Introduction
International compliance impacts any organisation that is selling to or in another country outside the UK. This article and video explain the key points you need to know, the next steps you should take and how Ecosurety can help.
Watch explainer video - part one
What is international compliance?
Across the EU there is well established legislation in place for packaging, WEEE and batteries which originated from the following EU directives:
- Packaging Directive 94/62/EC (1994)
- WEEE Directive 2012/19/EU (2002)
- Batteries Directive 91/157/EC (2006)
Each member state implemented these directives into domestic legislation, including the UK, and this has resulted in different systems and rules across the EU that you must comply with. With each country having different obligation thresholds, reporting requirements and costs, international compliance can be tricky to navigate.
Is your organisation impacted?
If your organisation is selling electronic items, batteries, packaging or packaged goods in or to other countries, you may have obligations in those countries that you must comply with.
Be aware that complying with the regulations in the UK, including being registered with the appropriate UK environment agency, does not cover your obligations in other countries.
Carefully consider the following four questions, if you answer yes to any of them, then you should investigate your potential obligations as soon as possible:
- Do you export outside of the UK?
- Do you have a physical presence in another country?
- Do you sell direct to an individual end consumer outside the UK via the internet including on Amazon or Ebay?
- Are you planning to expand operations to other countries beyond the UK?
What do you need to do next?
If you answered yes to any of the above questions, then you probably have obligations overseas. Your next task will be to identify which countries you are selling to or in, and any countries where you have a physical presence (such as a retail store or a registered business entity). This is an essential task, as it will enable you to understand the requirements you must fulfill and your likely compliance costs.
Be aware that simply offering goods for sale in other countries means you may have obligations to fulfill, including registering with the appropriate agency. Make sure you include this when checking if you have any international compliance obligations, particularly where your products are offered for sale online.
Another fundamental task you must complete is to compile a database of your products (i.e. electronic items, batteries, packaging or packaged goods) that you are selling in or to other countries. This should include:
- Sales data to determine the exact quantities involved
- Detailed data about your products themselves (if electricals/batteries)
- Packaging materials used
- Weight per component utilised
When you know all the above information, it will be possible to scope out your obligations, required actions and even your potential costs. You will also be ready to take steps to register and comply in obligated countries.
Be aware that the level of detail about your products and packaging that you must report has been increasing across the EU. For example, it is likely that you will need to collect and report data on the exact plastic polymer and material types used in your packaging, rather than general categories such as “plastic” or “paper”.
Watch explainer video - part two
What are the requirements for compliance overseas?
You may need to take steps for each of the countries you have obligations in, including:
- Registering with the relevant authorities
- Reporting data
- Providing takeback for WEEE and batteries
- Providing correct customer information
- Complying with labelling requirements
- Financing the collection and recycling of waste to offset your obligations
These requirements can vary quite widely across each of the member states, and you will need to fulfill them for each individual country you have obligations in.
What if you are not compliant?
Failure to comply with overseas regulations can lead to expensive fines or trade sanctions, as well as damage to your company’s reputation.
How can Ecosurety help?
Ecosurety can support you with international compliance in a number of ways:
- Free scoping of your international obligations. Complete our comprehensive scoping questionnaire to enable us to identify which countries you likely have obligations in. We'll advise on what your next steps are and explain how we can help.
- Country specific compliance guides. Our country specific compliance guides give you an overview of the exact requirements for each country and enable you to understand your obligations, fees and next steps.
- Bespoke impact assessment. This is effectively an audit to identify if you are already registered and fulfilling any obligations overseas, so you know if you need to take any further action. This is ideal if you are concerned about potential incorrect reporting or registration gaps in your compliance.
- Full compliance support. A comprehensive service to undertake registrations, join required schemes and report data on your behalf in all obligated countries. Ideal if you do not have sufficient internal resource or wish to centralise your pan-European compliance.
Complete the scoping questionnaire
Please click here to complete our international compliance scoping questionnaire.
Our team will be in touch with you shortly to discuss your next steps. Alternatively, you can directly contact our team to request more information about our international compliance services.
