Recycling & WEEE Policy 

Recycling & WEEE Policy
Effective Date: 25 September 2026
Last Updated: 25 September 2026

Eco Tech Recycle is a trading name of Tech Cell Limited (Company No. 14338989).
This Recycling & WEEE Policy explains how Eco Tech Recycle handles unwanted, surplus, faulty, damaged, end-of-life and mixed-condition electrical and electronic equipment. It explains our reuse-first approach, how we distinguish used electrical and electronic equipment (EEE) from waste electrical and electronic equipment (WEEE), our acceptance limits, data-aware handling, waste documentation, reuse and parts routes, and downstream recycling arrangements.
This Policy applies to individuals, businesses, schools, charities, community organisations, trade customers and other organisations that provide, sell, donate, drop off, send or arrange collection of electrical or electronic equipment to Eco Tech Recycle.
This Policy should be read together with our:
Collection, Device Acceptance & Valuation Policy;
Data Erasure & Data Security Policy;
Purchase, Buy-Back & Payment Terms;
Business & School Collection Terms;
Device Grading, Functional Condition & Resale Classification Policy;
Delivery, Shipping & Collection Policy;
Privacy Policy;
Complaints Policy; and
any quotation, collection confirmation, invoice, handover record, asset record, waste transfer documentation or written agreement issued by Eco Tech Recycle.
Where a written quotation, collection confirmation, service agreement, handover record or invoice contains specific lawful terms for a particular job, those specific written terms will take priority for that job.
Key Points at a Glance
Eco Tech Recycle follows a reuse-first approach where lawful, safe and practical.
Not every item received is automatically non-waste EEE; whether equipment is waste depends on its legal status and the circumstances of transfer.
WEEE is handled only within the scope of applicable registrations, exemptions and lawful downstream routes.
Eco Tech Recycle holds a T11 WEEE exemption for eligible repair, refurbishment and dismantling activity.
A T11 exemption is not the same as an environmental permit or AATF approval.
WEEE identified as POPs waste will not be repaired or refurbished for reuse where that is prohibited by law.
Data-bearing equipment will not knowingly be released into an end-user reuse, resale or donation route while a known material data-security risk remains unresolved.
Free collection is not guaranteed.
Unsafe, contaminated or out-of-scope equipment may be refused or require a specialist route.
Eco Tech Recycle avoids unsupported claims such as “zero landfill”, “100% sustainable” or “100% recycled”.
Purpose of This Policy
The purpose of this Policy is to explain how Eco Tech Recycle manages electrical and electronic equipment in a responsible, practical and transparent way.
Our aims include:
prioritising reuse where lawful, safe and practical;
extending the useful life of suitable technology;
supporting repair and refurbishment;
recovering reusable parts where legally and technically appropriate;
directing non-reusable equipment to appropriate recycling, recovery or specialist treatment routes;
reducing unnecessary waste;
applying data-aware and safety-conscious handling;
supporting customers with clear acceptance and collection processes;
maintaining appropriate waste and service records; and
avoiding misleading environmental or compliance claims.
The route for any item or batch depends on factors including its legal status, condition, safety, data-security risk, repairability, customer instructions, commercial viability and available lawful downstream routes.
EEE and WEEE
EEE means electrical and electronic equipment.
WEEE means waste electrical and electronic equipment.
Under applicable waste law, electrical or electronic equipment is waste where the holder discards it, intends to discard it or is required to discard it.
An intention to repair, refurbish or reuse equipment does not by itself mean that the equipment is not waste.
Whether an item remains used EEE or has become WEEE is assessed according to the circumstances and applicable law and Environment Agency guidance.
Where equipment is genuinely transferred as used EEE for continued use or lawful reuse, relevant conditions must be satisfied. Where those conditions are not met, the equipment may need to be handled as WEEE.
Equipment sent to Eco Tech Recycle for repair or refurbishment and return to the same owner may remain EEE where the legal conditions for that route are met.
Reuse-First Approach
Where lawful, safe and practical, Eco Tech Recycle follows a reuse-first approach.
Suitable equipment may be considered for:
continued use;
repair;
refurbishment;
upgrade;
redeployment;
resale;
an agreed donation route;
lawful parts recovery; or
responsible recycling or recovery where another route is not suitable.
A reuse-first approach does not guarantee that every device will be reused.
Equipment may be unsuitable for reuse because of:
safety;
age;
damage;
data-security risk;
legal waste classification;
POPs status;
failed components;
missing parts;
activation locks or management restrictions;
ownership concerns;
poor market demand;
disproportionate repair cost; or
lack of a suitable lawful route.
T11 WEEE Exemption
Tech Cell Limited T/A Eco Tech Recycle holds an Environment Agency T11 WEEE exemption for eligible repair, refurbishment and dismantling activities.
T11 Exemption Reference: EXP/ZS3295UG
Registered: 27 May 2026
Valid until: 27 May 2029
The T11 exemption permits eligible repair, refurbishment or dismantling of specified WEEE so that whole items or components can be reused for their original purpose or components can be recovered, subject to the exemption’s conditions and limits.
Eco Tech Recycle operates relevant T11 activities only within the scope of the exemption and applicable law.
The T11 exemption does not authorise every form of waste treatment.
In particular, activities outside the scope of the exemption are only carried out where another lawful authorisation applies or are transferred to an appropriately authorised downstream provider.
The T11 exemption does not mean that Eco Tech Recycle is an Approved Authorised Treatment Facility (AATF), and Eco Tech Recycle does not represent the exemption as an environmental permit or AATF approval.
T11 Operating Boundaries
Eco Tech Recycle will not rely on its T11 exemption for activities that the exemption does not permit.
Current T11 restrictions include restrictions on:
mechanical treatment such as shredding, granulation or compaction;
de-gassing ozone-depleting substances;
treating WEEE for disposal to landfill or incineration;
mixing hazardous waste with other hazardous or non-hazardous waste;
accepting or treating fluorescent light bulbs or tubes under T11; and
repairing or refurbishing WEEE that is POPs waste for reuse.
Where equipment requires treatment outside the T11 scope, Eco Tech Recycle may refuse it, arrange a different authorised route or transfer it to an appropriately authorised downstream provider.
Waste Carrier / Dealer Registration
Tech Cell Limited operates under its applicable waste carrier/dealer registration when carrying or arranging the transfer of controlled waste.
Waste Carrier / Dealer Registration: CBDU609113
The registration supports relevant waste collection and transport activities but does not replace the need for appropriate site authorisation, exemption, permit, duty-of-care documentation or downstream authorisation where those are required.
Equipment We May Accept
Subject to assessment, Eco Tech Recycle may accept:
laptops;
MacBooks;
desktop PCs;
iMacs;
all-in-one computers;
workstations;
servers;
mini PCs;
thin clients;
mobile phones;
smartphones;
tablets;
iPads;
monitors;
networking equipment;
routers;
switches;
CCTV equipment;
gaming consoles;
chargers;
power supplies;
cables;
docks;
accessories;
smart devices; and
other related IT and electronic equipment.
Acceptance depends on the equipment type, quantity, legal status, condition, safety, location, data-security risk, repair potential, reuse potential, recycling route and agreed service scope.
Equipment We Do Not Normally Accept as Standalone Items
Unless agreed in advance, Eco Tech Recycle does not normally accept the following as standalone items:
televisions;
printers;
photocopiers;
CRT monitors;
white goods;
large household appliances;
lamps and lighting equipment;
fluorescent tubes;
loose unsafe batteries;
contaminated equipment;
chemically contaminated equipment;
equipment with medical or biological contamination;
equipment containing unknown hazardous substances;
fire-damaged equipment;
equipment presenting an immediate safety risk;
general household waste; or
non-electrical waste.
Certain items such as printers, televisions or mixed electrical equipment may sometimes be considered as part of a larger pre-approved business or IT collection where a lawful route is available.
This must be agreed before collection.
Eco Tech Recycle may refuse any item that is unsafe, unsuitable, materially misdescribed, not legally transferable, outside the agreed service scope or for which an appropriate lawful route is unavailable.
Faulty, Damaged, Incomplete or Untested Equipment
Eco Tech Recycle may accept faulty, damaged, incomplete, untested or no-power devices where they are safe to handle and suitable for the agreed route.
Examples include equipment with:
cracked screens;
faulty keyboards;
missing batteries;
missing storage drives;
missing RAM;
charging faults;
software faults;
no-power faults;
display faults;
cosmetic damage;
liquid damage;
damaged cases;
missing accessories;
unknown condition;
failed components; or
intermittent faults.
Acceptance does not guarantee:
repair;
reuse;
resale;
payment;
commercial value; or
a particular recycling route.
Following assessment, equipment may be directed to repair, refurbishment, parts recovery, recycling, return, specialist treatment or refusal.
Batteries and Fire-Risk Equipment
Batteries can create fire, storage and transport risks.
Customers must tell Eco Tech Recycle in advance where equipment contains or may contain:
swollen batteries;
leaking batteries;
punctured batteries;
burnt batteries;
heat-damaged batteries;
devices that become unusually hot;
devices that smoke, smell or spark;
fire-damaged devices;
loose lithium batteries;
damaged power packs;
liquid-damaged devices; or
exposed hazardous components.
Eco Tech Recycle may refuse, isolate, reclassify or separately handle equipment that appears unsafe.
Hazardous batteries and other hazardous components will be stored and handled using an appropriate route.
Customers must not send visibly unsafe batteries or fire-risk devices without prior agreement.
Reasonable additional packaging, handling, transport or specialist treatment charges may apply where they have been agreed or clearly communicated before the additional service is carried out.
Data-Bearing Equipment
Electrical and electronic equipment may contain personal, business, school, customer or organisational data.
Examples include:
laptops;
desktops;
MacBooks;
iMacs;
servers;
workstations;
phones;
tablets;
SSDs;
hard drives;
USB devices;
memory cards;
CCTV systems;
network devices; and
smart devices.
Customers should back up any information they wish to retain before handover.
Eco Tech Recycle’s data-security processes are explained in our Data Erasure & Data Security Policy.
Eligible equipment may be processed using licensed Certus data-erasure software where applicable.
A factory reset alone is not represented as certified secure data erasure.
Data-bearing equipment will not knowingly be released into an end-user reuse, resale or donation route while a known material data-security risk remains unresolved.
Where erasure is unsuccessful or unsuitable, storage media may be removed, securely destroyed, processed through an appropriate secure downstream route, returned where agreed or excluded from reuse.
Locks, MDM and Account Restrictions
Eco Tech Recycle does not unlawfully bypass security, ownership or organisation-management restrictions.
Devices may be refused, returned, held, revalued, reclassified or routed away from reuse where they are subject to:
Apple Activation Lock;
iCloud;
Find My;
Google Factory Reset Protection;
Samsung Account restrictions;
BIOS or firmware passwords;
MDM;
Microsoft Intune;
Windows Autopilot;
Jamf;
Apple Business Manager;
Apple School Manager;
Google Workspace management;
school, business or organisation management profiles;
finance restrictions;
lease restrictions; or
other ownership restrictions.
Customers should remove relevant restrictions before handover where they have authority to do so.
Customer Preparation Before Collection or Drop-Off
Before collection or drop-off, customers should, where reasonably possible:
back up required data;
remove SIM cards;
remove memory cards;
remove personal accessories;
remove cases or covers not intended for transfer;
remove Apple ID, iCloud and Find My restrictions;
remove Google FRP restrictions;
remove Samsung Account restrictions;
remove MDM and organisation-management profiles;
remove BIOS or firmware passwords where appropriate;
sign out of personal accounts;
provide charger information where relevant;
separate equipment by type where practical;
provide an asset list where available;
disclose faults;
disclose liquid damage;
disclose missing components;
disclose battery issues; and
ensure equipment is accessible for collection.
Customers should not send passwords, banking credentials, recovery keys, authentication codes or other sensitive credentials unless Eco Tech Recycle has provided a specific secure process for a clearly defined legitimate purpose.
Ownership and Authority
By offering equipment to Eco Tech Recycle, the customer confirms that:
they own the equipment or are authorised by the legal owner to release it;
the equipment is not knowingly stolen;
it is not subject to an undisclosed ownership dispute;
relevant lease, finance or third-party ownership arrangements have been disclosed;
they have authority to instruct Eco Tech Recycle to handle the equipment; and
information supplied is accurate to the best of their knowledge.
Eco Tech Recycle may refuse, delay, hold, return or suspend processing where ownership, authority, lease, finance, theft or other legal concerns arise.
Waste Duty of Care and Documentation
Where equipment is waste or becomes waste, applicable waste duty-of-care requirements apply.
Depending on the route, customer type and waste classification, records may include:
collection confirmation;
handover records;
asset lists;
waste transfer notes or equivalent records;
hazardous waste consignment documentation where required;
internal intake records;
serial-number or IMEI records;
data-erasure records where applicable;
downstream recycling or treatment records; and
invoices or payment records where applicable.
Business and organisational customers may have their own legal responsibilities to describe, classify, store and transfer waste correctly and to retain relevant duty-of-care records.
The level of documentation supplied by Eco Tech Recycle depends on the service agreed and legal requirements.
Business, School, Charity and Organisation Collections
For organisations, Eco Tech Recycle may request:
asset lists;
equipment quantities;
device types;
serial numbers;
site contacts;
collection addresses;
access details;
data-security requirements;
ownership or authority confirmation;
safeguarding or visitor instructions;
collection timing restrictions;
loading requirements;
waste documentation requirements; and
reporting requirements.
Organisations should ensure that only authorised personnel release equipment.
Specific visitor, safeguarding, reception, loading or site-access requirements must be communicated before collection.
When Equipment Becomes WEEE
Whether equipment is EEE or WEEE is determined by applicable waste law and the circumstances.
Equipment becomes waste where the holder discards it, intends to discard it or is required to discard it.
Equipment may therefore already be WEEE when transferred to Eco Tech Recycle, even where repair, refurbishment or reuse is being considered.
Where used EEE is transferred without becoming waste, the applicable legal conditions for genuine continued use or reuse must be met.
Eco Tech Recycle will not deliberately describe WEEE as non-waste EEE merely because it may later be repaired, refurbished or reused.
POPs and WEEE Reuse
Some WEEE and components may contain persistent organic pollutants (POPs).
Eco Tech Recycle will apply applicable POPs requirements when assessing WEEE for repair, refurbishment, component recovery or reuse.
WEEE that is identified as POPs waste will not be repaired or refurbished for reuse where applicable law prohibits that route.
Equipment or components requiring POPs destruction or other specialist treatment will be directed to an appropriate authorised downstream route.
Where components are removed from WEEE, their waste and POPs status must be considered before any reuse route is selected.
Parts Recovery
Where whole-device reuse is not suitable, Eco Tech Recycle may recover components where this is lawful, safe and practical.
Potential components may include:
screens;
keyboards;
RAM;
storage devices;
chargers;
power supplies;
motherboards;
speakers;
cameras;
housings;
cables; and
other internal parts.
A component removed from WEEE does not automatically cease to be waste merely because it may be reusable.
Where applicable, relevant end-of-waste, POPs, data-security, safety and reuse requirements must be satisfied before a component is released as a non-waste reusable product.
Data-bearing components will not knowingly be released for reuse while an unresolved material data-security risk remains.
Parts that are unsuitable for lawful reuse will be directed to an appropriate recycling, recovery or treatment route.
Downstream Recycling and Treatment
Where Eco Tech Recycle cannot lawfully or practically reuse, repair, refurbish or recover equipment, it may transfer material to an appropriately authorised downstream recycling, treatment, recovery or specialist processing route.
Downstream routes may vary according to:
equipment type;
waste classification;
condition;
hazardous components;
POPs status;
location;
legal requirements; and
available authorised providers.
Eco Tech Recycle aims to select appropriate downstream routes and avoid unnecessary disposal.
However, Eco Tech Recycle does not guarantee that every item, component or material will be reused, recycled or recovered in full.
Some material may require specialist treatment, destruction, disposal or energy recovery where legally appropriate.
WEEE Evidence and AATF Status
WEEE evidence notes are subject to specific regulatory rules and may only be issued by organisations with the required approval or authorisation.
Eco Tech Recycle does not represent its T11 exemption as AATF status.
Unless Eco Tech Recycle separately holds the required approval at the relevant time, customers should not assume that Eco Tech Recycle can issue WEEE evidence notes.
Where a customer has a specific WEEE evidence requirement, this must be discussed and agreed before the service begins so that an appropriate lawful route can be arranged.
Mixed Loads
A mixed load may contain:
reusable equipment;
repairable equipment;
WEEE;
locked equipment;
incomplete equipment;
parts-recovery items;
recycling-only material;
data-bearing devices;
accessories;
cables; and
out-of-scope items.
Eco Tech Recycle may separate the load into different routes after assessment.
Where a customer requires item-by-item valuation, asset recording, serial-number reporting, data-erasure reporting, WEEE classification or detailed route reporting, this must be agreed as part of the service.
Additional charges may apply where detailed reporting is outside the standard agreed scope.
Environmental Claims
Eco Tech Recycle aims to reduce unnecessary waste and prioritise suitable reuse.
We avoid unsupported absolute environmental claims.
Unless supported by appropriate evidence, we do not claim that:
every device will be reused;
every device will be repaired;
every item will have value;
every item will avoid recycling;
every component will be recovered;
every item will avoid disposal or energy recovery;
our service is carbon neutral;
our service produces zero landfill;
our service is 100% sustainable;
all equipment is 100% recyclable; or
every device receives certified data erasure.
Environmental information or reporting should reflect the actual service, records and route taken.
Reuse, Resale and Donation
Equipment may only enter a reuse, resale or donation route where Eco Tech Recycle considers that route lawful and appropriate.
Factors may include:
legal waste status;
condition;
functionality;
safety;
data-security outcome;
POPs assessment;
battery condition;
lock status;
ownership status;
cosmetic grade;
compatibility;
customer instructions;
market demand; and
commercial viability.
A device is not automatically suitable for reuse merely because it powers on.
Donation does not override waste, data-security, product-safety or POPs requirements.
Device Grading and Route Decisions
Eco Tech Recycle may record separate classifications for:
cosmetic condition;
functional condition;
screen or display condition;
security and lock status;
completeness;
data-erasure status; and
commercial or recycling route.
A physically good device may still be unsuitable for reuse because of data, legal, lock, safety or POPs concerns.
A cosmetically poor device may remain suitable for repair, lawful parts recovery or another appropriate route.
Further information is set out in our Device Grading, Functional Condition & Resale Classification Policy.
Customer Instructions About Reuse or Waste
Customers should tell Eco Tech Recycle before processing begins where they require a specific outcome, such as:
reuse assessment;
recycling only;
no resale;
no donation;
data-erasure reporting;
storage-media destruction;
asset recording;
return of specified items;
donation route;
parts recovery only;
waste-transfer documentation; or
specific downstream requirements.
Eco Tech Recycle may accept or decline instructions depending on legality, feasibility, safety, cost and available routes.
Customer instructions cannot require Eco Tech Recycle to treat waste as non-waste or to carry out an activity that is not legally authorised.
Valuation and Recycling Cost
Equipment may have positive value, no commercial value or negative value once collection, testing, data security, repair, treatment and recycling costs are considered.
Valuation and payment arrangements are governed by the Collection, Device Acceptance & Valuation Policy and Purchase, Buy-Back & Payment Terms.
Transport, specialist handling, recycling or treatment costs may affect whether a collection is:
free;
chargeable;
associated with a purchase offer; or
declined.
A device with a high original purchase price may have little or no current value where it is obsolete, locked, damaged, incomplete, unsafe, untestable, data-risk affected or uneconomical to repair.
Customer Responsibility for Accurate Information
Customers should provide accurate information about:
equipment type;
quantity;
condition;
known faults;
missing components;
battery condition;
lock status;
ownership;
data-security requirements;
location;
access; and
hazardous or unsafe characteristics.
Eco Tech Recycle may revise or withdraw a collection, valuation, acceptance decision or route where information supplied was materially inaccurate, incomplete or misleading.
Refusal, Reclassification and Return
Eco Tech Recycle may refuse, reclassify, isolate, return or propose additional handling arrangements where equipment:
is outside the agreed scope;
is unsafe;
is materially different from its description;
contains hazardous or contaminated material;
contains unsafe batteries;
cannot lawfully be transferred;
has unresolved ownership concerns;
cannot be lawfully processed under Eco Tech Recycle’s available routes;
creates an unexpected material safety or handling risk; or
requires specialist treatment not agreed in advance.
Reasonable additional handling, return or specialist treatment charges may apply where they were agreed or clearly disclosed, or where materially inaccurate customer information creates a different service requirement and the customer agrees to the revised arrangement.
Records, Photographs and Evidence
Eco Tech Recycle may create records or photographs for legitimate purposes including:
collection evidence;
condition evidence;
asset tracking;
valuation;
route decisions;
repair assessment;
data-security workflows;
recycling documentation;
waste duty-of-care records;
dispute handling;
quality control; and
fraud prevention.
Records may contain device condition, batch layout, labels, serial numbers, IMEI numbers, damage, missing components or storage-media information.
Personal data within these records will be handled in accordance with the Privacy Policy and applicable data-protection law.
Liability and Statutory Rights
Eco Tech Recycle will take reasonable care when handling equipment.
However, many items supplied are used, faulty, damaged, incomplete, untested, obsolete or end-of-life and may contain hidden defects or unstable components.
Subject to applicable law, Eco Tech Recycle will not normally be responsible for loss arising solely from:
pre-existing faults;
hidden faults that could not reasonably have been identified;
normal failure of old or damaged components;
reduction in value caused by undisclosed faults;
customer failure to remove locks;
customer failure to disclose battery or safety risks;
customer failure to disclose ownership restrictions;
items not supplied or recorded; or
materially inaccurate customer information.
Data-related handling is also subject to the Data Erasure & Data Security Policy.
Nothing in this Policy excludes or restricts liability for:
death or personal injury caused by negligence;
fraud or fraudulent misrepresentation;
failure to provide a consumer service with reasonable care and skill where required by law;
statutory rights that cannot lawfully be excluded or restricted; or
any other liability that cannot lawfully be excluded or restricted.
Nothing in this Policy affects a consumer’s statutory rights.
Complaints
Customers with concerns about recycling, WEEE handling, collection, route decisions, documentation, return, valuation or communication may complain under the Eco Tech Recycle Complaints Policy.
Complaints should be sent to:
Email: info@ecotechrecycle.co.uk
Subject: Complaint – Recycling / WEEE
Where possible, please include:
customer name;
organisation name, where applicable;
collection or reference number;
device or batch details;
date of collection or drop-off;
summary of the issue;
relevant photographs or documents; and
the outcome requested.
Eco Tech Recycle will review complaints fairly in accordance with its Complaints Policy and applicable legal obligations.
Changes to This Policy
Eco Tech Recycle may update this Policy to reflect changes in:
legislation or regulatory guidance;
business operations;
collection routes;
repair or reuse processes;
WEEE handling requirements;
downstream recycling routes;
data-security procedures;
compliance requirements; or
customer feedback.
The version applying to a confirmed service will normally be the version in force when that service was agreed, together with any specific written terms applicable to that service.
Later changes will not normally alter a confirmed contract retrospectively unless:
the customer agrees;
the change is required by law; or
another lawful basis permits the change.
The current version will be available on our website.
Contact Us
Eco Tech Recycle
A trading name of Tech Cell Limited
Company No. 14338989
Email: info@ecotechrecycle.co.uk
Telephone: +44 7777 239555
Website: www.ecotechrecycle.co.uk
Contact Address:
Suite 2, First Floor
16 Industrial House
Grand Arcade
London
N12 0EH