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The ERCC has sent notices to the below list of manufacturers that were non-compliant or in violation of two or more state electronics recycling laws. There are many additional companies that are non-compliant in one state, and can be found on the individual state program pages.

The notice included the following text:

Re: IMMEDIATE ACTION REQUIRED: Non-Compliance with State Electronics Recycling Laws

Dear Manufacturer:

The Electronics Recycling Coordination Clearinghouse (“ERCC”) is writing to inform you that [company] is noted on two or more state lists as non-compliant or unregistered as of [DATE] with state electronics recycling laws. State program managers from the respective states have determined that your company is a responsible manufacturer, i.e. meets the definition of being a manufacturer under their law, and that your company manufactures, owns brands, or otherwise meets the definition for having electronic devices covered by the law. The following states have indicated these brands are in non-compliance (as of January 2017):

Updated list of manufacturers non-compliant in 2 or more states

AG Neovo Technology Corp CT, IN, MD, MI, MO, ME, MN, OR, PA WA, WI
Archos Inc. CT, ME, MI, MO, WI, WA, WV
Astak WA, WI
Avatar Tech WA, WI
Broksonic c/o Hatzlachh Supply Inc. CT, IN, MD, MI, ME, OR, WA
Coby USA/Coby Electronics Corp
ME, MI, NC, VT, WI, WV
Double Power Technology CT, MD, IL, MO, NC, OR, WI
HKC Digital IL, ME, WA, WI
Hyundai IT America Corp MD, ME,WI
iDeaUSA ME, WA, WI
Kith Consumer Products NC, WA
Microsoft Corporation
 MI, NC
Miracle Business
ME, WI
Mustek, INC ME, NC, WA
Naxa Electronics
ME, MD
Sungale (R-Beam Electronics)
ME, MN, NC
 Supersonic
MD, ME, NC, WI, VT
Upstar USA
MD, ME, VT
Velocity Micro/ Velocity Holdings
IN, ME, MI, MN, MO, NC, OR, WV


Under these state laws, non-registered brands or non-compliant manufacturers cannot sell their covered devices in the state, either directly or through physical or online retailers, and responsible manufacturers may face penalties for not registering and/or meeting recycling program obligations. Currently, your products may not be sold by any means in the states in which your brand/s is listed as non-compliant or not registered. In addition to registering your brand, the state law may require you to establish or join a recycling program and meet specific requirements.

The ERCC urges you to contact the relevant state program manager immediately and take the steps necessary to comply with the state laws. The information below provides links to web pages for each state law, and a complete list of state agency contacts.

 

ERCC maintains an updated chart of non-compliant/unregistered manufacturers on its website (www.ecycleclearinghouse.org). ERCC will remove your company from this list when it comes into compliance in all states. In addition, the ERCC is conducting outreach to major retailers to inform them of the brands that appear on the state non-compliance lists that may not be sold in their stores.

 

Should you have any questions or need additional help, please contact Jason Linnell, at (304) 699-1008 or by email to jlinnell@electronicsrecycling.org, or contact any of the state program managers where your company is listed directly with the enclosed contact information.

 

Sincerely,

Jason Linnell

NCER Executive Director

 

Attachments: State Agency Contacts

List of State Pages

ERCC Overview