Skip Navigation LinksDEP > Businesses > Land > Waste > Recycling > Electronics Recycling > Manufacturer Requirements

Manufacturer Requirements

The Covered Device Recycling Act (CDRA) imposes a number of responsibilities on manufacturers of covered devices that offer their covered devices for sale in Pennsylvania. Covered devices include desktop computers, laptop computers, computer monitors, computer peripherals and televisions.

However, manufacturers of only computer peripherals are excluded from the manufacturer responsibilities established by the CDRA.
Manufacturer Responsibilities:

Forms & Instructions

Sales Prohibition & Brand Labeling (Sections 302-303 of CDRA)

Beginning Jan. 1, 2012, a manufacturer may not sell new covered devices in Pennsylvania unless the devices are labeled with the manufacturer's brand, whether owned or licensed, and the manufacturer has registered the brand with DEP.

Registration (Section 304 of CDRA)

Beginning Jan. 1, 2012, manufacturers of desktop computers, laptop computers, computer monitors and televisions must register annually with the department in order to sell their covered devices in Pennsylvania. However, manufacturers of only computer peripherals do not need to register with the department in order to sell their computer peripherals in Pennsylvania.

Manufacturer Registration Form for Calendar Year 2018 (eLibrary)

  • Due to the department by Aug. 31 of each subsequent program year.
  • Must be submitted with a $5,000 registration fee.

A covered device manufacturer must register annually with the department by Aug. 31 in order to sell its covered devices in Pennsylvania.

Plans for Covered Device Collection & Recycling [Section 305 of CDRA]

Plans are to be submitted on a form provided by the department.

Individually, or as part of a group, a manufacturer must establish, conduct and manage a plan to collect, transport and recycle a quantity of covered devices equal to its obligated share. A completed Planning Form must be received and approved by the department by Aug. 31, 2016, and the plan must include:

  • Methods used to collect covered devices, including the names and locations of collection sites. 
  • The names and locations of directly utilized recyclers and the recycling processes they use.
  • A means to publicize collection opportunities, collection locations, and educate consumers, including a website or toll-free telephone number.
  • The intention of the manufacturer(s) to fulfill its requirements under this act.
  • For the initial plan, an estimate of the weight to be collected in the first calendar year.

The department will review a submitted plan within 60 days of its receipt, and will then notify the manufacturer(s) of the plan's approval or rejection in writing. If the plan does not include all of the required information the manufacturer(s) plan will be returned with the Department's rejection by certified mail. Manufacturer(s) have 30 days from receipt of the Department's notice to submit a revised plan for approval.

For subsequent planning years (beginning 2013), all manufacturers, or groups of manufacturers, must submit an updated plan to the department by Aug. 31. A manufacturer, or group of manufacturers, that met their plan requirements during the previous calendar year may resubmit their previous plan if no changes have been made.

A manufacturer, or group of manufacturers, that did not meet their plan requirements shall include with their updated plan a detailed narrative of changes demonstrating the process by which the manufacturer or group of manufacturers will increase the collection of covered devices by a minimum of 2 percent by weight per year.

Annual Reporting [Section 305(c) of CDRA]

NEW Annual Report for Electronics Manufacturers for Calendar Year 2017 (eLibrary)

A manufacturer or group of manufacturers that conducted a collection, transportation, and recycling program for covered devices in the previous year under an accepted plan must submit an annual report to the department by Jan. 31 of each year.

Requirements of the report:

  • Includes the total weight of each manufacturer's covered devices sold nationally during the calendar year two years prior, and the calculated PA sales. (For example, the report that is due Jan. 30, 2013 must include sales data from 2011.)
  • Includes the weight of various covered devices the manufacturer(s) collected from consumers in Pennsylvania during the previous calendar year. (For example, the report due Jan. 30, 2013 must include 2012 collection data.)

National sales data submitted by manufacturers is exempt from Right-To-Know disclosure unless required by law or court order.

Penalties – Beginning in 2013, at the conclusion of each calendar year, if the total weight of covered devices collected by a manufacturer or group of manufacturers is less than the amount provided in its approved plan for that year, the manufacturer(s) must pay a penalty.

  • Due to the department by March 15 of the following year.

Calculated by multiplying the unmet portion, in pounds, plus an additional 10 percent, times the cost per pound for the collection, transportation and recycling of covered devices as determined by the department.

Fee Prohibition [Section 504 of CDRA]

No manufacturer may charge a fee or cost to a consumer (including home-based businesses) for the collection, transportation or recycling of a covered device, unless a financial incentive (e.g. coupon, rebate or other) of equal or greater value is provided to the consumer.

Environmentally Sound Management Responsibilities [Section 505 of CDRA]

Beginning Jan. 1, 2012, any covered devices collected by any collection programs in Pennsylvania shall be recycled in a manner that is in compliance with all applicable federal, state and local laws, regulations and ordinances, and may not be exported for disposal in a manner that poses a significant risk to the public health or the environment.

Manufacturers should not transfer any collected covered devices to an electronics recycling facility unless they can demonstrate to the department that the facility has achieved and maintained one of the following certifications:

Visit our electronics recycling facilities webpage for a list of electronics recyclers. If the recycling facility is located in Pennsylvania, the facility must also have obtained permit #WMGR081 from the department.

Frequently Asked Questions (PDF)

For further information, please contact:

Pennsylvania Department of Environmental Protection
Bureau of Waste Management
Division of Waste Minimization and Planning
Rachel Carson State Office Building
P.O. Box 8472
Harrisburg, PA 17105-8472
Telephone: 717-787-9871