By requiring a solid waste processing license for electronics recyclers, the revised rules will allow the department to provide a list of licensed recyclers to individuals, businesses, institutions and organizations wishing to recycle electronics.
The rule would not directly affect electronics consumers (individuals, and K-12 public schools and Parental Choice Program schools) that are already responsible for recycling their used electronics under E-Cycle Wisconsin. It also would not directly affect businesses that must recycle, reuse or manage their electronics as hazardous waste, but are not covered by E-Cycle Wisconsin.
7. Summary and preliminary comparison with any existing or proposed federal regulation that is intended to address the activities to be regulated by the proposed rule:
There is no existing or proposed federal regulation for electronics recycling.
8. Anticipated economic impact of implementing the rule (note if the rule is likely to have an economic impact on small businesses):
We anticipate the total economic cost of this proposed rule to be minimal (less than $50,000).
Much of the proposed rule would codify current practices. Depending on the exact nature of changes made to operational standards for registered recyclers under s. 287.17(8), Wis. Stats., these facilities might incur small, one-time costs associated with staff time to understand and implement the changes. The department will conduct outreach to affected facilities through workshops, webinars and/or one-on-one technical assistance. The rule would reduce annual registration fees paid to the department by some electronics manufacturers. This loss of revenue can be absorbed by the department without changes to program service.
Requiring a solid waste processing license for electronics dismantling and processing activities would have a one-time cost for some facilities, including small businesses. Electronics dismantling/processing locations not registered with E-Cycle Wisconsin would incur a one-time $550 Initial Site Inspection fee (paid to the department) and one-time costs to set aside money (owner financial assurance funds) for closure and cleanup costs and, in some cases, to hire a consultant to help prepare these documents. Some facilities registered as collectors, but not recyclers, under E-Cycle Wisconsin could incur similar one-time costs. Recyclers registered with E-Cycle Wisconsin would see little, if any, additional costs, as they would already meet most license requirements. A small amount of department staff time would be required for the licensing process.
Some of these costs could be offset by the benefit of being on a department list of licensed facilities, which could make it easier for some to attract customers. Requiring solid waste processing licenses for facilities dismantling or processing electronics could also reduce or avoid costs to landlords and governments caused by the cleanup of illegally stored or dumped mismanaged electronics, which can run into the tens or hundreds of thousands of dollars.
9. Anticipated number, month and locations of public hearings:
The department anticipates holding one public hearing in the month of April 2021. The hearing city will be: Madison with webcast.
The department will hold the hearing in this location to allow stakeholders to attend in person but also accommodate stakeholders located throughout the state and outside of Wisconsin via online streaming.
Contact Person: Sarah Murray, 608-264-6001
