The Association of Electrical and

Medical Imaging Equipment Manufacturers

2014 Northwest Hazardous

Materials Conference

WASHINGTON H.B. 2246:

MANUFACTURERS’ PERSPECTIVE

MARK A. KOHORST

NATIONAL ELECTRICAL MANUFACTURERS ASSOCIATION

Troutdale, OR

June 2014

The Association of Electrical and

Medical Imaging Equipment Manufacturers

What is NEMA? NEMA and Lamp Recycling Lamp Recycling Legislation The Financing Question HB 2246 Maine, Vermont Where to from here?

Topics

The Association of Electrical and

Medical Imaging Equipment Manufacturers

NEMA Vital Statistics Created 1926, Largest US Trade Association of

Electro-Industry Manufacturers Membership: Appr 450 US Manufacturers Products used in Generation, Transmission,

Distribution, and End-Use of Electricity 8 Industry Divisions, ~52 Product Sections Dry Batteries to Motors to Traffic Signaling Equip to

MRIs, etc. Principally a Standards Organization More than 500 Industry Standards; Internally and With

ANSI and IEC Also Advocacy, Data Collection & Analysis, International

Collaboration, Safety Promotion

The Association of Electrical and

Medical Imaging Equipment Manufacturers

NEMA Lamp Manufacturing Section

Currently 25 companies Large, household name producers (GE, Philips, OSRAM, etc.) Smaller, specialty lamp manufacturers

About $3 billion in lamp shipments covering commercial,

industrial, institutional, residential, automotive, and specialty lighting markets

The Association of Electrical and

Medical Imaging Equipment Manufacturers

NEMA and Lamp Recycling

Manufacturers label every package sold in North America

Created www.lamprecycle.org – one stop center for

recycling information More than 200,000 page views per year Separate pages for state programs

Ongoing education through distribution chain, outreach Encourages enforcement of local, federal, state laws

NEMA Actively Promotes Recycling Hg-added Lamps

The Association of Electrical and

Medical Imaging Equipment Manufacturers

Legislation

Focus on residential market, not commercial/industrial All manufacturers selling in the state must participate “Level playing field”

Must include a “Sunset” Provision Encourages state enforcement on non-compliant companies Provides adequate state antitrust protection For WA law, “state action doctrine” is crucial

Ensures sustainable financing for life of program E.g., “Environmental Handling Charge”

Key Elements of a State Lamp Recycling Law

The Association of Electrical and

Medical Imaging Equipment Manufacturers

Financing MechanismKey Considerations

Spent Hg-added lamps have virtually no residual value Substantial difference from lead-acid batteries, certain

electronics Cost of recycling CFLs, LFs is very high relative to retail

price of new products Package of 8 leading brand CFLs (13w), $10.35 plus shpg on

Amazon EcoSmart 4-pack CFLS (13w), $3.97 at Home Depot Loaded cost of recycling CFLs can approach 50 cents per unit

CFLs have long been “commodity products” – so pricing

flexibility is extremely limited Manufacturers do not “shift” costs between product lines Cost internalization not a viable option for these products

The Association of Electrical and

Medical Imaging Equipment Manufacturers

Environmental Handling Charge

Various precedents exist (e.g., paint, mattresses, tires) Applies to all manufacturers selling in the state, ensuring

level playing field Helps to educate consumers on importance of recycling Uses third party “stewardship organization” for collection,

disbursement Subject to state review and approval If kept low enough, not expected to deter sales Temporary program . . . . Won’t last forever

Not Ideal, but Necessary for a Statewide Program

The Association of Electrical and

Medical Imaging Equipment Manufacturers

H.B. 2246

Expected to provide funds for comprehensive program Provides flexibility concerning remittance of fees Added to price when lamp is sold by producer – producer remits

fee to SO OR

Retailer collects fee from consumers – retailer remits fee to SO Consistent with ‘over the border’ program in British Columbia Enacts a statewide disposal ban for mercury-added lights

Not Ideal, but Good Solution for WA State

The Association of Electrical and

Medical Imaging Equipment Manufacturers

Other State LawsMaine Vermont

Enacted June 2009 Enacted May 2011 Covers “mercury-added

lamps sold or distributed for household use”

A person(?) may recycle any number of CFLs and up to 10 non-CFLs

No antitrust immunity Includes antitrust immunity

Sales ban for non-compliance No sustainable funding mechanism

The Association of Electrical and

Medical Imaging Equipment Manufacturers

Where to from here? FIRST – Get program started successfully in WA SECOND – Observe, evaluate, improve as needed BEYOND WASHINGTON . . . . Each state is different Politics unpredictable Cost challenges remain difficult

MEANWHILE . . . . . Mercury content still falling Transition to next generation lighting continues

75 years of excellence

Thanks for your attention!

Mark A. Kohorst

703-841-3249

703-841-3349 (fax)

Mar_kohorst@nema.org

NEMA

Suite 900

1300 North 17th

Street

Rosslyn, Va. 22209

www.nema.org