# The UAE E-Waste Take-Back Duty Suppliers Already Have > Since May 2021 UAE suppliers of electronics and batteries must take back e-waste free, report monthly and pay for treatment. The rule and how emirates apply it. **Source:** https://www.esgweise.com/insights/uae-e-waste-take-back-duty-suppliers/ **Author:** Sumit Agarwal **Published:** 2026-10-23 **Countries:** UAE --- ## Key points - Cabinet Resolution No. 39 of 2021, in force since 17 May 2021, requires suppliers to collect e-waste and battery waste from consumers free of charge, using recycling bins in their sales centres. - The supplier must report the quantities collected and how they were treated to the competent authority every month, and pays all treatment and disposal costs. - A supplier is any entity supplying products to the UAE, so importers and distributors are in scope, not only manufacturers. - Abu Dhabi requires e-waste to go to permitted collectors and facilities with an electronic manifest; Dubai requires a Dubai Municipality accredited recycler and a Waste Disposal Service permit. - Missing the monthly report is a violation under Article 30 of Federal Law 12 of 2018, with a fine of up to AED 20,000, plus licence suspension or closure under the regulation. --- ## Introduction Most discussion of producer responsibility in the UAE looks ahead to a national framework. For electronics and batteries, part of it is already here. Since **17 May 2021**, the executive regulation of the federal waste law has required suppliers to take e-waste and battery waste back from consumers, free of charge, to report on it every month and to pay for its treatment. This article sets out what the rule says, who it applies to, and how Abu Dhabi and Dubai route the waste once it is collected. ## The rule **Federal Law No. 12 of 2018 on Integrated Waste Management** makes the waste producer and the supplier responsible for accepting returned products and remaining waste after use, and for the cost, as the executive regulation determines (Article 5). **Cabinet Resolution No. 39 of 2021** is that executive regulation. Article 2(2) places four duties on the supplier: 1. **Returned products.** Accept returned defective or non-conforming products and bear the cost of disposing of them properly. 2. **Free consumer take-back.** Collect and accept e-waste and battery waste from consumers free of charge, by providing recycling bins in its sales centres, and have it treated or disposed of through the concerned entities. 3. **Monthly reporting.** Report every month to the competent authority on the quantities of e-waste and battery waste collected and the method of treatment or disposal. 4. **Full cost.** Bear all costs of treating or disposing of the e-waste and battery waste. The emirate's competent authority may add requirements (Article 2(3)). ## Who counts as a supplier The law defines a supplier as the entity supplying products, of whatever type, to the State. That reaches past manufacturers to **importers, distributors and brand owners** that bring electrical and electronic equipment or batteries into the UAE market. Any of them selling to consumers through sales centres carries the collection duty. E-waste and battery waste are defined by what the consumer discards: items disposed of by the person who used the device or battery. ## How the waste moves in Abu Dhabi **EAD Circular No. (4) of 2022, Recycling of WEEE in the Emirate of Abu Dhabi** (22 March 2022) applies to organisations that generate waste electrical and electronic equipment. It requires them to: - contract only with permitted service providers registered for e-waste collection - send WEEE only to permitted treatment facilities in Abu Dhabi - use the electronic waste manifest system Waste licensing and inspection moved from Tadweer to the Environment Agency Abu Dhabi on 29 May 2024, so permits and approvals now sit with EAD. ## How the waste moves in Dubai **Dubai Municipality's Technical Guidelines on Recycling of WEEE, Version 1.0** (22 August 2024) apply to WEEE generators and to recyclers licensed for the activity "Recycling of WEEE", including in the free zones. Under them: - WEEE goes only to a Dubai Municipality accredited recycler or a Municipality facility - each disposal is covered by an online Waste Disposal Service permit, valid for three months - accredited recyclers report to the Municipality every month Failing to file the monthly report, or any other breach of the regulation, is a violation under Article 30 of Federal Law 12 of 2018, with a fine of up to **AED 20,000**. Cabinet Resolution 39 of 2021 adds temporary closure for up to six months with licence suspension, and permanent closure with licence withdrawal if the violation is not removed (Article 10). Dumping waste in undesignated places carries a fine of up to **AED 1,000,000** for an entity (Article 28). For electronics and batteries, producer responsibility in the UAE is not a future framework. It has been a monthly reporting duty since May 2021. ## Moving e-waste across borders The UAE ratified the **Basel Convention** on the control of transboundary movements of hazardous wastes in November 1992. A MOCCAE decision bars the passage or export of hazardous waste across UAE borders without the Ministry's written permission. Much e-waste is hazardous because of batteries, circuit boards and the substances in them, so exporting collected e-waste for recycling needs that permission. Unlike the other five GCC states, the UAE has not ratified the Basel Ban Amendment. ## What a compliant programme looks like 1. **Scope.** List the electrical and electronic products and batteries you supply in the UAE, by emirate and by sales channel. 2. **Collection points.** Free consumer return bins in each sales centre, with signage, and a process for returned defective stock. 3. **Licensed partners.** A contract with a permitted collector and treatment facility in each emirate where you sell, checked against the current EAD and Dubai Municipality approvals. 4. **Records.** Weights collected per site per month, transfer notes or manifests, and certificates of recycling or disposal from the facility. 5. **Monthly report.** Filed with the competent authority on time, reconciled to the transfer records. 6. **Cost and data.** Book the treatment cost against the product lines that cause it, and keep a placed-on-market dataset by product category. The national EPR framework MOCCAE is preparing will start from that number. ## How ESGweise helps ESGweise helps suppliers, importers and retailers run the take-back duty properly: confirming scope, setting up collection and the monthly report, checking the licensing of collectors and recyclers, and bringing the data into [ESG reporting](/services/reporting/) and an [ISO 14001](/services/iso-implementation/) environmental management system. For the wider framework, see [UAE Extended Producer Responsibility](/insights/uae-extended-producer-responsibility-epr-2026/). ## Conclusion The free take-back of e-waste and batteries, the monthly report and the full cost of treatment have been the supplier's obligations since May 2021. Companies that run them as a routine now hold the data, the contracts and the audit trail that a national EPR scheme will expect. ## Sources - Federal Law No. (12) of 2018 on Integrated Waste Management, UAE legislation portal, legislation 1164 (Articles 1, 5, 28 to 30) - Cabinet Resolution No. (39) of 2021, Executive Regulation of Federal Law No. 12 of 2018, UAE legislation portal, legislation 1490 (Articles 1, 2 and 10) - Environment Agency Abu Dhabi, Circular No. (4) of 2022, Recycling of Waste Electronics and Electrical Equipment in the Emirate of Abu Dhabi, 22 March 2022 - Abu Dhabi Media Office, EAD expands licensing and permitting to waste, 29 May 2024 - Dubai Municipality, Technical Guidelines on Recycling of Waste Electrical and Electronic Equipment, Version 1.0, 22 August 2024 - Basel Convention Secretariat, Parties and Signatories, and Ban Amendment ratifications (read 23 October 2026) --- ## Frequently asked questions ### Do UAE retailers have to take back old electronics? Suppliers do. Article 2(2) of Cabinet Resolution No. 39 of 2021 requires the supplier to collect and accept e-waste and battery waste from consumers free of charge by providing recycling bins in its sales centres, and to have it treated or disposed of through the concerned entities. A supplier is any entity supplying products to the State, which covers importers and distributors that sell to consumers. ### What must be reported, and how often? A monthly report to the competent authority in the emirate, covering the quantities of e-waste and battery waste collected and the method used to treat or dispose of it. ### Who pays for e-waste recycling in the UAE? The supplier. Cabinet Resolution No. 39 of 2021 makes the supplier bear all costs of treating or disposing of the e-waste and battery waste it collects, as well as the cost of disposing of returned defective products. ### Is this the same as the UAE EPR pilot? No. The take-back duty has been law since 17 May 2021. The EPR pilot launched by MOCCAE and Tadweer Group on 3 July 2025 is a separate, voluntary programme that tests a wider national framework covering electronics, batteries and packaging. --- Published by ESGweise Global LLC, Dubai. https://www.esgweise.com