Export Requirements of EPA s Cathode Ray Tube Rule. Minnesota E-Waste Recyclers Workshop December 17, 2008

Transcription

1 Export Requirements of EPA s Cathode Ray Tube Rule Minnesota E-Waste Recyclers Workshop December 17,

2 Introduction Why are electronics exported?» No smelters/refiners in the U.S. can convert copper and precious metal bearing electronics materials into metals that are pure enough for use» Nearly all markets for plastics from electronics are overseas, primarily in Asia American RetroWorks 2

3 Introduction Why are electronics exported?» There are no longer any cathode ray tube (CRT) glass furnaces in the Western Hemisphere for use of recycled CRT glass» The major markets for reuse (of both whole equipment and components) are outside the U.S., mostly in developing countries. American RetroWorks 3

4 Introduction There are problems with illegitimate recycling» China and Africa» Illegal dumping The CRT Rule requires notification similar to hazardous waste exports 4

5 Final rule issued, July 2006» The complete rule is listed at 40 CFR Part Intended to streamline requirements and encourage recycling The rule is a conditional exclusion» If rule is complied with, CRTs can be handled as non-waste Non-compliance may constitute a violation of Resource Conservation and Recovery Act (RCRA) hazardous waste requirements The rule makes no changes to how RCRA applies to disposal of CRTs 5

6 EFFECTIVE DATES Domestic requirements go into effect if adopted by the states» Region 5 states that have adopted the rule Illinois (9/08) Indiana (9/07) Michigan» Region 5 states have not yet adopted the rule Ohio Michigan Minnesota» State contacts on back of handout Export requirements went into effect January 29,

7 Definitions Cathode ray tube or CRT: means a vacuum tube, composed primarily of glass, which is the visual or video display component of an electronic device. A used, intact CRT: means a CRT whose vacuum has not been released. A used, broken CRT: means glass removed from its housing or casing whose vacuum has been released. CRT collector: means a person who receives used, intact CRTs for recycling, repair, resale, or donation. 7

8 Definitions CRT processing means conducting all of the following activities:» Receiving broken or intact CRTs; and» Intentionally breaking intact CRTs or further breaking or separating broken CRTs; and» Sorting or otherwise managing glass removed from CRT monitors. Recycling: consists of disassembly to recover valuable materials from the CRTs, such as lead or glass Reuse: The CRT remains intact, and is able to be used as a display device. The CRT, or the device that it is in, may or may not need repair. 8

9 Processed Glass Processed glass:»not regulated if destined for CRT glass manufacturer or lead smelter»if destined for other types of recycling, may be excluded on a case-by-case basis»no speculative accumulation»no notification is needed for the export of processed glass 9

10 EXPORT REQUIREMENTS Two types of notifications 1. Export for recycling International notification & consent Notify EPA Administrator 2. Export for reuse/refurbishment One-time notification to EPA only Notify EPA Regional Administrator 10

11 EXPORT FOR RECYCLING CRTs & unprocessed CRT glass» Exporter must send notification to EPA Administrator 60 days prior to export» Notification should include: Exporter and receiving recycler names and addresses Exporter EPA ID number (if applicable) Amount (pounds) of material, and rate of export, during the next 12 months Notification may cover export over a 12 month or lesser period Points of entry and departure of all countries the CRT will pass through Shipping means and container type How the CRTs will be recycled The name of any transit countries through which the CRTs will be sent and a description of the approximate length of time the CRTs will remain in such country and the nature of their handling while there.» Observe same packaging & labeling requirements as if domestic shipment» No speculative accumulation 11

12 EXPORT FOR RECYCLING» Once EPA receives the notice: EPA forwards the notification to transit & importing countries EPA notifies exporter of consent or denial by countries Export cannot proceed without consent of receiving countries» Recycling notifications go to: Office of Enforcement and Compliance Assurance See 40 CFR for mailing addresses» Retain copies of notifications and Acknowledgement of Consent to Export CRTs for three years after the receipt of the Acknowledgement. 12

13 EXPORT FOR REUSE/REFURBISHMENT Intact CRTs for Reuse or Refurbishment» Exporter must send a one-time notification to EPA Regional Administrator Notification must contain: Exporter s contact information Statement of intent to export» Exporter must keep business records for 3 years demonstrating export for legitimate reuse/refurbishment» Shipment can proceed without acknowledgement of EPA 13

14 EXPORT FOR REUSE/REFURBISHMENT Notification mailing address for reuse shipments exported from EPA Region 5 states Regional Administrator US EPA Region 5 Attn: William Damico Land and Chemicals Division 77 West Jackson Boulevard Chicago, IL

15 FAQ/EXPORTING LISTS FAQ s and a list of companies approved to export for recycling is at: There are 17 companies listed currently (12/08)» The list is expected to be updated quarterly List of companies approved to export for reuse are expected to be posted in January, 2009» Will be at the same web address» Will include a list of Regional Office contacts for filing export for reuse notifications Both lists contain company name, address, and for recycling, end date of approval for export for recycling 15

16 ENFORCEMENT Incentive for downstream due diligence:» All persons* in management chain can be held liable for downstream violation * Those involved from point at which decision was made to recycle 16

17 CRT Rule Outreach Region 5 mailing» Mailing to recyclers Informational letter Notice one pager June 28, 2006 Federal Register Notice 17

18 EPA contacts - Office of Solid Waste:» Marilyn Goode goode.marilyn@epa.gov 18

19 EPA Region 5 Electronic Waste Contact: Chris Newman EPA Region newman.christopherm@epa.gov 19