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Final Regulation Workshop

California’s Electronic Waste Recycling Program

November 2006

CIWMB Electronic Waste Recycling Program

www.ciwmb.ca.gov/electronics www.eRecyle.org

ewaste@calepa.ca.gov

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Electronic Waste Recycling Act of 2003

• Advance recycling fee (ARF) on retail sales of covered electronic devices • Recovery / recycling payments to qualified handlers of covered electronic wastes (CEWs)• Manufacturer requirements:

–labeling, reporting –product design: ROHS–consumer information

• State purchasing guidelines: EPP• Statewide public education campaign

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Statutory & Regulatory History

• SB 20 – October 2003– Initial emergency regs April 2004

• SB 50 – September 2004– Revised emergency regs November 2004

• Program start – January 2005– Revised emergency regs November 2005

• Final rulemaking – 2006 – Final regulations adopted by CIWMB July 2006– Final regulations approved by OAL November 27th

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CEW Payment System at a Glance

Consumer RetailerFee paidat purchase

Remits fee (Quarterly)

Deposits fee

Program Implementation

Permitting+ Inspections

Fee Collection

Recycling payment(48¢/lb)

Recovery payment(20¢/lb)

IWMB

DTSC

BOE

Recyclers Collectors

E-Waste Account

USED item recycled as “E-Waste”

NEW itempurchased

E-Waste

Electronics

$$

Payment Claim

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CEW Collectors and Recyclers

• CIWMB collaborates with DTSC on approvals

• Requires appropriate notification, authorization, and/or inspections

• ~500 approved collectors

• ~50 approved recyclers / dual entities

• CIWMB pays recyclers; recyclers pay collectors

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CEW Payment System Volumes

• Activities began January 1, 2005

•2005 volumes:–$31M (65M lbs) in claims received

• 2006 volumes thus far:–$44M (91M lbs) in claims received

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Program Growth Since Inception

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Looking Ahead

• Net Cost Reports due March 1, 2007–Web-based training slated for January

• DTSC determines what is a CED/CEW–NEW starting July 2007 – portable DVD players

•Statewide promotion www.eRecycle.org –Objective: awareness, convenience

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Looking Ahead

• Deploy Audit Functions–Assistance with net cost reports–Standardize data tracking–Compliance, enforcement & fraud minimization

• Next Rulemaking...? –You can always build a better mousetrap

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So, What’s New in the Final Regs?

• New & revised definitions• Limitations on CEWs from illegal disposal• Limitations on recovery payments• Future Net Cost Report flexibility• Certification of regulatory awareness• Maintenance of in-state location• Expanded prohibitions• Ability to suspend participants

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So, What’s New in the Final Regs?

• Enhanced collection documentation • Inventory tracking requirements• Weighmaster requirement for recyclers• More detailed transfer records• Glass shipment from all claimed CEWs• Refined claim reporting • Claim review standards

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So, What’s New in the Final Regs?

• Let’s take a closer look…– Please refer to the regs themselves:– www.ciwmb.ca.gov/rulemaking/EWaste/

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Revised Forms and Documents

• Available on websitewww.ciwmb.ca.gov/Electronics/Act2003/Recovery/Application/

• Application (186)

• Proof of Designation

• Collection Logs (198, 198SA)

• Transfer Receipts, Summary (197, 197S)

• Claim Forms and Worksheets (196, 196A, 196B)

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Chronic Challenges

Or, how we see the world…

• Collection Logs–Incomplete documentation–Superfluous documentation–Secondary logs from unapproved handlers–Illegibility (unreadable)–Alterations

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Chronic Challenges

•Transfer Documentation–Incomplete transfer packages (missing logs)–Missing signatures–Missing certified weights (tickets)–Inefficient use of transfer receipts–Illogical dates

•Transfers before collection

•Transfers after cancellation

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Chronic Challenges

•Cancellation documentation–Dubious links between received material and cancellation activities–Mass balance discrepancies

•New regs require better inventory tracking

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Chronic Challenges

•Claim Preparation and Submittals–Premature claim reports

•No glass shipments

•Receipts not yet secured from shipping/destinations

–Incomplete claim packages•Missing Collection Logs, Transfers Docs, etc

•Clarity of residuals disposition – BOLs, etc

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Chronic Challenges

•Claim Packages–Disorganized–Deficient–Superfluous

…a claimant is signing, attesting to completeness and accuracy; it should be!

•If you have questions, please ask!

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What Can We Do To Help You?

•Information?

•Guidance?

•Tools?