March 23, 2009

The National Center for Electronics Recycling (NCER) has updated its study for the National Electronics Recycling Infrastructure Clearinghouse (NERIC) on projected costs to the electronics manufacturing industry to comply with state and local electronics recycling mandates in 2010.  This updated study identified and estimated all manufacturer compliance costs resulting from e-waste legislation adopted in the following 19 jurisdictions: California, Maine, Maryland, Washington, Minnesota, Oregon, Connecticut, North Carolina, Texas, New Jersey, Virginia, West Virginia, Oklahoma, Rhode Island, Missouri, Hawaii, Illinois, Michigan and New York City.  The NCER notes that several other states are considering enactment of e-waste legislation but the study only covers legislation enacted before March 9, 2009. 

The NCER estimates that the electronics manufacturing industry will expend approximately $90 million in 2010 to comply with electronics recycling mandates across 19 US jurisdictions with enacted e-waste mandates, an increase of $19 million and 5 jurisdictions from the previous study completed in May 2008.  These costs break down as follows:

• $71 million for collection, transportation and recycling of covered electronic products
• $14 million for internal compliance costs such as tracking, reporting and registration
• $4.5 million for government-incurred administrative costs

This study builds upon the 2006 Patchwork Study, also conducted by the NCER with NERIC support. The Patchwork Study identified internal costs resulting from the 4 states (California, Maine, Maryland and Washington) having enacted mandatory e-waste legislation and estimated the fraction of those costs that would not be incurred under a national approach (i.e., “dead weight” or “patchwork” costs). Total internal manufacturer compliance costs were estimated in the Patchwork Study at $4.63 million in 2006.  Since the publication of the Patchwork Study 3 years ago, 15 additional jurisdictions have enacted legislation with varying requirements, bringing the e-waste patchwork to date to 18 states and 1 city. This covers more than one-half of the total US population. Internal compliance costs for 2010 were scaled up 3X to account for the 10 new jurisdictional mandates enacted since 2006 to arrive at the $14 million estimate cited above.  Highlights of other NCER-estimated costs are as follows:

• For the Maine program, consolidation, transportation and shipping costs are estimated at an average of $0.30/lb. with an assumed 10% increased in collected amounts in 2010 over 2X actual amounts collected during the first half of 2008.  Given program similarities with Maine, costs in Connecticut are estimated by adjusting projected 2010 Maine costs to Connecticut's population plust an additional 10% to account for inclusion of printers that are not included in Maine’s program (cost of desktop management in CT balances out to zero).
• Rhode Island assumes 2.5 lbs./capita is collected/recycled in 2010 at an average cost of $0.20/lb. plus the $5,000 registration fee paid by 100 manufacturers.  
• Costs for Maryland are estimated using actual registration funds received in FY 2008.  
• Washington costs are estimated from per pound budgeted amounts from the Washington Materials Management and Financing Authority for operational costs for 2009 times 12X the actual collected CEP amounts in January, 2009.  Administrative costs incurred by the Department of Ecology and paid for by manufacturers are also included in the 2010 Washington estimate.  
• Oregon operating costs are estimated assuming throughput for 2010 at 12X the actual CED collection amount reported for January, 2009, and costs are assumed at $0.28/lb. covering collection, transportation, recycling and program administration costs.  Costs for New Jersey are derived from the Oregon estimate scaled up to New Jersey's population, and with the state registration fees estimated accordingly.
• North Carolina assumes 2.5 lbs./capita during this first program year (2010) at $0.20/lb. cost to the manufacturers, plus 50 computer manufacturers estimated to pay initial $10,000 registration fee and 25 TV manufacturers to pay initial $2,500 registration fee.  
• Minnesota costs assume 30 million lbs. of covered products are collected and recycled in 2010 at a cost of $0.20/lb.  
• For Texas the NCER assumed that 75 manufacturers will spend an average of $5,000 each to comply with that state’s requirements.  Given the program similarities to Texas, costs for Virginia, Oklahoma, Missouri, West Virginia and Michigan (IT portion only) are estimated as the same as in Texas.  Hawaii is assumed 2X Texas (for 2010 before TVs are included) due to higher logistics costs. Registration fees were also estimated for Oklahoma, Missouri, Hawaii and Michigan.  
• New York City costs assume collection of 2.5 lbs./capita at an average collection, transportation and recycling cost of $0.50/lb. in 2010, plus a $1,500 registration fee paid by 100 unique manufacturers.  
• Illinois assumes 2.5 lbs/capita of CED throughput at $0.30/lb. total cost, plus 100 unique manufacturs paying the $2,000/year registration fee.
• Michigan television manufacturer costs assume 1 lb./capita of TV throughput in 2010 (starting from April 1) at a total cost of $0.25/lb., plus a $3,000 registration fee paid by 100 unique manufacturers.  The IT cost of this program are assumed to be the same as Texas as noted above.

For more information or to provide feedback on this study please email us at info@ecyclingresource.org.