DRAFT

EXPORT FOR REUSE REQUIREMENTS

For used electronics exported for repair, refurbishment, and re-manufacturing, the Vermont Facility must prove that all materials are legally managed in an environmentally sound manner, with individual record keeping of the number of units accepted, preparation criteria, etc.

For exports containing focus materials:

A)  Must notify EPA

B)  Must maintain records for 3 years.  These records must, at a minimum, include:

1. Import permit notification from reuse market

2. Purchase order describing materials accepted by the reuse market.  The Purchase Order must include:

                2.1 Limits on maximum quantity of product accepted by the reuse market, if any

                2.2  Instructions on materials not accepted by the reuse market

                2.3  Severability, enforcement, and arbitration terms

                2.4  Packaging and preparation criteria for shipment

3.  Fallout tracking and downstream audits

3.1   Payment for proper recycling of any excess, incidental breakage, or other fallout.

                3.2  Downstream audits of any downstream recycling of fallout

                3.3  Warranty of refurbished products resold

                3.4  Proof of wholesale or retail reuse of refurbished product

4.  Records of recycling of all items NOT accepted by the reuse purchase order.

5.  Written instructions to Vermont facility staff on proper sorting, care, testing, or removal of items not accepted under the Purchase Order

6.  Records of Quality Assurance and Quality Control, e.g. records of meetings reinforcing quality requirements on Vermont staff, changes in instructions to reflect changing purchase orders, record keeping, etc.

7.  ISO140001, ISO9000, RIOS, R2, E-Steward or similar evidence of audits of reuse market by independent third party inspectors.

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EXPORT FOR RECYCLING REQUIREMENTS

For used electronics sent for demanufacturing or recycling to OECD or NAFTA countries, such as intact CRT tubes sent to Canada, maquila disassembly (temporary trans-boundary shipments, not considered exported), or final recycling.

A)  Must notify EPA

B)  Must maintain records for 3 years.  These records must, at a minimum, include:

1.  Annual notification of EPA of any focus material exported for recycling

2.  Purchase Order identifying scrap accepted for recycling by the export market (e.g. ABS plastic, copper degaussing coils, aluminum heat sinks, etc.).   Generic terms such as “breakage” and “plastic bearing” (to describe printers) are not acceptable proof that the material was not exported for discard or disposal.

3.  Proof of downstream audits

                2.1 Mass balance of focus materials, and residue report

                2.2 Legal import permit

                2.3  Proof of re-transit for non-exported focus material (e.g. CRTs from maquila demanufacturing).             

4.  Records of recycling of all items NOT accepted by the reuse purchase order (evidence that non accepted materials have been removed, e.g. pre-1972 CRTs which may contain cadmium phosphors)

5.  Written instructions to Vermont facility staff on proper sorting, care, testing, or removal of items not accepted under the Purchase Order

6.  Records of Quality Assurance and Quality Control, e.g. records of meetings reinforcing quality requirements on Vermont staff, changes in instructions to reflect changing purchase orders, record keeping, etc.

7.  ISO140001, ISO9000, RIOS, R2, E-Steward or similar evidence of audits of reuse market by independent third party inspectors.