Compliance ServicesJason Linnell, NCER

Overview

• State laws: Dividing the states– Know the system types

• Manufacturer needs and possible services

• Other types of Compliance services– EPEAT and design initiatives

Overview of State Laws

• 21 states (+NYC) with some type of e-waste lawo CA, CT, IL, IN, HI, ME, MD, MI, MN, MO,

NC, NJ, NYC, OK, OR, RI, TX, VA, VT, WA, WI, WV

o Almost 170 million US residents or 56% of US population covered by a law

o One advanced fee, others producer responsibility

o 16 in effect as of 4/1/10o Fewer than half in effect for over 1 year

State Models

• Pounds sold – OEM lbs goal anywhere in state, individual goals– IL, IN, (MI), MN, (NYC), WI

• Default and opt-out, usually with convenience goals, collective programs– OR, RI, (VT), WA

• Limited takeback programs– MD, MO, (NC), OK, TX, VA, WV,

• Recycler approval, then bill manufacturer– CT, ME

State Law Compliance Services

• Traditional collector relationships and logistics services– Find pounds from collectors to meet OEM need– Manage collector network requirements in

default/opt-out states– Provide transport services, report results

• Broker pounds in lbs sold states– To other OEMs, recycler; beware of deadlines!– Risk in taking from local govt without OEM buyer

More State Law Compliance Services

• Data Services– Know all you can!– Track brands, product categories, product age (if

possible)– All could be valuable and make the difference in

getting contracts• Currently required in few states, but could expand

• Consulting services– Knowledge about laws/models can be service to

OEMs, other vendors

Other Services

• EPEAT– Know the extra points! Manufacturers looking for

Gold may need recycler assistance– Track materials down three levels– Keep tabs on developing TV/Imaging standards

– more detailed recycler requirements likely on OEM to their recycler/s: offer proactive solutions!

– Closed loop recycling – work with downstream vendors and then contract manufacturers

• I.E. Extra points for plastics post-consumer content

Other Services

• General DfE/DfR– Evaluate processes and track data on

challenges from product design – be ready when OEM asks

– Look for ways to incorporate data on materials of concern location – more data coming

Thank You!

Jason Linnell, NCERPhone: (304) 699-1008jlinnell@electronicsrecycling.org

Visit us on the web: www.electronicsrecycling.organd www.ecycleclearinghouse.org

Background Slides on State Laws

Overview of States With Laws

NYC

States With Producer Responsibility

Laws

States With ARF (Consumer Fees)

Laws

States With Landfill Disposal Fee

States With Disposal Ban/No E-Waste

Law

WV

MDCT

ME

VA

NC

IL

OK

TX

MO

MN

MI

CA

OR

WA

AR

RI

NH

VT

MA

NJ

IN

WI

Recycler Participation

WI

IN

CA

State Approval, Unlimited

States Approval, Limited

Default Program or Limited Manufacturer

All Manufacturers/Groups of Manufacturers,

Unlimited

NYC

OR

WA

TX

MO

MN

IL

MI

WV VA

NC

MD

NJ

ME

CTRI

OK

WI

NYC

RI

RETURNS 1 - Manufacturers must develop and implement their own recycling programs for their own returned products (TX requires program to collect from consumers, NC requires program to collect from collectors).

RETURNS + TV MARKET SHARE- IT Manufacturers pay for costs of their own branded products collected plus a pro rata share of orphan products. TV manufacturers pay based on their market share percentage of all TVs returned.

ME

CT

NJ

MDWV

HI

VA

NC

MI

IL

MO

OK

TX

MN

WA

OR

CAIN

Types of FinancingARF - Electronic Waste Recycling Fee, assessed on the sale of covered electronic products

FEE - Manufacturer Annual Registration Fees (can be significantly reduced by establishing an approved take-back program)

SHARE - Manufacturers must finance a program to collect & recycle their brand’s share of covered products, either collectively or independently

(LBS. SOLDManufacturer pays registration fee and for collection and recycling of covered electronic devices based on their yearly sales to households

LBS. SOLD SHAREManufacturers are a assigned a market share percentage based on total weight sold into the state.  A separate per capita goal is used for collection targets.

VT

Adding Covered EntitiesOur Patchwork Quilt

-Households-Small Business-Non-Profits-Any Entity w/ Fewer Than 7 Devices

-Households-Small Gov’t-Small Business-School Districts-Charities

Households Only Consumers Only (Who Use Computer Equipment for Home or Home Business Use)

Any Entity

Households& Schools

Hawaii

NYC

Rhode Island

HouseholdsSmall Business with fewer than 7 employees

-Households-Small Businesses-Public Schools

-Households-Charities-School Districts-Businesses (Less than 10 Employees)

Desktops, Laptops (over 4 inch),TVs (over 4 inch), Monitors (over 4 inch)

Laptops, TVs (over 9 inch), Monitors (over 9 inch)

Desktops, Laptops, TVs (over 4 inch), Monitors (over 4 inch)

TVs with exclusions (over 4 inch), Monitors (over 4 inch), Laptops (over 4 inch)

TVs (over 4 inch), Monitors (over 4 inch), Laptops (over 4 inch)

Desktops, laptops, computer monitors, printers, and TVs

Desktops, laptops, computer monitors, printers, keyboards, mice, digital music players, and TVs

*Product scope for MD and MN includes products triggering a manufacturer obligation to participate in the program.

NYC

Rhode Island

Desktops, laptops, computer monitors over 9 inch and TVs over 9 inch

Hawaii

Product Scope By State

Current MetricsMost Recent Per Capita Rates

State In Effect? DateCA Yes 1/1/2005

HI No 1/1/2010

IL No 1/1/2010

IN Yes 4/1/2010

ME Yes 1/18/2006

MD Yes 1/1/2006

MI Yes 4/1/2010

MN Yes 7/1/2007

MO Yes 7/1/2009

OK Yes 1/1/2009

OR Yes 1/1/2009

RI Yes 2/1/2009

TX Yes 9/1/2008

VA Yes 7/1/2009

VT No 7/1/2011

WA Yes 1/1/2009

WI Yes 1/1/2010

WV Yes 1/1/2009

18 In Effect Above, 4 Pending BelowCT No* 7/1/2009 – likely September 2010

NJ No 7/1/2010

NC No 7/1/2010

NYC No ??– delayed