UAE EPR in 2026: the e-waste and battery take-back duty in law since 2021, the 2025 MOCCAE and Tadweer pilot, and what is still to come.
Part of the reading list: UAE climate and environmental compliance
Introduction
Extended Producer Responsibility (EPR) moves the cost and the paperwork of post-consumer waste from the municipality to the company that put the product on the market. In the UAE it exists in two layers, and most commentary only sees one of them.
The first layer is already law. Since 17 May 2021, suppliers of electrical and electronic products and batteries have had to take that waste back from consumers free of charge, report on it monthly and pay for its treatment.
The second layer is a broader national framework covering more product streams, a producer responsibility organisation and, eventually, fees. That layer is being prepared and piloted, but it has not been issued.
What EPR is
Under EPR the producer or supplier stays responsible for a product after the consumer has finished with it. The responsibility is financial, because the producer funds collection and treatment, and operational, because the producer reports what it placed on the market and what came back. Its purpose is to make recoverability a design and pricing decision rather than a municipal cost.
The law that already applies
Federal Law No. 12 of 2018 on Integrated Waste Management (in force 31 March 2019) contains the principle. Article 5 makes both the waste producer and the supplier responsible for accepting returned products and remaining waste after use, and for the financial cost of doing so, as the executive regulation determines. The law defines a supplier as the entity supplying products to the State, which brings importers into scope, not only local manufacturers.
Cabinet Resolution No. 39 of 2021, the executive regulation, came into force on 17 May 2021 and turned that principle into specific duties for e-waste and batteries. Under Article 2(2), the supplier must:
- accept returned defective or non-conforming products and bear the cost of disposing of them properly
- collect 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
- submit a monthly report to the competent authority on the quantities collected and how they were treated or disposed of
- bear all costs of treating or disposing of that e-waste and battery waste
The competent authority in each emirate can add requirements. We cover how this works on the ground, and the Abu Dhabi and Dubai rules that sit alongside it, in the UAE e-waste take-back duty.
The national framework and the 2025 pilot
On 8 December 2024 the Ministry of Climate Change and Environment (MOCCAE) announced that it had started preparing an EPR framework, describing EPR as one of the main initiatives of the National Agenda for Integrated Waste Management 2023 to 2026.
On 3 July 2025 MOCCAE and Tadweer Group signed a memorandum of understanding for a pilot:
- Scope: electrical and electronic equipment, batteries and packaging
- Where: Abu Dhabi and Dubai
- Duration: nine months, renewable, according to the Arabic release from WAM, the state news agency
- Producer responsibility organisation: Tadweer Group, on a temporary basis
- Participants: 26 companies signed an EPR Pledge
On 30 July 2026 the UAE Circular Economy Council reviewed the outcomes of the pilot and recommendations for its next phase. No results were published.
What does not yet exist, as of 23 October 2026:
- a federal cabinet resolution or ministerial decision establishing a national EPR scheme
- a national producer responsibility organisation (Tadweer’s role is tied to the pilot)
- an EPR fee schedule or eco-levy
- an EPR duty for packaging. Packaging is covered by the single-use plastics bans, not by a take-back obligation
No official source gives a date for the national framework. Companies should plan for it without assuming a deadline.
EPR is where waste policy meets the balance sheet: the cost of recovery moves from the municipality to the producer.
What producers should do now
- Confirm whether you are a supplier. If you import or sell electrical and electronic products or batteries in the UAE, the 2021 take-back duty applies to you today.
- Put the collection and reporting in place. Free consumer return points at sales centres, a contract with a licensed e-waste collector and recycler, and a monthly report with quantities and treatment routes.
- Map what you place on the market. Product and packaging quantities by category, material and weight. Every EPR scheme in the world starts from this number, and the national framework will too.
- Keep an auditable trail. Waste transfer records, recycler certificates and the monthly reports, retained and reconciled.
- Design for recovery. Less material, fewer mixed materials and easier disassembly lower the cost of compliance under any future fee model.
- Connect it to your ESG reporting. Collection and recovery data is circular-economy performance that belongs in your sustainability report.
How ESGweise helps
ESGweise helps producers, importers and retailers in the UAE meet the take-back duty that already applies and prepare for the national framework: confirming scope, setting up the collection and monthly reporting, building the placed-on-market dataset, and bringing it into ESG reporting and an ISO 14001 environmental management system.
Conclusion
UAE EPR is not a future event. The supplier take-back duty for e-waste and batteries has applied since May 2021, and the national framework announced in December 2024 is being tested through the 2025 pilot. Companies that run the existing duty properly now will have the data, the contracts and the reporting routine that any wider scheme will ask for.
Sources
- Federal Law No. (12) of 2018 on Integrated Waste Management, UAE legislation portal, uaelegislation.gov.ae, legislation 1164 (Articles 1, 5, 26, 28 to 31)
- 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)
- MOCCAE news release on starting to prepare an EPR framework, 8 December 2024 (Arabic)
- WAM, MOCCAE collaborates with Tadweer Group to launch pilot project, 3 July 2025 (English and Arabic)
- Ministry of Economy and Tourism, UAE Circular Economy Council meeting, 30 July 2026
Frequently asked questions
What is Extended Producer Responsibility (EPR)?
EPR makes the producer or supplier responsible for a product after use, including collection, recycling and safe disposal. The responsibility is financial (paying for take-back and treatment) and operational (reporting what is placed on the market and what is recovered).
Is EPR mandatory in the UAE?
In part. Cabinet Resolution No. 39 of 2021, the executive regulation of Federal Law 12 of 2018, has required suppliers since 17 May 2021 to take back e-waste and battery waste from consumers free of charge at their sales centres, to report monthly and to bear all treatment costs. A wider national EPR framework covering more product streams was announced by MOCCAE in December 2024 and had not been issued as of 23 October 2026.
Which products does the UAE EPR pilot cover?
The pilot launched on 3 July 2025 covers electrical and electronic equipment, batteries and packaging, in Abu Dhabi and Dubai, with Tadweer Group acting as the producer responsibility organisation on a temporary basis. It runs for nine months and is renewable. The UAE Circular Economy Council reviewed its outcomes on 30 July 2026.
What are the penalties under the UAE waste law?
Federal Law 12 of 2018 sets a maximum fine of AED 1,000,000 for an entity that litters, buries, burns or dumps waste in undesignated places, AED 30,000 for an individual doing the same, and AED 20,000 for any other violation of the law or its regulation. Authorities can also suspend a licence and close a facility temporarily or permanently.