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California’s Electronic Waste Recycling Program. SB 20/50: An Overview of Collector & Recycler System Requirements CIWMB E-waste Group www.eRecycle.org. E-Waste Recycling Program Material & Cash Flow. Payments.
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California’s Electronic Waste Recycling Program SB 20/50: An Overview of Collector & Recycler System Requirements CIWMB E-waste Group www.eRecycle.org
Payments • Distribution of recovery and recycling payments to qualified (approved) entities to cover the cost of collection and recycling. • Eligible activities began January 1, 2005. • Only properly documented covered electronic wastes (CEW’s) collected from CA sources after start date are eligible for payment. • Payments are limited to recycling (cancellation) activities that occur in-state.
California Source “California Sources” of CEWs are consumers, as defined in Section 42463 (d) of the Public Resources Code, located in California who generate CEWs after their own use of the CEW. California sources may include, but are not limited to the business sector, residential sector, local government, state government, schools and other institutions within the borders of California. Entities who take, further handle, consolidate, store, or otherwise deal with discarded, donated or collected CEWs are not California consumers, or California sources. (14 CCR 18660.5(a)(11))
Payments • Collectors and recyclers must offer a “cost-free and convenient” collection opportunity as a condition of payment. • Initial combined recycling payment rate is $.48 per pound of material cancelled (includes $.20 per pound recovery payment which must be passed on to Approved Collector). • CIWMB may revise the payment amount every two years if necessary.
Responsibilities Under The Act - Approved Collectors An Approved Collector is entitled to receive $.20 per pound for CEWs transferred to an Approved Recycler if the Collector: • Tracks sources of CEWs and only transfers CEWs generated from CA sources for payment. • Submits required collection documentation to approved Recycler(s) • Establishes a cost-free opportunity for the collection of CEWs.
Responsibilities Under The Act - Approved Recycler An Approved Recycler may claim $.48 per pound of CEWs cancelled in a manner approved by the State if the Recycler: • Is inspected by DTSC and be found to be in conformance with all applicable laws, and is accessible during normal business hours for unannounced inspections or audits by state or local agencies. • Only submits claims for eligible CEWs, including supporting documentation, to CIWMB as specified in regulation. (CEWs that are reused are not eligible for recycling payment claim.) • Makes recovery payments ($.20 per pound) to Approved Collectors within 60 days of the date of transfer of CEWs.
Useful Forms • Application for Approval • Collection Log • Transfer Receipt • Payment Claim • Claim Worksheets • Posted at:www.ciwmb.ca.gov/Electronics/Act2003/Recovery/
Claim Organization • Provide a table of contents • Organize the package logically • Ensure that collection logs and all other supporting documentation are clear and comprehensive • When in doubt, provide extra description
Common Claim Challenges General • Documentation is illegible (logs, weight tickets, receipts) • Collector/Recycler relationship unclear • Signatures on claim or supporting documentation are not that of a person(s) with designated signature authority (Section 18660.11) • Confusion regarding what constitutes a Reporting Period
Common Claim Challenges (cont.) Ineligible Material Claimed • Accumulated prior to Jan 1, 2005 • Received from undocumented source • Exempted equipment (PRC 42463(f)(2)) included
Common Claim Challenges (cont.) Source Documentation • Collection logs are missing or deficient. (18660.20(j)) • Collection activities details are missing • Materials received from other handlers lacks source documentation. • Confusion regarding Local Government provision and/or unclear Agent authority
Common Claim Challenges (cont.) Transfer Documentation • Transfer receipts missing or misused • Descriptions of discrepancies • Recovery payment documentation
Common Claim Challenges (cont.) Processing Documentation • Record of definitive cancellation (weight, date, method) (18660.21(l)(3)) • Processing Log (description of cancellation activities including the types of cancellation methods used, and the time periods in which each cancellation occurred) often not included (18660.22(c)(2)) • Manufacturers names, model numbers, serial numbers and weights for non-CRT-containing CEWs missing (18660.25(e)(4))
Common Claim Challenges (cont.) Disposition Documentation • Missing or incomplete shipping documents for glass and residuals • Missing receipts from the end use destination and no description of the ultimate disposition of the glass cullet or bare CRTs demonstrating that the disposition is not disposal to land, water, or air (18660.23(g) or 18660.24(g)) • A quantification and description of the disposition of treatment residuals (18660.24(h))