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RE: US manufacturers take back requirements



As far as I know, the US has few if any legal requirements for manufacturer takeback.  Most efforts (e.g., electronics, printer cartridges, remanufactured automotive parts) are voluntary.


There are several exceptions:

  • Federal CFC recovery and recycling requirements (I don’t know if the manufacturer is responsible)
  • Beverage container deposit-refund/redemption systems in a number of states.
  • Removal of mercury switches from junked vehicles—Maine places certain responsibilities on the auto manufacturers, including payment of a bounty on each switch recovered (see http://janus.state.me.us/legis/statutes/38/title38sec1665-A.html ).  Arkansas and New Jersey passed similar laws and others states are considering this too.  Since Hg switches are being phased out of new vehicles and mercury content of other products is being decreased or eliminated (the P2 approach), the recovered Hg may not necessarily be recycled.


I hope this is helpful.  Perhaps other P2Techies have other examples.





Rodney Sobin
Office of Small Business Assistance
Virginia Department of Environmental Quality
Postal: P.O. Box 10009, Richmond, VA 23240-0009
Street:  629 E. Main St., Richmond, VA 23219-2429
Tel. 804-698-4382       fax 804-698-4264 

Environmental Assistance for Small Businesses http://www.deq.virginia.gov/osba/smallbiz.html

Virginia Comprehensive Assistance Network http://www.deq.state.va.us/osba/vacan/

DEQ Innovative Technology http://www.deq.virginia.gov/innovtech

DEQ Distributed Energy Resources http://www.deq.virginia.gov/innovtech/der1.html
Virginia Environmental Services Network http://www.vesn.biz

-----Original Message-----
owner-p2tech@great-lakes.net [mailto:owner-p2tech@great-lakes.net] On Behalf Of Judy Wlodarczyk
Sent: Friday, January 06, 2006 10:50 AM
Subject: US manufacturers take back requirements


I apologize if you have received this more than one time, but I am having computer problems.


I am working with a client that has to comply with the WEEE (Waste Electronic and Electrical Equipment) EU requirement.  This directive requires manufacturers of these types of equipment to have take-back arrangements for recycling at the end of life of the product.  We know that they are various requirements in the US for these products to be recycled or disposed of properly at the end of life by the end-user. 


Question:  Are there any states that currently have regulations on the books that require take-back by the manufacturer instead of the end user?   Appreciate any insight you can provide.


Judy Wlodarczyk

1090 Elm Street Suite 202
Rocky Hill, CT  06067

Email:  jwlodarc@connstep.org
Office: 860-644-9718

Cell:    860-539-4926

Fax:    860-529-5001

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