment to UK households on an online marketplace is not the producer for it. The marketplace operator is. The rule is regulation 2D of the WEEE Regulations 2013, inserted by SI 2025/910.
The rule has two conditions, and both have to hold. The buyer is a private household, and the sale goes through an online marketplace that you do not operate yourself. Where both hold, the marketplace carries the producer obligations for that equipment. There is then nothing for you to register under the UK electricals rules for those sales. Where you supply UK end users directly, from your own website or shop, regulation 2D makes the overseas supplier the producer itself. There is no de minimis: a producer registers at any volume. The tonnage of equipment you place on the UK market decides the route, not the duty. A small producer registers directly, and a larger producer joins an approved compliance scheme. If you sell only to UK businesses, or through both a marketplace and your own shop, tell Eldris before you pay. The answer then depends on the details.
Batteries: no representative route, so the UK importer generally registers
The Waste Batteries and Accumulators Regulations 2009 define the producer as a person in the UK who first places batteries on the market. UK battery law has no authorised-representative route. An overseas seller with no UK establishment therefore generally cannot be the obligated producer; the UK importer is.
Here the UK differs from the EU. In the EU, a producer that sells batteries directly to end users in a member state where it is not established appoints an authorised representative there, under Regulation (EU) 2023/1542, Article 56(3). The EU battery registration guide covers that route. The UK has no such mechanism, so a business based abroad cannot take on the producer role by appointing someone. The obligation stays with whoever in the UK first places the batteries on the market, which for imported goods is the UK importer. A UK battery producer with no UK-established entity is one of the cases Eldris quotes individually rather than pricing automatically. Where you have a UK establishment and place batteries on the market yourself, the battery registration applies to you. The tonnage of portable batteries then decides whether you register as a small producer or join a scheme. Industrial and automotive batteries have no threshold at all.
Packaging: turnover and tonnage set the producer category
UK packaging EPR sorts producers into categories by turnover and by the tonnage of packaging they handle. GOV.UK guidance on who must comply sets the tests. It also makes the owner of an online marketplace a producer where packaging is supplied in the UK from outside the UK.
For packaging sold through a platform from abroad, the marketplace is therefore a producer in its own right. The guidance first asks whether a business is established in the UK, then which category its turnover and tonnage put it in. A small producer registers with the regulator and reports its packaging data every year. A large producer registers every year, reports every six months, obtains packaging waste recycling notes, submits a compliance certificate and pays PackUK waste disposal fees. Those fees scale with tonnage, so Eldris quotes large producers individually. Importing through someone else does not always end the duty. GOV.UK says a brand owner is still a producer when it asks another organisation to import its filled branded packaging into the UK. Eldris confirms your producer category before anything is filed. It works from your most recent annual accounts and the packaging tonnage you supplied to the UK in the previous calendar year.
What Eldris quotes for the UK, and what it needs from you
Eldris quotes UK registration only once you confirm that you supply UK customers directly. The calculator leaves the UK out until you say so. Its note gives the reason: in most cases there is nothing for a marketplace seller to register.
Where you do supply directly, there is one UK line per stream. The packaging line covers producer registration and annual declarations, with compliance scheme and Environment Agency fees passed through at cost. The electricals line covers producer registration and declarations, with compliance scheme fees at cost. The battery line covers producer registration and scheme membership, with battery scheme fees at cost above the portable battery threshold. Each price, and the average time to register, is on the pricing page. Two UK cases are quoted individually: large packaging producers, whose disposal fees scale with tonnage, and battery producers with no UK-established entity. Besides the usual company documents, the UK needs your most recent annual accounts. The portal also asks what you place on the UK market each year and which UK registrations you already hold, so nothing is registered twice. The UK registration page sets out the three lines.
Selling into the EU as well: where the answer changes
The UK answer does not carry over to the EU. Since Brexit the UK runs its own rules for electricals, batteries and packaging, so an EU registration gives no UK coverage. Equally, nothing to register in the UK says nothing about Germany or France.
In the EU, a seller that sells directly to consumers in a member state from another country is the producer there. That holds through a marketplace or its own website alike. For electrical equipment the rule is Directive 2012/19/EU, Article 3(1)(f)(iv). For batteries it is Regulation (EU) 2023/1542, Article 3(47)(d), and for packaging Regulation (EU) 2025/40 (the PPWR), Articles 3(1)(15) and 44(2). A seller established outside the country appoints an authorised representative there. Eldris includes the representative where the law requires one, and a line that passes its fee through at cost says so. The same marketplace sale can leave nothing to register in the UK and still make you the producer in each EU country you ship to. The guide to the WEEE Directive sets out how the EU rules treat sellers and marketplaces. Eldris covers 29 countries: the 27 EU member states, Norway and the UK. The short answer on UK registration for sellers based abroad sits with the other questions sellers ask.
Frequently asked questions
I sell on Amazon.co.uk from abroad. Is there anything to register?
In most cases, no. For electricals sold to UK households, the marketplace has been the producer since 12 August 2025. For batteries, the UK importer generally is, as UK battery law has no representative route. Packaging depends on your turnover and tonnage. If any UK sales are direct, tell Eldris before you pay.
Do thresholds decide whether I register directly or join a scheme?
Yes, for electricals and batteries. Tonnage decides the route, not whether you register: a small producer registers directly, a larger one joins an approved scheme. Industrial and automotive batteries have no threshold. For packaging, turnover and tonnage decide whether you are obligated at all, and in which category.
My quote has a UK battery line, but I have no UK company. Can it come off?
Yes. Reply to the quote before you pay, or build a new quote without it. Where a seller has no UK establishment, UK battery law generally makes the UK importer the producer. A battery producer with no UK-established entity is quoted individually, not automatically.
Does an EU registration cover my UK sales?
No. The UK runs its own rules for electricals, batteries and packaging, separate from the EU, so an EU number gives no UK coverage. The reverse is also true. If you supply UK customers directly and Eldris already registers you elsewhere, adding the UK uses the details on file.
What does Eldris need for a UK registration?
The same company documents as for any other country, plus your most recent annual accounts as turnover evidence. The portal also asks for the packaging tonnage you supplied to the UK in the previous calendar year. It asks too for the weight of electrical equipment and portable batteries you place there, and any UK registration you hold.
What does a UK registration cost?
Each UK line shows its price and average time to register on the pricing page. Compliance scheme and Environment Agency fees are passed through at cost, never marked up. Large packaging producers are quoted individually, because their PackUK disposal fees scale with tonnage.
Sources
- Directive 2012/19/EU on waste electrical and electronic equipment (WEEE) EUR-Lex
- Regulation (EU) 2023/1542 on batteries and waste batteries EUR-Lex
- Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) EUR-Lex
- Eldris prices and average registration times: the Eldris price list
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EPR registration from £185 per country per year, annual reporting included and the authorised representative arranged where the law requires one.
Packaging, electronics (WEEE) and batteries in 29 countries. Average registration time runs from 1 week (Germany packaging) to 9–17 weeks (Greece), or 4–5 months for Spain packaging without a Spanish tax number. See every price
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