Notification Obligation for Retailers and Online Stores in Electronic Waste Management

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Notification Obligation for Retailers and Online Stores in Electronic Waste Management: A Comprehensive Overview

Under Estonia’s Waste Act, all shops and online stores selling electronic devices, including batteries and accumulators, are mandated to publicly inform customers about the possibilities for returning old electronic equipment.

The law stipulates that retailers of electronic devices must organize the collection and recycling of electronic waste.

The Estonian Environment Agency has initiated extensive checks to ensure compliance with legal requirements. The checks determine whether shops and online stores selling electronic devices fulfill their statutory notification obligations.

The Agency systematically monitors the adequacy and compliance of the electronic waste collection network and conducts spot checks on the return of electronic waste, batteries, and accumulators at sales points. During upcoming checks, the Agency will also observe how consumers are informed about waste return opportunities.


What a Retail Store Must Do

Download an old electronic devices notification poster to your computer, complete it, and place it in a visible location in your sales hall, such as near the entrance or at the cash register.

Here are detailed instructions for retailers selling electronic devices, including batteries and accumulators:

Guidance for Retailers of Electronic Devices

Under the EU’s WEEE (Waste Electrical and Electronic Equipment) Directive, retailers, including online stores, are obligated to take back old or malfunctioning electronic devices when a consumer purchases a new similar product. This is known as the “one-to-one” take-back principle, aimed at facilitating proper electronic waste management.

Retail locations with an area of at least 400 m² selling electronic devices must accept devices up to 25 cm in size free of charge. Additionally, the return of batteries and accumulators is mandatory at all sales points where they are sold.

Retailers are responsible for organizing the collection and recycling of electronic waste. Larger devices exceeding 25 cm must be directed to appropriate collection points, which sales locations should inform consumers about. Retailers are also responsible for informing consumers about the correct disposal of electronic waste and their rights and obligations related to device return.

What an Online Store Must Do

Online stores must add relevant information prominently on their website, explaining that old electronic waste, batteries, and accumulators can be returned for free and include information about the collection network.

Instructions for Online Retailers of Electronic Devices

Under the principle of producer responsibility, online stores must ensure the proper handling of sold products after their end-of-life. The WEEE Directive imposes various obligations on online retailers, including take-back and notification requirements.

Online stores must provide information on their websites about consumers’ rights to return old or used devices, how to do so, and location references. A simple notice on the website with a link to collection point locations is sufficient.

Recommended link for reference:

Online stores are required to take back old electronic devices when a customer purchases a new similar product. They must also inform consumers on their website about the right and process of returning old devices. In addition, online stores must organize the proper recycling or recovery of collected devices. Estonia-based online stores importing products must register in the PROTO register and join a producer responsibility organization according to the Waste Act § 25 paragraph 6.

Producer responsibility organizations, such as Eesti Elektroonikaromu, help online retailers comply with WEEE Directive requirements by offering services like waste collection, sorting, and processing.

In case of violations, the Environment Agency may impose fines or consider criminal liability for major infringements. To avoid violations and associated sanctions, it is advisable to join a producer responsibility organization, which helps fulfill responsibilities and ensures compliance with legal and sustainability goals.

If you have additional questions regarding the notification obligation or wish to join a producer responsibility organization, please contact us.

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Notification Obligation for Retailers and Online Stores in Electronic Waste Management 9

List of products for which the notification obligation arising from WEEE requirements applies when sold in retail stores or online shops.

Large household appliances

  • large cooling appliances
  • refrigerators
  • freezers
  • other large appliances used for refrigeration, conservation and storage of food
  • washing machines
  • clothes dryers
  • dish washing machines
  • cooking
  • electronic stoves
  • electric hot plates
  • microwaves
  • other large appliances used for cooking and other processing of food
  • electrical heating appliances
  • electric radiators other large appliances for heating rooms, beds, seating furniture
  • electric fans
  • air conditioning appliances
  • other fanning, exhaust ventilation and conditioning equipment

Small household appliances

  • vacuum cleaners
  • carpet sweepers
  • other appliances for cleaning
  • appliances used for sewing, knitting, weaving and other processing for textiles
  • irons and other appliances for ironing, mangling and other care of clothing
  • toasters
  • fryers
  • grinders, coffee machines and equipment for opening or sealing containers or packages
  • electric knives
  • appliances for hair-cutting, hair drying, tooth brushing, shaving, massage and other body care appliances
  • clocks, watches and equipment for the purpose of measuring, indication or registering time
  • scales

IT and telecommunications equipment

  • centralised data processing
  • mainframes
  • minicomputers
  • printer units
  • personal computing
  • personal computers (CPU, mouse screen and keyboard included)
  • laptop computers (CPU, mouse screen and keyboard included)
  • notebook computers
  • notepad computers
  • printers
  • copying equipment
  • electrical and electronic typewriters
  • pocket and desk calculators
  • any other products and equipment for the collection, storage, processing, presentation or communication of information by electronic means
  • user terminal and systems
  • facsimile
  • telex
  • telephones
  • pay telephones
  • cordless telephones
  • cellular telephones
  • answering systems
  • any other products or equipment of transmitting sound, images or other information by telecommunications

Consumer equipment and photovoltaic panels

  • radio sets
  • television sets
  • video cameras
  • video recorders
  • hi-fi recorders
  • audio amplifiers
  • musical instruments
  • any other products or equipment for the purpose of recording or reproducing sound or images, including signals or other technologies for the distribution of sound and image than by telecommunications
  • photovoltaic panels

Lighting equipment

  • straight fluorescent lamps
  • compact fluorescent lamps
  • high intensity discharge lamps, including pressure sodium lamps and metal halide lamps
  • low pressure sodium lamps
  • luminaries for fluorescent lamps with the exception of luminaries in households
  • other lighting or equipment for the purpose of spreading or controlling light with exception of filament bulbs

Electrical and electronic tools (with the exception of large-scale stationary industrial tools)

  • drills
  • saws
  • sewing machines
  • equipment for turning, milling, sanding, grinding, sawing, cutting, shearing, drilling, making holes, punching, folding, bending or similar processing of wood, metal and other materials
  • tools for riveting, nailing or screwing or removing rivets, nails, screws or similar uses
  • tools for welding, soldering or similar use
  • equipment for spraying, spreading, dispersing or other treatments of liquid or gaseous substances by other means
  • tools for mowing or other gardening activities

Toys, leisure and sports equipment

  • electric trains or car racing sets
  • hand-held video games consoles
  • video games
  • computers for biking, diving, running, rowing, etc
  • sports equipment with electric or electronic components
  • coin slot machines

Medical devices (with the exception of all implanted and infected products)

  • radiotherapy equipment
  • cardiology equipment
  • dialysis equipment
  • pulmonary ventilators
  • nuclear medicine equipment
  • laboratory equipment for in-vitro diagnosis
  • analysers
  • freezers
  • fertilization tests
  • other appliances for detecting, preventing, monitoring, treating, alleviating illness, injury or disability

Monitoring and control instruments

  • smoke detectors
  • heating regulators
  • thermostats
  • measuring, weighing or adjusting appliances for household or as laboratory equipment
  • other monitoring and control instruments used in industrial installations (e.g. in control panels)

Automatic dispensers

  • automatic dispensers for hot drinks
  • automatic dispensers for hot or cold bottles or cans
  • automatic dispensers for solid products
  • automatic dispensers for money
  • all appliances which deliver automatically all kinds of products

Batteries and Accumulators – All Types

  • All A; B; C; D; SR and CR Type Batteries
  • Hearing aid batteries
  • Large batteries, such as those for laptops, phones, or electric tools
  • Car batteries
  • Industrial batteries
  • Batteries for electrical and electronic devices, such as vacuums, trimmers, lawnmowers
  • Vapors/e-cigarette batteries
  • Wheelchair or golf cart batteries
  • Items with non-removable batteries (such as children’s toys)
  • Items with non-removable batteries (such as children’s toys)

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