At a glance
| Point | As of 15 October 2026 |
|---|---|
| Legal basis | Ordinance on the Return, Take-back and Disposal of Electrical and Electronic Equipment (VREG) of 20 October 2021, SR 814.620, in force since 1 January 2022, version of 1 September 2023[1] |
| Underlying act | Environmental Protection Act (USG), Art. 30b[1][2] |
| Obligations | return by consumers, free take-back by producers and retailers, crossed-out wheeled bin symbol, notice of the take-back[1] |
| Register | no state producer register under the VREG[1] |
| Financing | voluntary advance recycling contribution (vRB) paid to Swico or SENS[3][9] |
| Enforcement | cantons; data to the Federal Office for the Environment (BAFU) on request[1] |
| Open | recognition of industry organisations and contributions from non-members: act adopted but not in force; ordinance at draft stage[2][5][6] |
| Batteries | regulated separately, state advance disposal fee (VEG) collected via INOBAT[15] |
How the Swiss system works
Switzerland regulates waste electrical and electronic equipment without a registration obligation. The VREG obliges everyone involved to return and take back equipment, but does not prescribe how this is financed[1]. Since the 1990s, industry schemes run by the private sector have taken on this task[9][12].
- Consumers must return end-of-life equipment to retailers, producers, disposal companies or public collection points; disposing of it with household waste or bulky waste is prohibited[1][3].
- Producers take back equipment of the brands they manufacture or import free of charge[1].
- Retailers take back equipment of the type they stock free of charge, even without a new purchase; retail stores (Detailhändler) do so at their points of sale during opening hours[1][11].
- Producers affix the crossed-out wheeled bin symbol visibly and permanently to the equipment; those obliged to take back equipment point out the free take-back[1].
Financing runs through the vRB. A producer or importer joins Swico or SENS, charges the contribution per device to the trade and pays it into the scheme's fund. The trade passes it on to end customers, who later hand in the device free of charge[9][14]. If you do not join a scheme, you remain bound by the VREG: you dispose of the returned equipment at your own expense, keep a record of equipment sold and taken back, and give the BAFU and the cantons access to it for the last five years[1].
For equipment designed exclusively for professional or commercial use, only the disposal requirements and the data collection of the VREG apply, not the take-back obligation[1]. Until the Federal Department of the Environment, Transport, Energy and Communications (UVEK) specifies the equipment covered, the VREG lists seven categories, from consumer electronics through household appliances and lamps and luminaires to tools, sports and leisure equipment and toys[1].
vRG, vRB, VEG: the terms
The Swiss terms sound similar but mean different things. Swico explains: "vorgezogene Recyclinggebühr (vRG)" (advance recycling fee) is the historical name; because a fee (Gebühr) is a state charge but the system is voluntary, the authorities today use "vorgezogener Recyclingbeitrag (vRB)" (advance recycling contribution)[9].
| Term | What it is | Who collects it | Mandatory? |
|---|---|---|---|
| vRG, vorgezogene Recyclinggebühr (advance recycling fee) | older name of the vRB, still used in Swico and SENS contracts | Swico, SENS[11][14] | voluntary |
| vRB, vorgezogener Recyclingbeitrag (advance recycling contribution) | contribution per device for collection, transport and recycling | Swico, SENS[9][12] | voluntary, contractual once you join |
| VEG, vorgezogene Entsorgungsgebühr (advance disposal fee) | state fee, for example on batteries | INOBAT on behalf of the BAFU[15] | statutory |
| vEB, vorgezogener Entsorgungsbeitrag (advance disposal contribution) | planned contribution from non-members to a recognised industry organisation | in the draft[6] | draft, not adopted |
Swico, SENS and INOBAT compared
Which scheme is responsible depends on the product group. If you sell equipment from both areas, you sign the appropriate contract for each area; in its affiliation contract, SENS explicitly asks whether a Swico contract exists[14].
| Feature | Swico Recycling | SENS eRecycling | INOBAT |
|---|---|---|---|
| Product groups | office, IT, consumer electronics, communications, photography, graphic arts industry, measuring and medical technology, security technology, musical instruments, dental equipment[9][10] | refrigeration and large household appliances, small household appliances, luminaires and lamps, tools, toys, photovoltaics, heat pumps, e-cigarettes, welding equipment[12][14] | batteries and rechargeable batteries of all kinds[15] |
| Basis | voluntary industry solution under the VREG[9] | voluntary industry solution under the VREG[14] | state VEG under the Chemical Risk Reduction Ordinance[15] |
| Contract | Convention on the Recycling of Electrical and Electronic Equipment (Konvention über Recycling von Elektro- und Elektronikgeräten)[11] | affiliation contract for producers/importers (Anschlussvertrag)[14] | registration with INOBAT[15] |
| Reporting and settlement | half-yearly using a control sheet; from 15,000 francs of vRB per year with confirmation from a fiduciary office[11] | half-yearly, quarterly or monthly, as you choose[14] | quarterly in the AVEG portal[15] |
| Term | withdrawal with six months' notice to the end of a calendar year[9][11] | one fixed year, then six months' notice to the end of the year[14] | statutory obligation[15] |
| Batteries in equipment | included in the vRB, no separate settlement with INOBAT[9] | included in the vRB; SENS represents the partner towards INOBAT[14][21] | report loose batteries and replacement batteries directly[15] |
Luminaires and lamps used to be handled by the Stiftung Licht Recycling Schweiz (SLRS); it merged with SENS in 2021[12]. Both schemes cover Switzerland and Liechtenstein[9][14].
Who is affected
The VREG distinguishes between producers and retailers. A producer is anyone who manufactures equipment professionally or imports it into Switzerland for commercial supply; a retailer is anyone who obtains equipment and supplies it commercially in Switzerland[1]. The VREG sets no minimum quantity[1].
| Your situation | Role | What follows |
|---|---|---|
| You manufacture equipment in Switzerland | producer | take-back of your brands; joining Swico or SENS, or your own disposal with records[1][9] |
| You import equipment into Switzerland for commercial supply | producer | as above; the scheme settles the vRB with the party placing the equipment on the market[1][21] |
| You resell equipment from a Swiss importer | retailer | take-back of the equipment in your range and a notice about it; your supplier charges you the vRB[1][21] |
| You are an EU business supplying consumers in Switzerland directly | not explicitly regulated | joining is possible; a contribution obligation for non-members is planned, not in force[2][16][19] |
| You supply a Swiss importer from the EU | not a producer in Switzerland | the importer is the producer and settles the vRB[1][21] |
| Your equipment is designed only for commercial use | limited | only disposal requirements and data collection[1] |
Swico and SENS are open to all companies that manufacture equipment in Switzerland or Liechtenstein or import it there[11][14]. The SENS contract explicitly also covers equipment imported through mail order or online offers[14]. The public list of Swico convention signatories also includes companies based in Germany, the Netherlands or Luxembourg[16]. Whether a foreign online retailer without a Swiss seat already bears the VREG take-back obligations today is not explicitly regulated by the ordinance. The Federal Council classifies foreign online mail-order companies as parties placing products on the market[19]. The question remains open until the planned rules are adopted.
Joining step by step
- Assign product groups: using the Swico equipment list and the SENS tariff and equipment list; check equipment with batteries separately[10][13].
- Read the contract documents: for Swico the Convention and the Practical Guideline, for SENS the affiliation contract[9][14].
- Sign and send the declaration of accession or the affiliation contract. Membership of the Swico association is not required for Swico Recycling[9]. At SENS, the obligations apply from signature, with no entry fee and no back payment for earlier sales[14].
- Store the tariffs in your invoicing system and charge the vRB to the trade or to customers[9][14].
- Report and settle: Swico half-yearly using a control sheet, SENS at the interval you chose; loose batteries directly to INOBAT[11][14][15].
Tariffs 2026 and 2027
Both schemes raised their contributions as of 1 January 2026. Swico did so for the first time since 2015, with contractual certainty until 2030[10]. SENS raised the tariffs for small appliances and power tools because the small appliances fund had fallen below its lower limit[13].
| Scheme and device | vRB 2026 | vRB 2027 |
|---|---|---|
| Swico: notebook from 12 inches | 6.00 francs incl. VAT[10] | 6.00 francs[10] |
| Swico: smartphone, smartwatch | 0.20 francs incl. VAT[10] | 0.20 francs[10] |
| Swico: tablet 9 to 14.9 inches | 2.50 francs incl. VAT[10] | 2.50 francs[10] |
| Swico: television from 55 inches | 30.00 francs incl. VAT[10] | 30.00 francs from 56 inches[10] |
| SENS: device under 0.25 kg | 0.19 francs excl. VAT (previously 0.185)[13] | 0.19 francs[20] |
| SENS: device 0.25 to under 5 kg | 0.68 francs excl. VAT (previously 0.56)[13] | 0.68 francs[20] |
| SENS: device 5 to under 15 kg | 3.11 francs excl. VAT (previously 2.31)[13] | 3.11 francs[20] |
| SENS: device 15 to under 25 kg | 7.51 francs excl. VAT (previously 5.56)[13] | 7.51 francs[20] |
Swico calculates the vRB on the list price or recommended retail price, without discount; as of 2027, six tariffs fall, for example for docking stations from 2.50 to 0.50 francs[10]. SENS grades household appliances by declared goods weight; separate lists apply to refrigeration appliances, luminaires, power tools, toys, photovoltaics, heat pumps and e-cigarettes[21].
Towards consumers, the vRB must be included in the displayed price under the Price Disclosure Ordinance (Preisbekanntgabeverordnung). Swico recommends also showing it separately on quotations and invoices[9]. This differs from Germany: there, producers may not show disposal costs separately to end customers, as the guide to the ElektroG (German Electrical and Electronic Equipment Act) explains.
Free riders and revision: what is adopted and what is open
Part of the equipment recycled in the Swiss system is not financed. According to Swico and SENS, this mainly concerns purchases from foreign online retailers and platforms, as well as suppliers that do not join a scheme[8][18].
- Adopted: On 15 March 2024, Parliament amended the USG. Art. 32ater allows the Federal Council to oblige producers, importers and foreign online mail-order retailers to pay a vRB to a recognised industry organisation if its agreement covers at least 70 percent of the domestic market and 50 percent of the market participants[4].
- Not in force: Art. 32ater only enters into force at a later date; Fedlex shows this in the version of 1 August 2026[2].
- Draft: On 22 December 2025, the UVEK opened the consultation on the environmental ordinance package autumn 2026; it ran until 12 April 2026[5]. The draft of the Waste Ordinance (VVEA) provides for the recognition of industry organisations by the BAFU and an advance disposal contribution for non-members, including foreign online mail-order companies; the amount is to be set by the UVEK[6]. The draft names 1 November 2026 as the date of entry into force[6].
- Open: We have found no decision by the Federal Council up to 15 October 2026; the Waste Ordinance applies in the version of 1 August 2026 without these articles[7]. Swico rejects the draft in its current form because it does not effectively include foreign platforms[8]. On 6 May 2026, the Federal Council announced that, according to current planning, it will put rules on online mail-order retailers and platforms out to consultation at the end of 2026[19].
Until then, the current position applies to businesses: VREG obligations and voluntary membership. When and how much non-members will have to pay has not been determined.
Consequences of not participating
Joining Swico or SENS is voluntary; the VREG obligations apply regardless[1][9]. Enforcement lies with the cantons[1]. Violations of waste regulations based on Art. 30b USG are contraventions under Art. 61 USG[2]. SENS publicly lists non-participants[18].
Deadlines and timeline
| Date | Event | Status |
|---|---|---|
| 1 January 2022 | VREG of 20 October 2021 in force | applies[1] |
| 1 January 2025 | USG amendment on the circular economy in force, without Art. 32ater | applies[2] |
| 1 January 2026 | new vRB tariffs at Swico and SENS | applies[10][13] |
| 12 April 2026 | end of the consultation on the environmental ordinance package autumn 2026 | completed[5] |
| 1 November 2026 | entry into force named in the VVEA draft | draft, not adopted[6] |
| end of 2026 | planned consultation on online mail-order retailers and platforms | announced[19] |
| 1 January 2027 | tariff and equipment lists 2027 | published[10][20] |
Common mistakes
- Joining only one scheme despite a mixed range. Solution: assign each product group to the Swico or SENS list[10][13].
- Settling replacement batteries through the vRB. Solution: report loose batteries directly to INOBAT[15].
- Assuming the Swiss contribution covers EU sales. Solution: a separate registration in each EU country[17].
- Forgetting the wheeled bin symbol because there is no register. Solution: the symbol is mandatory in Switzerland too[1].
For businesses from Switzerland, the Netherlands and Austria
The Swiss industry scheme does not apply to sales into the EU. In the EU, registration is state-run and applies per country; a German registration applies only in Germany[17].
- Germany: A Swiss producer without a German establishment appoints an authorised representative for electrical equipment, who registers with stiftung ear (the German WEEE register). The guides ElektroG and WEEE number show how this works[22].
- Batteries in equipment: Under German battery law, too, a foreign direct seller needs an authorised representative[17].
- Packaging: For shipping packaging, registration and system participation are added; the guide to EPR gives an overview of all areas.
Businesses from the Netherlands, Austria or Germany that supply customers in Switzerland directly are registered in the EU but are not automatically covered in Switzerland. They can join Swico or SENS; an obligation for foreign mail-order retailers is planned but not adopted[6][14][19]. What representation in EU countries costs is shown in our article on the costs of an EPR authorised representative. In a digital needs analysis for businesses with Switzerland, the Netherlands or Austria as their home market, ClearoSystems checks which obligations apply per product, role, sales channel and country, and then supports registration, reports and the appointment of an authorised representative.
Status and changes
As of 16 October 2026. On that day we checked the VREG (version of 1 September 2023), the USG and the VVEA in the version of 1 August 2026 on Fedlex, the amendment to the USG of 15 March 2024, the consultation draft of the environmental ordinance package autumn 2026, the Federal Council's opinion on motion 26.3243, the producer, tariff and contract pages of Swico and SENS, and the INOBAT page for producers and importers[1][2][4][6][19]. Changes: 15 October 2026, first version; 16 October 2026, technical clarifications after expert review (vRB as the current name). Translated from the German version of 16 October 2026.
Frequently asked questions
- Is joining Swico or SENS mandatory?
- No. Joining is voluntary. The take-back obligation under the VREG applies in any case, however. If you do not join a scheme, you must dispose of the returned equipment yourself, document sales and take-back figures and keep the records for five years. Swico considers going it alone more expensive than joining.
- Do I need a registration number in Switzerland, like the WEEE number?
- No. Switzerland has no state producer register and no registration number for electrical equipment. You sign a contract with Swico or SENS and settle the contributions there. Marketplaces in the EU that require a WEEE number mean the registration in the respective EU country.
- My product fits both schemes, for example a smart speaker with a light function. Where do I report it?
- What counts is how the equipment is assigned in the lists of the two schemes. Swico covers consumer electronics such as speakers, SENS covers luminaires. For equipment with several functions, clarify the assignment with the scheme before the first sale so that it is not reported twice.
- We sell from Germany into Switzerland through an online shop. Do we have to charge the vRB?
- There is currently no statutory contribution obligation for foreign mail-order retailers; it is provided for in the draft of the Waste Ordinance, but not adopted. You can join voluntarily and then settle the vRB like a Swiss importer. Whether you already bear VREG take-back obligations today is not explicitly regulated.
- Does my Swico membership also cover my sales to Germany?
- No. Swico and SENS cover only Switzerland and Liechtenstein. For Germany you need a separate registration with stiftung ear; as a business without a German establishment, through an authorised representative.
Sources
- [1]Verordnung über die Rückgabe, die Rücknahme und die Entsorgung elektrischer und elektronischer Geräte (VREG), SR 814.620, Stand 1.9.2023 (accessed 15 Oct 2026)
- [2]Bundesgesetz über den Umweltschutz (USG), SR 814.01, Stand 1.8.2026 (accessed 15 Oct 2026)
- [3]BAFU: Elektrische und elektronische Geräte (accessed 15 Oct 2026)
- [4]Umweltschutzgesetz, Änderung vom 15. März 2024, AS 2024 648 (accessed 15 Oct 2026)
- [5]UVEK, Medienmitteilung vom 23.12.2025: Vernehmlassung über sechs Verordnungen im Bereich Umwelt (accessed 15 Oct 2026)
- [6]Vernehmlassungsentwurf: Abfallverordnung (VVEA), Änderung, Verordnungspaket Umwelt Herbst 2026 (accessed 15 Oct 2026)
- [7]Abfallverordnung (VVEA), SR 814.600, Stand 1.8.2026 (accessed 15 Oct 2026)
- [8]Swico: Vernehmlassungsantwort zum Verordnungspaket Umwelt Herbst 2026 vom 10.04.2026 (accessed 15 Oct 2026)
- [9]Swico Recycling: Hersteller und Importeure, mit FAQ (accessed 15 Oct 2026)
- [10]Swico Recycling: Tarife und Geräteliste, vRB 2026 und 2027 (accessed 15 Oct 2026)
- [11]Swico: Konvention über Recycling von Elektro- und Elektronikgeräten (accessed 15 Oct 2026)
- [12]SENS eRecycling: Branchen und Elektrogerätekategorien (accessed 15 Oct 2026)
- [13]SENS eRecycling: Anpassung der Tarife ab dem 1. Januar 2026 (accessed 15 Oct 2026)
- [14]SENS: Anschlussvertrag zum SENS-Rücknahmesystem (Fassung 04.09.2025) (accessed 15 Oct 2026)
- [15]INOBAT: Informationen für melde- und gebührenpflichtige Firmen (accessed 15 Oct 2026)
- [16]Swico Recycling: Liste der Konventionsunterzeichner (accessed 15 Oct 2026)
- [17]stiftung ear: Pflichten als Hersteller nach ElektroG und Batterierecht, FAQ zur Geltung in anderen EU-Ländern (accessed 15 Oct 2026)
- [18]SENS eRecycling, 28.07.2026: Faires Recycling beginnt beim Kauf (accessed 15 Oct 2026)
- [19]Curia Vista 26.3243, Motion Gmür-Schönenberger: Gleichbehandlung von Online-Plattformen gemäss VREG, Stellungnahme des Bundesrats vom 06.05.2026 (accessed 15 Oct 2026)
- [20]SENS eRecycling: Tarif- und Geräteliste 2027 (accessed 15 Oct 2026)
- [21]SENS eRecycling: Tarif- und Geräteliste, gültig ab 1. Januar 2026 (accessed 15 Oct 2026)
- [22]stiftung ear: WEEE-Registrierung beantragen als ausländisches Unternehmen (accessed 15 Oct 2026)


