UAE Cabinet Resolution No. 39 of 2021 and E-Waste
By Ali Hassan, Editor, MAH Recycling
One article of Cabinet Resolution No. 39 of 2021 puts a take-back duty on whoever supplies electronics to the UAE. If you distribute devices, build them or simply retire them in bulk, it is worth reading the text rather than a summary. This guide covers what it says and what records back it up. It is general information, not legal advice.
What the resolution is
Cabinet Resolution No. 39 of 2021 is the executive regulation of Federal Law No. 12 of 2018 on Integrated Waste Management. It was issued on 21 April 2021 and took effect the day after publication in the Official Gazette.
Three definitions shape everything else. E-waste means damaged electrical and electronic equipment, or parts of it, disposed of by the consumer. Battery waste covers batteries, expired or not, that the consumer disposes of. A consumer is any person or legal entity that uses such devices, so companies are consumers too.
What suppliers must do
Article 2(2) sets four duties for suppliers:
- Accept returned products and bear the cost of proper disposal.
- Collect e-waste and battery waste from consumers free of charge, using recycling bins in their sales centres.
- Send the competent authority a monthly report on quantities collected and how they were treated or disposed of.
- Bear all treatment and disposal costs.
Article 2(3) lets the competent authority add further requirements, so local rules may go beyond this text.
Who owes what
| Role | Duty under the resolution | Records that support it |
|---|---|---|
| Supplier (distributor, OEM, retailer) | Take back e-waste and batteries free; report monthly; bear costs (Art. 2) | Weights collected, treatment method, recycler records |
| Corporate waste producer | Dispose of waste properly and bear the cost (Art. 2(1)) | Asset inventory, transfer record, certificate |
| Establishment handling hazardous waste | Separate, classify and report as the authority requires (Art. 5) | Waste type log, data submitted to the authority |
| Operator moving waste between emirates | Licensed carrier, tracked vehicle, hand-over certificate (Art. 6) | Hand-over certificate, transport records |
Where corporates fit
A company retiring laptops is both a consumer and a waste producer. The take-back duty is written around bins in sales centres, so it may not suit a bulk pickup of racks or fleets. The text does not carve out business consumers, so ask your supplier whether it accepts corporate volumes. Even if it does, the producer duty in Article 2(1) stays with you.
Article 9 matters for batteries and residues. Residual e-waste goes to hazardous landfill, and burying battery waste is banned in every landfill type. Both points favour a documented recycling route.
What a supplier’s monthly report needs
The regulation asks for quantities and the treatment or disposal method. Our reading is that suppliers need downstream data from their recycler, such as weights received, treatment method and a hand-over record per batch. That is an inference from the report requirement, not wording in the text, so confirm the format with the authority.
What is still changing
In July 2025, the Ministry of Climate Change and Environment signed an agreement with Tadweer Group for the UAE’s first Extended Producer Responsibility pilot. It covers electrical and electronic equipment, batteries and packaging, runs in Abu Dhabi and Dubai, and names Tadweer as the producer responsibility organisation. Treat it as a pilot that informs future policy, not as binding law.
Check the current text and local rules with your legal team. For documented collection and recycling, see our e-waste recycling service.
