ERCC Notices to Non-Compliant Manufacturers
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
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 March 2017):
Updated list of manufacturers non-compliant in 2 or more states
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
firstname.lastname@example.org, or contact any of the state program managers
where your company is listed directly with the enclosed contact information.
NCER Executive Director
Attachments: State Agency Contacts
List of State Pages