Electronic Product Management - Implementing the Electronic Waste Recycling Act of 2003

Frequently Asked Questions Regarding
Collector and Recycler Net Cost Reporting

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Question : Who is required to submit a net cost report and what is the deadline?

Answer : All approved collectors and approved recyclers must submit an annual net cost report to the CIWMB. The next report is due on or before March 1, 2007.

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Question : What must the net cost report include?

Answer : Per 14 CCR 18660.10(d), the annual net cost report must include (among other requirements):

• An annualized summary of the net revenues, costs and net costs (costs minus revenues) of covered electronic waste (CEW) recovery and/or CEW recycling;
• Total annualized revenues excluding recovery and recycling payments received from the CIWMB, plus a list of the types of revenues included;
• Total annualized costs, plus a list of the types of costs included; and
• The net cost per pound of CEW recovery and the net cost per pound of CEW recycling.

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Question : What documentation is required to be maintained?

Answer : The brief net cost reports submitted to the CIWMB must be supported by detailed documentation maintained at the approved collector or recycler’s place of business.

Approved collectors must maintain records on the costs, revenues and net costs associated with the collection, transportation and disposition of all CEWs handled (14 CCR 18660.20(j)(3)).

Approved recyclers must maintain records on the net costs associated with the disposition of all CEWs handled, the net costs of accepting the transfer of CEWs, the net costs of each cancellation method used, and any additional administrative costs of providing recovery payments to approved collectors (14 CCR 18660.21(I)(5)).

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Question : Do net cost reports need to cover recovery and recycling separately?

Answer : Yes. Approved collectors must maintain records and report net costs associated with CEW recovery. Approved recyclers must maintain records and report net costs associated with CEW recycling. Approved recyclers who are also approved collectors must maintain records and report net costs separately for CEW recovery and for CEW recycling activities.

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Question : Why is the CIWMB requiring this information, and how will it be used?

Answer : The CIWMB will analyze and compile information from the net cost reports in order to evaluate the potential need to adjust future future payment rates for CEW recovery and recycling and/or Electronic Waste Recycling Fees collected by retailers.

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Question : Does the CIWMB intend to review or audit net cost documentation records?

Answer : Yes. As part of the CIWMB’s analysis of costs, the CIWMB will visit a sample of approved collectors and recyclers to review and/or audit their net cost documentation.

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Question : How can the specific costs of recovering or recycling CEWs be separated from the costs of other, unrelated business activities?

Answer : The CIWMB recognizes that allocating some business costs to CEW recovery or recycling will be very challenging in some cases. Reasons for this include (but are not limited to) the fact that approved collectors and recyclers:

• May handle other types of waste materials in addition to CEWs;
• May be engaged in additional business activities unrelated to collection and recycling;
• May find it difficult to estimate the appropriate share of indirect costs such as utilities, building costs and administrative costs to allocate to CEW collection or recycling;
• May find it difficult to estimate the appropriate share of some staff members’ time to allocate to CEW collection or recycling.

The CIWMB anticipates allowing a wide range of methods to be used to address these and other cost calculation challenges, as long as they represent a good faith effort to accurately document the actual costs of collecting and recycling CEWs as specified in regulations.

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Question : How can reports be submitted?

Answer : Complete reports must include all of the information listed on Form 220, CEW Net Cost Report and the Net Cost Estimation Worksheets (Form 220a for collectors and dual entities and Form 220b for recyclers and dual entities). This Guide to Net Cost Reporting and the forms are available on the CIWMB’s website at:

http://www.ciwmb.ca.gov/electronics/Act2003/Recovery/NetCost/Default.htm

The report must be signed by the person your organization authorized on your application to the CIWMB to become an approved collector or recycler, and be delivered in hard copy to:

California Integrated Waste Management Board
Attention: Electronic Waste Recycling Program, MS #13A
1001 I Street, P.O. Box 4025
Sacramento, CA 95812-4025

A return receipt is suggested to verify deliveries.

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Question : How can a participant get more information and/or help?

Answer : General information on the California Electronics Recycling Act of 2003 is available through the CIWMB’s website at: http://www.ciwmb.ca.gov/Electronics/Act2003/. The CIWMB will maintain an up-to-date list of Frequently Asked Questions and Answers related to the CEW Net Cost Report on this website.

Regulations covering the net cost reporting requirement (14 CCR 18660.10) and the CIWMB’s authority to conduct audits (14 CCR 18660.9) are available online at:
http://www.ciwmb.ca.gov/Electronics/Act2003/Regulations/

For further information and assistance regarding the net cost report contact Matt McCarron of the CIWMB’s electronic waste recycling program staff by phone (916-341-6456) or by e-mail (ewaste@calepa.ca.gov).

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As the Integrated Waste Management Board (CIWMB), in consultation with the Department of Toxic Substances Control (DTSC), works to implement this important legislation, more information will be available through this website. Note that any guidance provided by the CIWMB should not substitute for careful reading of the original statute or subsequent regulations. Interested parties are encouraged to check back often, or subscribe to an e-mail newsletter to be kept apprised of developments and events.

Net Cost Reporting Page | Collector and Recycler Information Page

Last updated: June 13, 2008