The Environment Agency has published further guidance on the definition of ‘placed on the market’ being the point where Producers need to count the amount of electrical and electronic equipment, in tonnes, for which they have obligations. Using the EC guide to directives (the so-called Blue Book) they state that ‘placed on the market’ is considered to be the point when the intention for distribution or use in the UK is reached. The Agency have stressed that it is not the act of supplying the EEE but the point where it is made available for sale in the UK. The difficulty with this approach is, firstly, it doesn’t actually count products that will definitely be used in the UK (and hence end up in the UK waste stream) as products in UK warehouses could, ultimately, be exported, and does not take into account the cash flow implication for companies (having to ‘pay’ for their obligations on products not yet sold). The Agency state that they have previously taken a pragmatic approach (by allowing actual sales data to be used) but do not explain the reasons for abandoning their previous approach.