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Information for electronics manufacturers

Manufacturers of covered electronic devices sold to Wisconsin households, K-12 public schools or Parental Choice Program schools must register under E-Cycle Wisconsin and follow its requirements, including recycling or arranging for the recycling of a certain amount of electronic devices each year. Manufacturers must also submit an annual report and re-registration form to the DNR.

Who must register

Who must register under E-Cycle Wisconsin

The requirements of Wisconsin's electronics recycling law apply only to manufacturers of covered electronic devices sold to Wisconsin households or covered schools.

E-Cycle Wisconsin focuses on the brands of covered electronics. There should be only one party responsible for each type of covered device under a specific brand. Unlike other states, Wisconsin's law deals only with brands currently being sold and the entities currently responsible for them.

An entity must register under E-Cycle Wisconsin if it does one or more of the following:

  • Manufactures covered electronics to be sold under its own brand.
  • Sells covered electronics manufactured by others under its own brand (i.e., does not own the factories where the electronics are produced).
  • Licenses its brand for manufacture and sale of covered electronics by others, and has not designated the licensee as the responsible party.
  • Is a licensee designated by the licensor under s. 287.17(1m), Wis. Stats., as the party assuming responsibility for the manufacturer's recycling responsibilities under this program.

Who should not register

Only manufacturers meeting the above description are regulated under this law. A manufacturer is not regulated under this program if it:

  • does not plan to sell covered electronics to Wisconsin households or covered schools during the current program year;
  • only makes components or devices that are not on the list of covered electronics; or
  • only remanufactures or refurbishes covered electronics.

If you have questions about whether your company needs to register, please contact us at DNRWAe-cycling@Wisconsin.gov or 608-264-6001.

Requirements

Electronics manufacturer requirements under Wisconsin's law

Manufacturers covered under Wisconsin's electronics recycling law must do all of the following in order to sell covered electronics to Wisconsin households, K-12 public schools and Parental Choice Program schools.

  • Submit an annual registration form to the DNR.
  • Pay an annual fee, if applicable, upon registration.
  • Report annually on sales of covered electronic devices to Wisconsin households and covered schools.
  • Ensure that all covered electronic devices sold under their brand in Wisconsin have a manufacturer's label that is permanently affixed and prominent.
  • If the manufacturer has a recycling target for a given program year, based on its prior sales, it must work with registered collectors and recyclers to meet this recycling target. Manufacturers negotiate private contracts with recyclers to purchase credits for the number of pounds needed to meet the target.
  • If a manufacturer does not meet its recycling target, it must pay a shortfall fee to the DNR.

A manufacturer does not need to limit its recycling to its own brand, but can pay for the recycling of any brands of eligible electronic devices collected from Wisconsin households and schools.

Note that recyclable materials that are sent to landfills for disposal or for use as alternate daily cover are not eligible for manufacturer credit under E-Cycle Wisconsin. In particular, glass from cathode ray tubes that is sent to landfills is not eligible.

Annual registration fees vary, depending on the number units of covered electronics sold in Wisconsin. The fee levels are:

  • $5,000 for manufacturers that sold 250 covered electronics or more to Wisconsin households, K-12 public schools and Parental Choice Program schools during the previous program year;
  • $1,250 for manufacturers that sold between 25 and 249 units; and
  • $0 for manufacturers that sold fewer than 25 units, including manufacturers of new products that were not sold during that time period.

When a manufacturer fills out its annual registration form, the online system will calculate the fee owed and generate an invoice for payment.

A manufacturer may carry out its responsibilities jointly with other manufacturers and may participate with other manufacturers in creating an entity to collect and recycle electronics.

Manufacturers must work with recyclers or collectors registered with E-Cycle Wisconsin to meet their recycling targets. They may also do their own collecting and/or recycling, provided they register with E-Cycle Wisconsin as a recycler or collector.

Recycling targets, carryover credits and shortfall fees

Each manufacturer must recycle, or arrange for the recycling, of a certain amount of eligible electronics each program year. This recycling target is based on a percentage of the manufacturer's covered electronics device sales to Wisconsin households, K-12 public schools and Parental Choice Program schools during an earlier 12-month period.

To meet its target, a manufacturer may recycle any eligible electronics of any brand, regardless of which brands or devices it makes. Manufacturers are not required to accept all electronics or all brands.

If a manufacturer recycles more than its target weight in a given program year, it can carry over a percentage for use during one of the next three program years. It can also sell the credits to another manufacturer during one of the next three program years. Carryover credits are capped at 20 percent of a manufacturer's recycling target for the program year.

If a manufacturer fails to reach its recycling target, it must pay a shortfall fee along with its registration fee for the next program year.

Revocation of manufacturer registration

If a manufacturer fails to meet program requirements, the DNR may revoke its E-Cycle Wisconsin registration.

Registering and reporting

Manufacturer registration and reporting overview

Manufacturers covered by Wisconsin's electronics recycling law must register and report to the DNR by Sept. 1 each year. Manufacturers offering covered products for sale to Wisconsin households or schools for the first time must register within 10 days of beginning to do so.

On the registration form, manufacturers must list all their current brands of covered electronics sold to Wisconsin households and K-12 schools. They must also provide their recycling target for the current program year—the amount they will need to recycle by next June 30. For information on calculating the target, see Recycling Targets and Credits.

On the report portion of the form, manufacturers must report the weight of eligible electronics recycled on their behalf during the previous program year by registered E-Cycle Wisconsin recyclers.

Initial registration

If you are registering as a manufacturer for the first time, contact us at DNRWAe-cycling@Wisconsin.gov or 608-264-6001 to get information and registration instructions..

Re-registration and annual report

For currently registered manufacturers, the next re-registration/annual report form will be due Sept. 1, 2017. The form should be available online in July 2017.

If you have not previously completed online forms for the DNR recycling program, you will need to complete a one-time registration process to get access to the online report system.

Report links

Paying fees

Annual manufacturer registration fees

Manufacturers of covered electronic devices are required to submit a registration fee with their annual registration. The fee is:

  • $5,000 for manufacturers that sold 250 covered electronics or more to Wisconsin households, K-12 public schools and Parental Choice Program schools during the previous program year;
  • $1,250 for manufacturers that sold between 25 and 249 units; and
  • $0 for manufacturers that sold fewer than 25 units, including manufacturers of new products that were not sold during that time period.

When you fill out the initial registration or annual re-registration form online, the system will calculate your registration fee and produce an invoice for you.

Shortfall fees for failure to meet recycling targets

Manufacturers that fail to meet their recycling target for a given program year are assessed a shortfall fee. The fee amount is automatically calculated by the online reporting system, which will add this fee to any registration fees you owe on an invoice. For more on shortfall fees, see recycling targets, credits and fees.

How to pay fees

If you need the DNR's taxpayer ID or a completed W-9 form, please contact the E-Cycle Wisconsin staff.

There are three ways to pay your registration and/or shortfall fees to the DNR:

  • e-check, using our online payment system (with a bank routing number and account number);
  • electronic funds transfer/ACH; or
  • a traditional check.

For each of these options, you will need the invoice generated when you submit your initial registration or annual report. If for some reason you don't have this, please contact the E-Cycle Wisconsin staff.

If paying by check, mail with a copy of your invoice to:

Wisconsin Department of Natural Resources
PO Box 78816
Milwaukee, WI 53278-0816

Make checks payable to: Wisconsin Department of Natural Resources. Please include your invoice number on the check.

If a street address is needed, use the following:

Wisconsin Department of Natural Resources
Bureau of Waste and Materials Management - WA/5
101 S Webster Street
Madison WI 53702

Last revised: Thursday March 09 2017