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2014 Northwest Hazardous Materials Conference

WASHINGTON H.B. 2246: MANUFACTURERS’ PERSPECTIVE . 2014 Northwest Hazardous Materials Conference. MARK A. KOHORST NATIONAL ELECTRICAL MANUFACTURERS ASSOCIATION Troutdale, OR June 2014. Topics. What is NEMA? NEMA and Lamp Recycling Lamp Recycling Legislation The Financing Question

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2014 Northwest Hazardous Materials Conference

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  1. WASHINGTON H.B. 2246: MANUFACTURERS’ PERSPECTIVE 2014 Northwest Hazardous Materials Conference MARK A. KOHORST NATIONAL ELECTRICAL MANUFACTURERS ASSOCIATION Troutdale, OR June 2014

  2. Topics • What is NEMA? • NEMA and Lamp Recycling • Lamp Recycling Legislation • The Financing Question • HB 2246 • Maine, Vermont • Where to from here?

  3. NEMA Vital Statistics • Created 1926, Largest US Trade Association of Electro-Industry Manufacturers • Membership: Appr 450 US Manufacturers • Products used in Generation, Transmission, Distribution, and End-Use of Electricity • 8 Industry Divisions, ~52 Product Sections • Dry Batteries to Motors to Traffic Signaling Equip to MRIs, etc. • Principally a Standards Organization • More than 500 Industry Standards; Internally and With ANSI and IEC • Also Advocacy, Data Collection & Analysis, International Collaboration, Safety Promotion

  4. NEMA Lamp Manufacturing Section • Currently 25 companies • Large, household name producers (GE, Philips, OSRAM, etc.) • Smaller, specialty lamp manufacturers • About $3billion in lamp shipments covering commercial, industrial, institutional, residential, automotive, and specialty lighting markets

  5. NEMA and Lamp Recycling • Manufacturers label every package sold in North America • Created www.lamprecycle.org– one stop center for recycling information • More than 200,000 page views per year • Separate pages for state programs • Ongoing education through distribution chain, outreach • Encourages enforcement of local, federal, state laws NEMA Actively Promotes Recycling Hg-added Lamps

  6. Legislation • Focus on residential market, not commercial/industrial • All manufacturers selling in the state must participate • “Level playing field” • Must include a “Sunset” Provision • Encourages state enforcement on non-compliant companies • Provides adequate state antitrust protection • For WA law, “state action doctrine” is crucial • Ensures sustainable financing for life of program • E.g., “Environmental Handling Charge” Key Elements of a State Lamp Recycling Law

  7. Financing Mechanism • Spent Hg-added lamps have virtually no residual value • Substantial difference from lead-acid batteries, certain electronics • Cost of recycling CFLs, LFs is very high relative to retail price of new products • Package of 8 leading brand CFLs (13w), $10.35 plus shpg on Amazon • EcoSmart 4-pack CFLS (13w), $3.97 at Home Depot • Loaded cost of recycling CFLs can approach 50 cents per unit • CFLs have long been “commodity products” – so pricing flexibility is extremely limited • Manufacturers do not “shift” costs between product lines • Cost internalizationnot a viable option for these products Key Considerations

  8. Environmental Handling Charge • Various precedents exist (e.g., paint, mattresses, tires) • Appliesto all manufacturers selling in the state, ensuring level playing field • Helps to educate consumers on importance of recycling • Uses third party “stewardship organization” for collection, disbursement • Subject to state review and approval • If kept low enough, not expected to deter sales • Temporary program . . . . Won’t last forever Not Ideal, butNecessaryfor a StatewideProgram

  9. H.B. 2246 • Expected to provide funds for comprehensive program • Provides flexibility concerning remittance of fees • Added to price when lamp is sold by producer – producer remits fee to SO OR • Retailer collects fee from consumers – retailer remits fee to SO • Consistent with ‘over the border’ program in British Columbia • Enacts a statewide disposal ban for mercury-added lights Not Ideal, butGoodSolutionfor WA State

  10. Other State Laws

  11. Where to from here? • FIRST – Get program started successfully in WA • SECOND – Observe, evaluate, improve as needed • BEYOND WASHINGTON . . . . • Each state is different • Politics unpredictable • Cost challenges remain difficult • MEANWHILE . . . . . • Mercury content still falling • Transition to next generation lighting continues

  12. Thanks for your attention! Mark A. Kohorst 703-841-3249 703-841-3349 (fax) Mar_kohorst@nema.org NEMA Suite 900 1300 North 17th Street Rosslyn, Va. 22209 www.nema.org

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