Compliance Services

1. Compliance Services Jason Linnell, NCER

2. Overview • State laws: Dividing the states • Know the system types • Manufacturer needs and possible services • Other types of Compliance services • EPEAT and design initiatives

3. Overview of State Laws • 21 states (+NYC) with some type of e-waste law • CA, CT, IL, IN, HI, ME, MD, MI, MN, MO, NC, NJ, NYC, OK, OR, RI, TX, VA, VT, WA, WI, WV • Almost 170 million US residents or 56% of US population covered by a law • One advanced fee, others producer responsibility • 16 in effect as of 4/1/10 • Fewer than half in effect for over 1 year

4. 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

5. 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

6. 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

7. 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

8. 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

9. Thank You! Jason Linnell, NCER Phone: (304) 699-1008 jlinnell@electronicsrecycling.org Visit us on the web: www.electronicsrecycling.org and www.ecycleclearinghouse.org

10. Background Slides on State Laws

11. Overview of States With Laws WA VT ME MN MA OR WI NH MI RI NJ CT MD IL IN CA WV NYC MO VA NC OK AR TX States With Producer Responsibility Laws States With ARF (Consumer Fees) Laws States With Landfill Disposal Fee States With Disposal Ban/No E-Waste Law

12. Recycler Participation WI IN WA ME MN OR MI NJ RI CT MD IL NYC WV CA MO VA NC OK TX State Approval, Unlimited States Approval, Limited Default Program or Limited Manufacturer All Manufacturers/Groups of Manufacturers, Unlimited

13. Types of Financing WI ARF - 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. SOLD Manufacturer pays registration fee and for collection and recycling of covered electronic devices based on their yearly sales to households LBS. SOLD SHARE Manufacturers 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. WA VT ME NYC MN OR MI CT RI NJ MD IN IL CA WV VA MO NC OK HI TX 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.

14. Adding Covered EntitiesOur Patchwork Quilt Rhode Island NYC Hawaii -Households -Charities -School Districts -Businesses (Less than 10 Employees) -Households -Small Businesses -Public Schools Households Only -Households -Small Business -Non-Profits -Any Entity w/ Fewer Than 7 Devices -Households -Small Gov’t -Small Business -School Districts -Charities Households & Schools Consumers Only (Who Use Computer Equipment for Home or Home Business Use) Households Small Business with fewer than 7 employees Any Entity

15. Hawaii Product Scope By State 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 Desktops, laptops, computer monitors over 9 inch and TVs over 9 inch Rhode Island NYC *Product scope for MD and MN includes products triggering a manufacturer obligation to participate in the program.

16. Current Metrics Most Recent Per Capita Rates