BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 2284
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          Date of Hearing:   April 7, 2014

                       ASSEMBLY COMMITTEE ON NATURAL RESOURCES
                                Wesley Chesbro, Chair
                   AB 2284 (Williams) - As Amended:  March 27, 2014
           
          SUBJECT  :   Recycling household batteries

           SUMMARY  :  Requires producers of non-rechargeable household  
          batteries to develop and implement a plan to collect and manage  
          batteries sold in the state.  

           EXISTING LAW:  

          1)Under the California Integrated Waste Management Act of 1989,  
            requires each city or county to divert 50 percent of solid  
            waste from landfill disposal or transformation on and after  
            January 1, 2000.  Establishes a statewide policy goal that not  
            less than 75 percent of solid waste be source reduced,  
            recycled, or composted on and after January 1, 2020.  

          2)Establishes the California Oil Recycling Enhancement Act,  
            which requires manufacturers of used oil to pay a fee of 4  
            cents per quart (16 cents per gallon) to the Department of  
            Resources Recycling and Recovery (CalRecycle), which then pays  
            a recycling incentive of 4 cents per quart to industrial  
            generators, curbside collection program operators, and  
            certified used oil collection centers for used oil collected  
            from the public and transported for recycling.  

          3)Establishes the Electronic Waste Recycling Act of 2003, which  
            requires a retailer selling a covered electronic device (CED)  
            in California to collect a recycling fee (between $3 and $5)  
            from the consumer.  Fees are deposited into the Electronic  
            Waste Recovery and Recycling Account, which is continuously  
            appropriated to CalRecycle and the Department of Toxic  
            Substances Control (DTSC) to make electronic waste recovery  
            payments to cover the net cost of an authorized collector in  
            operating a "free and convenient" system for collecting,  
            consolidating, and transporting CEDs, and to make electronic  
            waste recycling payments to cover an electronic waste  
            recycler's average net cost of receiving, processing, and  
            recycling CEDs.  Defines CED as a product that contains a  
            video display device 4 inches and larger. 









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          4)Establishes the Cell Phone Recycling Act, which requires every  
            retailer of cell phones to have in place a system for the  
            acceptance and collection of used cell phones for reuse,  
            recycling, or proper disposal.  

          5)Establishes the Rechargeable Battery Recycling Act, which  
            requires every retailer of rechargeable batteries to have in  
            place a system for the acceptance and collection of used  
            rechargeable batteries for reuse, recycling, or proper  
            disposal.  

          6)Establishes the Dry Cell Battery Management Act, which  
            establishes requirements for the production and labeling of  
            consumer products with dry cell batteries and sets limits on  
            the amount of mercury in those batteries.  

          7)Establishes the Mercury Thermostat Collection Act, which  
            requires manufacturers to establish and maintain a program for  
            mercury-added thermostats.  Requires the program to include  
            collection, handling, and arranging for appropriate management  
            of mercury-added thermostats.   

          8)Requires pharmaceutical manufacturers that sell or distribute  
            a medication in California that is usually self-injected at  
            home with a hypodermic needle to submit to CalRecycle a plan  
            that describes any actions taken by the manufacturer for the  
            safe collection and proper disposal of the waste devices.  

          9)Establishes the Product Stewardship for Carpets Program, which  
            requires manufacturers of carpet sold in California to submit  
            a carpet product stewardship plan to CalRecycle that  
            demonstrates how waste carpet will be collected and properly  
            managed. 

          10)Establishes the Architectural Paint Recovery Program, which  
            requires architectural paint manufacturers to develop and  
            implement a program to manage waste latex paint.  

          11)Establishes the Used Mattress Recovery and Recycling Act,  
            which requires mattress manufacturers and retailers to develop  
            a mattress stewardships program to increase the recovery and  
            recycling of used mattresses.  

          12)Under the Unfair Business Practices Act, imposes civil  
            liability and criminal penalties for any unlawful, unfair, or  








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            fraudulent business act.

           THIS BILL  establishes the Primary Battery Stewardship Act (Act),  
          which:  

          1)Defines the terms used in the Act, including: 

             a)   "Collection rate" means the percentage of primary  
               batteries, by weight, that are collected during a calendar  
               year by a producer or organization.  

             b)   "Primary battery" means a non-rechargeable battery that  
               weighs 2 kilograms or less.  

             c)   "Primary battery containing product" means a product  
               that contains, or is packed with, a primary battery that is  
               intended to be replaced by the consumer.  

             d)   "Primary battery stewardship organization"  
               (organization) means an organization appointed by one or  
               more producers to design and administer a primary battery  
               stewardship plan.  

             e)   "Primary battery stewardship plan" (plan) means the plan  
               submitted to CalRecycle pursuant to the Act.  

             f)   "Producer" means one of the following:  

               i)     The person who manufactures a primary battery or the  
                 primary battery-containing product and who sells the  
                 product in the state under the person's own name or  
                 brand; 

               ii)    If there is no person to whom the above definition  
                 applies, the person who owns or licenses a trademark or  
                 brand under which a primary battery or primary  
                 battery-containing product is sold in the state; or, 

               iii)   If there is no person to whom the above definitions  
                 apply, the person who imports that primary battery or  
                 primary battery-containing product into the state for  
                 sale or distribution.  

          2)On or before January 1, 2016, requires each producer or  
            organization to submit a product stewardship plan to  








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            CalRecycle. 

          3)Requires that any organization formed to develop and implement  
            a plan must establish an advisory committee, as specified, to  
            provide input during the development of the plan.  

          4)Requires the producer or organization to consult with  
            stakeholders, solicit stakeholder comments, and make  
            stakeholder meetings available via telecommunication. 

          5)Requires that the plan include the following: 

             a)   Provide for a program that achieves a 10 percent  
               collection rate within two years and a 20 percent  
               collection rate within five years of implementation. 

             b)   Contact information for the producers and a description  
               of all brands included in the plan. 

             c)   The number and type of "convenient collection  
               opportunities provided by the program free of charge" for  
               consumers in all counties of the state, and ways that the  
               existing collection infrastructure can be maximized to  
               achieve the goals of the program, as specified.  Collection  
               points must be designed to accept not more than 100  
               batteries per visit by a consumer.    

             d)   A description of the methods that will be used to  
               responsibly manage discarded batteries and to recycle as  
               many of the battery components as technically feasible. 

             e)   Outreach and education efforts. 

             f)   The financing method selected to sustainably fund the  
               program. 

             g)   If the organization elects to work with local  
               governments, provisions for the implementation of the  
               program in conjunction with the appropriate local entities,  
               as specified.  

          6)Allows a producer or organization to petition CalRecycle to  
            adjust the collection rate.  Authorizes CalRecycle to adjust  
            the rate if it determines that there are documented  
            technological, ecological, cultural, economic, or other  








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            impediments or circumstances that are beyond the control of  
            the producer or organization.  

          7)Specifies that a person who manufactures, sells, offers for  
            sale, or imports a primary battery-containing product in the  
            state is not a producer for purposes of the Act if the person:  


             a)   Affirms to CalRecycle that the person only uses primary  
               batteries supplied by a producer participating in the Act;  
               and, 

             b)   Reports to the producer or organization specified  
               information relating to the use and number of products sold  
               in the state.  

          8)Requires CalRecycle to act on a plan submitted within 30 days,  
            as specified, and establishes a procedure if a plan is  
            rejected.  Requires CalRecycle to post all approved plans on  
            its website.  

          9)Within six months after the approval of a plan, requires a  
            producer or organization to implement the plan.  

          10)Within 30 days of the approval of a plan, and March 1  
            annually thereafter, requires CalRecycle to post a list of all  
            brands of batteries covered by the plan.  

          11)On and after July 1, 2016, prohibits a producer, wholesaler,  
            or retailer from offering a battery for sale that is not  
            covered by an approved plan.  Allows the sale of remaining  
            stock of non-covered batteries through October 1, 2016.  

          12)Requires producers of primary batteries or primary battery  
            containing products sold or offered for sale after July 1,  
            2016 to notify CalRecycle and requires the producer to submit  
            a plan to CalRecycle or join an existing organization.  

          13)Requires a producer or an organization to submit an annual  
            report to CalRecycle that includes specified information  
            relating to program implementation and collection rates.   
            Allows reports to be submitted biannually once a producer or  
            organization has achieved the collection rates required by the  
            Act.  









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          14)Requires a producer or organization to pay an administrative  
            fee at the time the plan is submitted and specifies that  
            CalRecycle establish the fee at an amount to cover, but not  
            exceed, its costs associated with reviewing, approving, and  
            enforcing the plan.  Specifies that the fee cannot exceed  
            $5,000.  

          15)Authorizes CalRecycle to assess administrative civil  
            penalties not to exceed $1,000 per day against a wholesaler or  
            retailer that violates the requirements of the Act, as  
            specified. 

          16)Authorizes a producer or organization that implements a plan  
            in compliance with the bill and incurs costs in excess of  
            $3,000 in collecting, handling, recycling, or properly  
            disposing batteries to bring a civil action to recover costs,  
            damages, and fees from another producer for failure to comply  
            with the Act, as specified.  

          17)Preempts a city, county, or district from adopting or  
            enforcing any ordinance that regulates the disposal,  
            collection, and recycling of primary batteries.  

           FISCAL EFFECT  :  Unknown


           COMMENTS  :  According to the author: 

               More than 150 million household batteries are sold in the  
               state annually, yet only about five percent are currently  
               collected for recycling.  To manage this universal waste,  
               local governments and taxpayers pay up to $2,700 per ton;  
               this amounts to tens of millions of dollars each year.  Low  
               recycling rates result in valuable metals entering our  
               landfills or stockpiled in the home; neither of which is  
               optimal.  AB 2284 would place recycling in the hands of the  
               private sector where competition drives down cost and  
               reduces costs to local governments.  

           Background on batteries  .  In California, household batteries are  
          classified as universal waste, which includes materials that  
          DTSC has determined are hazardous waste that are ubiquitous and  
          contain mercury, lead, cadmium, copper, or other substances  
          hazardous to human and environmental health. Since 2006,  
          universal waste has been prohibited from disposal in solid waste  








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          landfills. 

           Product stewardship/expanded producer responsibility (EPR)  :   
          Product stewardship refers to a policy model that includes  
          manufacturers in the end-of-life management for products that  
          they produce.  The California Product Stewardship Council states  
          that EPR is a strategy to place a shared responsibility for  
          end-of-life product management on all entities involved in the  
          product chain, instead of the local governments and taxpayers,  
          while encouraging product design changes that minimize a  
          negative impact on human health and the environment at every  
          stage of a product's lifecycle.  Ideally, EPR allows the costs  
          of management and disposal to be incorporated into the total  
          cost of a product.  Good EPR programs result in products that  
          are better designed for reuse and recycling, make recycling more  
          convenient for consumers, reduce illegal disposal of hazardous  
          materials, and encourage the use of recycled materials in new  
          products.  

           Local government impacts  :  Currently, local household hazardous  
          waste collection programs are the primary outlet for proper  
          management of universal waste and other hazardous wastes  
          generated by households, including batteries.  Cost estimates to  
          manage waste batteries average around $800 per ton (with some  
          costing up to $2,700 per ton), amounting to tens of millions of  
          dollars each year.  With decreasing revenues and increasing  
          responsibilities on local governments, another solution is  
          necessary to manage these products.  Many local governments have  
          greatly decreased their household hazardous waste programs,  
          leaving few management options for the public.  To date, 133  
          local resolutions have been adopted in California supporting the  
          EPR model.  

           Current battery recycling efforts :  The non-profit organization  
          Call2Recycle is working in North America to collect and recycle  
          rechargeable batteries.  Call2Recycle operates under the  
          Rechargeable Battery Recycling Corporation to promote  
          "environmental sustainability by providing free battery and cell  
          phone recycling in North America."  The Call2Recycle program for  
          rechargeable battery and cell phone recycling is available to  
          residents, retailers, businesses, communities, municipalities,  
          and public agencies in the US and Canada.  The program was  
          created in 1994 and is funded by battery and product  
          manufacturers to raise awareness about the importance of battery  
          recycling and to promote product stewardship initiatives. 








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          In 2006, the European Commission adopted the Batteries Directive  
          2006/66/EC, which requires member states of the European Union  
          to reach a 25 percent collection rate by 2012 and 45 percent by  
          2016.  The directive also establishes toxicity limits for  
          batteries.  

           Previous legislation  :  AB 488 (Williams) was similar to AB 2284  
          and would have required producers of non-rechargeable household  
          batteries to develop and implement a plan to collect and manage  
          batteries sold in the state.  This bill was held in the Assembly  
          Appropriations Committee.  

          SB 515 (Corbett, 2011) would have required a producer of  
          batteries sold in California to develop and implement a  
          household battery stewardship plan describing how it would  
          achieve collection of household batteries and the maximum  
          feasible recovery of materials from the collected batteries.   
          This bill was held in the Senate Appropriations Committee.

          SB 1100 (Corbett, 2010) was substantially similar to SB 515.   
          This bill was held in the Assembly Rules Committee. 

           Suggested amendments  :  

          1)Last year, this committee made several amendments to AB 488,  
            including exempting medical devices.  AB 2284 limits this  
            exemption to medical devices "that are implanted."   Most, if  
            not all, implanted devices are already exempt from the  
            requirements of the bill because they do not contain batteries  
            that are intended to be replaced by the consumer.   The  
            committee may wish to amend the bill  to clarify that the bill  
            does not apply to medical devices.  

          2)This bill requires that the plan submitted to CalRecycle  
            include "the number and type of convenient collection points  
            that shall be provided by the program free of charge for  
            consumers in all counties of the state?"  Paragraph 2 of  
            subdivision (d) of Section 42445.3 qualifies this requirement  
            by exempting "single retailers" from the specific collection  
            requirements; requiring "at least one" collection point in  
            non-rural counties; and, requiring  at least one collection  
            point per 10,000 residents by 2018 and one collection point  
            per 5,000 residents by 2021 in rural counties.  These  
            qualifiers appear to weaken the "free and convenient"  








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            collection requirement.    The committee may wish to amend the  
            bill  to strike out this paragraph (page 8, lines 16 to 30) to  
            ensure that free and convenient collection is available to all  
            consumers throughout the state.  

          3)This bill states that it is the intent of the Legislature that  
            any actions undertaken by a producer or organization pursuant  
            to the bill are exempt from federal and state antitrust laws;  
            however, the state has no authority to exempt entities from  
            federal law.   The committee may wish to amend the bill  to  
            remove "federal" from this provision (42445.17).  


           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Product Stewardship Council (sponsor) 
          City of Sacramento
          Solid Waste Association of North America



           Opposition 
           
          Advanced Medical Technology Association
          California Cable & Telecommunications Association
          Toy Industry Association
           
          Analysis Prepared by  :    Elizabeth MacMillan / NAT. RES. / (916)  
          319-2092