Manufacturer Obligations Under New York's E-Waste Law

November 15, 2017 7:30 am — 10:00 am
New York, NY (and webinar)

This event is coordinated with the New York Department of Environmental Conservation.

New York’s Electronic Equipment Recycling and Reuse Act requires manufacturers to provide free and convenient recycling of electronic waste, or e-waste—including computers, computer peripherals, televisions, small scale servers, and small electronic equipment—to most consumers in the state.

The Environmental Law Institute, New York’s Department of Environmental Conservation, and other experts in New York's electronics recycling law presented this free, comprehensive, two-hour workshop and webinar to help manufacturers know their obligations under the Act. Participants received a solid grounding in the law’s background and scope, including practical guidelines for navigating New York’s online registration and reporting system.  

Key elements included:

  • Understanding the amount of e-waste designated as each manufacturer’s responsibility to collect every year, along with surcharges imposed for falling short of meeting the goal, procedures for requesting a waiver and using credits earned by exceeding the goal
  • Maintaining a convenient e-waste acceptance program, including permitted methods for collecting e-waste and best practices, opportunities to partner with other manufacturers in a collective and obligations to accept other manufacturers’ brands
  • Due diligence in selecting a qualified recycler
  • Public education program criteria, labeling and recordkeeping requirements, and responsibilities to retailers
  • Enforcement and penalties
  • Accessing additional resources and support
  • New developments in the statewide program, including updates on new regulations, and how manufacturers can stay apprised and be involved in the process
  • The responsible recycling standard, the current enforcement landscape, and highlights from cases through the United States

Cynthia Harris, Staff Attorney, ELI
Glenn Hewitt, Environmental Program Specialist, NYS Dept. of Environmental Conservation Division of Materials Management
Brett Korte, Staff Attorney and Director, Associates Programs, ELI
Maggie Macdonald, Associate, Sive, Paget & Riesel P.C.
John Pendergrass, Vice President, Programs and Publications, ELI
Peter van Erp, Environmental Program Specialist, NYS Dept. of Environmental Conservation Division of Materials Management

PowerPoint presentation

Additional Resources:
Covered Electronic Equipment Manufacturer Requirements (NYS DEC)
Covered Electronic Equipment
New York State Municipalities with a Population of 10,000+
Common Problems with Manufacturer/Collective E-waste Acceptance Programs
Important Statutory Sections
NYS Certification Fee Form
NYS Manufacturer Annual Report Certification Form
NYS E-waste Program Annual Reporting Fee Invoice