Patchwork E-Waste Regulations Could Prove Costly
by an analogZONE special correspondent

A groundbreaking new study, A Study of the State-by-State E-Waste Patchwork, analyzes the costs of state-by-state legislation for electronics recycling programs compared to a nationwide e-waste scheme. Using estimates gathered from public and private sector participants in the existing mandatory e-waste recycling programs in California, Maine, Maryland, and Washington state, the study estimates the four-state dead weight costs that would not be incurred with a national program to be $25 M per year.

"This study proves that the current patchwork of different approaches to electronics recycling is indeed having an economic impact on all stakeholders," said Jason Linnell, executive director of the National Center for Electronics Recycling (NCER), which produced the study for the National Electronics Recycling Infrastructure Clearinghouse (NERIC). NERIC is administered by NCER and jointly funded by the Mid Atlantic Recycling Center for End-of-life Electronics project and the Consumer Electronics Association.

"At the present implementation rate of one new state-mandated program per year, recurring dead weight costs are expected to increase substantially during the coming years," according to NERIC. The study concludes that average one-time dead weight costs per state are $2.9 M and that recurring dead weight costs of a 20-state mega-patchwork of different regulations would reach $125 M per year.

Higher costs associated with state-by-state legislation include direct labor, general and administrative costs, and capital investments incurred by manufacturers, retailers, collectors, recyclers, and state governments. In addition to higher system costs, the study identified equity and fairness issues resulting from differing regulations in the four states. These could decrease compliance and increase enforcement costs.

Key cost drivers include:

• The need for individual states to exclude out-of-state electronics from entering their mandatory e-waste programs
• The need for each state to independently develop and enact legislation, establish its own administrative bureaucracy, and develop and implement its program
• Start-up costs and reporting requirements incurred by manufacturers and retailers

Although the study does not analyze benefits or drawbacks of individual e-waste programs or advocate any particular national or state plan, it makes these assumptions for the sake of comparing the costs of patchwork legislation to a hypothetical national e-waste program:

• E-scrap collection done locally with financing from a centralized collection incentive payment system or similar national-scale financing mechanism
• One coordinated administrative system to oversee financing, and coordinate reporting, enforcement, and other program requirements
• E-scrap treated as an interstate commodity and moved across state lines without consideration of the state of origin
• Enforcement by the federal government where necessary, with some oversight and/or delegated authority performed by state government where appropriate
• One set of national program requirements on financing, information reporting, and record keeping would be established at program initiation and would not change substantially over time.
  

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