A factory ships you a pallet of chargers in retail boxes. At the border, customs asks about duty and VAT. Nobody asks about recycling. Later, a regulator or a marketplace does, and you find that selling those chargers needs registrations you never made.
This is extended producer responsibility (EPR). The business that first places a product or its packaging on a market pays toward collecting and recycling it. This guide covers the electrical and packaging rules for importers in the EU and UK. Batteries have their own rules, covered in our battery guide. The rules also differ by country, so treat this as the map and ask a compliance adviser for the route.
Three streams, three sets of rules
| Stream | EU law | UK |
|---|---|---|
| Electrical and electronic equipment (WEEE) | Directive 2012/19/EU, with national registers | UK WEEE regulations |
| Packaging | Regulation (EU) 2025/40 | Packaging extended producer responsibility |
| Batteries | Regulation (EU) 2023/1542 | Waste Batteries Regulations 2009 |
Most importers of finished products meet all three, because the product has a plug or battery and ships in a box.
WEEE in the EU
The WEEE Directive defines a producer in several ways. Two reach importers from China:
- A business established in a Member State that places electrical equipment from a third country on that Member State’s market on a professional basis.
- A seller, established in another Member State or in a third country, that sells equipment by distance communication directly to private households.
The second case catches a Chinese seller who ships single orders to EU customers. Article 17(2) says such a seller must appoint an authorised representative in the Member State it sells to, by written mandate. The representative becomes responsible for fulfilling the producer’s obligations there.
Each Member State keeps its own producer register, and the directive says producers selling at a distance register in the country they sell to, through their representative if they have no establishment there. You register in each country you sell into, so a seller in five countries has five registrations.
Packaging in the EU
Regulation (EU) 2025/40 applies from 12 August 2026. It matters to importers in two ways:
- Importer duties. Article 18 says importers may only place on the market packaging that meets the regulation’s requirements, and must check that before the packaging goes on sale. The regulation also expects importers to put their name or trade mark on the packaging.
- Authorised representative. Article 45 says producers appoint an authorised representative for extended producer responsibility, by written mandate, in each Member State where they first make packaging available and are not established.
Member States add their own rules and dates. Ask your adviser which countries you sell in and what each one requires.
Packaging in the UK
The UK government’s response to its consultation on packaging EPR puts the legal duties on the first UK owner of the packaging. Where a non-UK company supplies packaging into the UK, that first UK owner carries them. The rules apply even if you discard the packaging before you sell the goods.
That makes the importer the usual carrier of the duty. Thresholds, reporting dates and fees change, so check GOV.UK for the current figures before you rely on any number.
What to ask the factory
- Packaging details. The weight and material of every layer: carton, inner box, insert, film and label.
- Product category. Whether the product counts as electrical equipment, and its weight.
- The label proof. Marks and symbols on the product and packaging, such as the crossed-out bin symbol.
- A change clause. No change of packaging material without your approval. A new layer changes your report.
Before you ship
- List what you place on the market
For each product, note whether it is electrical, whether it has a battery and what packaging it has.
- List where you sell
Rules and registers are national. Write down every EU country and the UK.
- Decide who is the producer
You as importer, or your customer, or a marketplace seller. Settle this in writing.
- Appoint representatives
If you sell by distance into countries where you are not established, appoint an authorised representative by written mandate.
- Register and report
Register with the national register or scheme for each stream. Keep the weight and material data from the factory.
- Mark the product and packaging
Agree the required symbols and details at proof stage, before printing.
How CFS helps
We ask the factory for packaging weights, materials and label proofs before production, and check marks at inspection. See supplier verification and quality control. For registrations and representatives, our group business VAT+ offers EPR compliance and an authorised representative service.
Bottom line
If you put electrical goods or packaging on a market, you are probably a producer, and each country keeps its own register. List what you sell and where, then appoint representatives and register before the first sale. Ask the factory for packaging data in the quote stage.
Checked against EUR-Lex and GOV.UK on 13 November 2026. These rules change often and differ by country. This guide is general information, not legal advice. A compliance adviser confirms what applies to you.
Questions we get asked
Am I a producer under the WEEE rules if I import electrical goods from China?
Probably. The EU WEEE Directive defines a producer as a business that places electrical and electronic equipment from a third country on the market of a Member State on a professional basis. A seller that sells directly to private households by distance communication from another country is also a producer.
Do I need an authorised representative for WEEE in each EU country?
If you sell to private households in a Member State where you are not established, yes. Article 17(2) of the WEEE Directive says a distance seller must appoint an authorised representative there by written mandate, and that representative becomes responsible for the producer's obligations in that country.
What do the new EU packaging rules ask of importers?
Regulation (EU) 2025/40, the packaging regulation, says in Article 18 that importers may only place on the market packaging that meets its requirements. Article 45 says producers appoint an authorised representative for extended producer responsibility in each Member State where they first make packaging available and are not established.
Who carries the packaging duty in the UK when goods come from China?
The UK government's response to its packaging consultation puts the legal duties on the first UK owner of the packaging, and says the rules apply even if you discard the packaging before you sell the goods. Check GOV.UK for the current thresholds and reporting dates.