Wednesday, January 20, 2016

Electronics Recycling Assn Of PA Calls For Action On PA’s E-Waste Law

The Electronics Recycling Association of PA Tuesday sent a letter to local government, environmental, waste industry and business groups providing an update on the status of electronics waste recycling in Pennsylvania under the state’s Covered Device Recycling Act of 2010.
The Association, which represents the major electronics waste recycling companies in the Commonwealth, reports the state’s e-waste recycling effort is shrinking dramatically and major changes need to be made to correct the problems with the Act.
They called on these groups to make Senate and House members aware of the problems and urged them to take action to change the law to get the program back on track. The text of the letter follows—
The Electronics Recycling Association of Pennsylvania (ERAP) is leading pursuit of amendment to Act 108, the Covered Device Recycling Act. ERAP is engaged in many stakeholder discussions and asks for your support, please read forward.
In November 2010, Act 108, the Covered Device Recycling Act (CDRA), was signed into law. CDRA requires electronics manufacturers to collect their share of electronics sold in Pennsylvania.
These electronics include desktop computers, laptop computers, computer monitors, computer peripherals (such as keyboards, mice, printers), and televisions (including flat panels). The CDRA requires recycling for 85 percent of Pennsylvania citizenry.
In January 2013, under CDRA, a disposal ban went into effect for electronics and residents could no longer dispose of these electronics. The program was phased in over three (3) years with manufacturers expected to pay for the collection, transportation, and processing of electronics.
Since the Covered Device Recycling Act began, there are negative impacts that occurred – here are a few.
1. Pennsylvania E-Scrap Recycling Is Shrinking, Not Growing: The total quantity of collection sites for 2015 was verified and of the total sites, approximately 150 sites accepted all CDRA listed electronics. Compared to the 85 percent coverage goal under the Act, these 150 sites only account for 63.5 percent of the Pennsylvania population. Without adequate electronic manufacturer financial support for coverage of collection, transportation, and recycling, recycling coverage will decrease, as we are observing amongst 2016 sites.
2. Additional Recycling Sites Are Closing In 2016: In 2016, and largely due to inadequate electronics manufacturer support as required in the CDRA, additional sites are closing or opting out of service to Pennsylvania citizens. The result is that:
-- Over 20 regional recycling sites are closing in western Pennsylvania;
-- 2 Counties in southcentral Pennsylvania have lost service;
-- Underserved counties include the five (5) county area surrounding Philadelphia;
-- Collection locations are absent from the majority of the Route 79 corridor from Butler County to Erie County, and many of the rural counties in the Commonwealth;
-- At last count, these effects impact but are not limited to 18 Counties of which DEP notified electronics manufacturers- Armstrong, Bucks, Bradford, Cameron, Carbon, Chester, Clinton, Cumberland, Delaware, Huntingdon, Montgomery, Montour, Perry, Philadelphia, Pike, Sullivan, Susquehanna, and Wyoming.
When paired with the electronics disposal ban that is part of CDRA, this has lead to heightened illegal dumping of electronics in state forests, abandoned properties, and off roadways, including computer monitors and old TVs, which are known to contain heavy metals, especially leaded glass.
3. Amount Paid By Manufacturers Does Not Cover Costs: Recyclers provide the collection, transportation, and processing on behalf of the manufacturers where the unit rate paid per pound for electronics from the manufacturer often is depressed. This is a flawed model, given dynamic fluctuations in scrap value.
The electronics manufacturer rate under the law does not adjust to changes in scrap value leaving not only recyclers, but municipally supported collection programs with inadequately mandated risk and unfunded liability.
4. Recyclers Have Reduced Participation: Since 2011 several Pennsylvania permitted recyclers have participated in the CDRA program. Two companies have closed their businesses. Eight (8) companies continue to reduce participation largely due to current CDRA structure.
The recyclers that remain engaged are faced with the risk and liability for the proper handling of electronics while not receiving the legislated electronics manufacturer payment that covers 100 percent of the cost of recycling.
The burden of this structure does not provide adequately for Pennsylvania nonprofit, for-profit, and municipal organizations that function as collectors. In most cases, the responsibility falls on the municipality, township, county, or authority.
5. Recycling Weight Targets Are 2 Years Old: CDRA requires electronics manufacturers to recycle in a given year the total weight of products they sold two (2) years ago. For 2016, an electronics manufacturer is required to recycle the weight of material they sold in Pennsylvania in 2014. Many electronics last longer than 2 years.
Picture this – How do you account for the 2014 reduced weight of a tablet, pad, or flat television – products of 2 years ago – when many of the electronics that we need to recycle are heavy, backbreaking console televisions of decades ago?
This arbitrarily reduces electronics manufacturer’s recycling because sales weight is going down. There is no relationship between dated electronics that need to be recycled and 2-year old sales.
This has caused Marketplace Imbalance – Sadly, it has become more effective for electronics scrap recyclers to decrease services to stabilize revenue rather than expand business to Pennsylvania citizens.
When your membership raises Covered Device Recycling Act (CDRA) concerns, we request that you swiftly mobilize and bring these issues to state representatives and senators….
Respectfully Submitted,
Electronic Recycling Association of Pennsylvania Board of Directors
Mark Kasper, Secretary, 484-951-6702,
A copy of the letter is available online.
For background on the recycling electronics law, visit DEP’s Electronics Recycling webpage.
Analysis: Electronics Recycling Effort Shrinking In PA, The Law Needs To Be Fixed

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