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RE: US manufacturer takeback requirements

Although it's a little different than the material takeback requirements
you're thinking of, a few regs require takeback of vapors from volatile

Stage I Vapor Recovery Systems require takeback of vapor from
underground gas tanks. Stage II systems require takeback from vehicle
gas tanks.  The requirements are imposed by State SIPs.  

About 14 states require dry cleaners to use vapor recovery when they
receive new shipments of perchloroethylene.  The burden falls on the 
solvent supplier. Many air permits also require vapor recovery when
loading tank trucks or railcars.  

Mike Heaney, P.E., Senior Engineer
Mike.Heaney@erg.com  ERG
(919)468-7870     fax (919)468-7801

>>> "Sobin,Rodney" <rsobin@deq.virginia.gov> 1/6/2006 12:47:10 PM >>>


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
the manufacturer is responsible)
*	Beverage container deposit-refund/redemption systems in a
of states.
*	Removal of mercury switches from junked vehicles-Maine places
certain responsibilities on the auto manufacturers, including payment
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


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

Virginia Comprehensive Assistance Network

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

DEQ Distributed Energy Resources
Virginia Environmental Services Network <http://www.vesn.biz/>

-----Original Message-----
From: owner-p2tech@great-lakes.net
On Behalf Of Judy Wlodarczyk
Sent: Friday, January 06, 2006 10:50 AM
To: p2tech@great-lakes.net 
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 
http://www.connstep.org <http://www.connstep.org/>  

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

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