1. 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

2. 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

3. 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

4. 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

5. 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 forwww.lamprecycle.org 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

6. 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

7. The Association of Electrical and Medical Imaging Equipment Manufacturers Financing Mechanism Key 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

8. 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

9. 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

10. The Association of Electrical and Medical Imaging Equipment Manufacturers Other State Laws MaineVermont  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

11. 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

12. 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 17 th Street Rosslyn, Va. 22209 www.nema.org