Lamp Recycling Presented by: Scott Thibodeau

Today’s Discussion Lamp Recycling 101 A Growing Issue Current Situation Different Approaches Are Needed Lamps and EPR Summary

Lamp Recycling 101 Market –670 Million Lamps Discarded Annually –25% Current Recycling Rate Services Provided by Recyclers –Large Quantities –Small Quantities

Lamp Recycling 101 How Are Lamps Recycled?

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A Growing Issue Projections for 300 million new CFLs in U.S. % residential not known Local take-back programs necessary to keep costs reasonable Market will not tolerate huge price increases- consumer lamp usage will be impacted

Current situation for public Infrastructure/funding for business in place and affordable = generator pays based on volume/service= acceptable cost Poor infrastructure for recycling consumer lamps Little convenient options for public Little, scattered retail take-back 2-4% participation in HHWs Direct mail back to recyclers cost prohibitive ($2-3 per bulb)

Different Approaches Are Needed Mercury lamp management is not like other products in many ways. –Volatile toxic material in fragile product –TSDs are regulated –Not the case for other commodity items (e-waste) with thousands of collectors and processors- value creates infrastructure! Without local consolidation, the cost of end-of-life handling of consumer lamps will be several times their price

Lamps and EPR Value of original product vs. value of recovered materials Recycling cost over lamp life cycle is insignificant, but recycling cost relative to new product cost is enough to affect lamp usage. Lamps as HW- breaking intentionally is treatment. Recyclers are HW TSDs and operate in highly regulated environment with oversight, compliance costs and CERCLA Liability Different commerce and culture for recycling HW vs. products that can either be harvested for reuse, or shredded for shipment offshore. Low entry barriers for handlers.

Manufacturer Concerns Manufacturers do not want to “take-back” or to be engaged in the commerce of HW recycling. If manufacturers pay- can cost be put in product- uniformly without state by state intervention or black markets. How can manufacturers recover costs? Margins and benefits are higher for distributors/retailers. If retailer sells only one brand, how could they get paid if return program was for all brands? Liability What’s next?

Retailer Concerns Breakage in store or parking lot Employee training Costs, ability to charge a fee to customers (e.g. Staples $10 for old product return) Liability What’s Next? Will retailers agree to participate? Will they agree to bear or share in costs?

Environmental Industry Concerns Small Quantities- How to deal with them? Transportation EPR and C&I Segments 3 rd Party Determines Recycler VS Marketplace

Unsolved issues: The dilemma remains how to make this easy and accessible for homeowners. Convenience is critical. HHW collection centers' participation is extremely low- about 2%. We don't expect increased CFL use to change that. Solid waste industry has, so far, not wanted to create diversion programs for their clients.

Summary If consumers’ drop-off locations are made available, people will be more likely to recycle Recycling capacity is available Low value of recycled materials means either someone subsidizes or product prices go up No one wants to pay Point of negative return for energy efficiency not known yet State-by-state approach will disrupt commerce