Information For Electronics Recyclers
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Recyclers of eligible electronic devices from Wisconsin households and schools may choose to participate in E-Cycle Wisconsin and follow its requirements, including maintaining pollution liability insurance and owner financial responsibility. Registered recyclers must also report to the DNR twice a year.
Recyclers should only register if they plan to work with an electronics manufacturer to meet the manufacturer's recycling obligation under Wisconsin's electronics recycling law.
Recyclers who choose not to participate in this program are not subject to its regulations and do not have to register with the DNR. However, all recyclers need to ensure they are in compliance with all applicable solid and hazardous waste rules
- Get general information about requirements for handling e-waste
- Learn more about the devices covered by E-Cycle Wisconsin
New electronics recycling rule
The DNR’s electronics recycling rule is effective July 1, 2023. The rule creates requirements for collecting, storing, transporting and processing electronics. Most Wisconsin facilities that dismantle or further process electronics will need a solid waste processing approval and license from the DNR. The rule also clarifies and adds some requirements for E-Cycle Wisconsin participants.
Who Should Register
Who should be a registered recycler under E-Cycle Wisconsin
A participating recycler accepts eligible electronics from collectors or directly from Wisconsin households or K-12 schools for the purpose of recycling and counting the recycled pounds toward a manufacturer's recycling obligation.
Under E-Cycle Wisconsin, recycling means preparing eligible electronics for use in manufacturing processes or for recovery of usable materials by other processors. That is, if you are involved in any dismantling of eligible electronics into component parts (screens, circuit boards, etc.), you meet the E-Cycle Wisconsin definition of a recycler.
Recyclers may also refurbish or repair electronics, but that part of their services is considered separate from E-Cycle Wisconsin, and the weights of those materials cannot be counted toward a manufacturer's recycling obligation.
A recycler who also collects eligible electronics from Wisconsin households and covered schools must also register separately as a collector.
Do not register as a recycler under E-Cycle Wisconsin if any of the following is true.
- You do not plan to work with an electronics manufacturer to meet its recycling obligation, or work with other recyclers registered with E-Cycle Wisconsin to provide eligible pounds..
- You only accept electronics from businesses, governments, organizations or others that are not households or schools.
- You accept electronics exclusively for refurbishing or repair.
- You only accept electronics from another recycler, and not directly from a collector or the public. Registration is also not necessary if the recycler only accepts eligible electronics from businesses, institutions or others not included in E-Cycle Wisconsin.
Requirements for registered E-Cycle Wisconsin recyclers
Recyclers participating in E-Cycle Wisconsin must do all of the following.
- Register annually with the DNR.
- Submit an annual report and a mid-year report to the DNR.
- Document liability insurance of at least $1 million for environmental releases, accidents and other emergencies.
- Maintain proof of financial responsibility for closure and cleanup.
- Prepare and maintain a written contingency plan for responding to releases of hazardous substances that complies with the requirements in s. NR 664.0052, Wis. Adm. Code.
- Certify that they comply with all federal, state and local requirements concerning storage, transportation, processing and exporting of eligible electronics and materials derived from eligible electronics, including federal requirements in 40 CFR 261.39(a)(5) and 273.20, and requirements in rules promulgated under s. 291.05, Wis. Stats.
- Certify they comply with federal requirements under 29 CFR 1910.120 (occupational and environmental health and safety training for employees).
- May not use prison labor to recycle electronics under E-Cycle Wisconsin.
- Keep detailed records (see the Recordkeeping and audits tab).
See links under the Resources tab to learn more about meeting these requirements.
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.
Any operations to collect and recycle devices (e.g., electronics from businesses or non-eligible recyclables) not covered by E-Cycle Wisconsin must be kept separate and cannot be counted toward manufacturer recycling obligations.
Forms for required owner financial responsibility
One of the operational requirements for registered E-Cycle Wisconsin recyclers is to maintain proof of financial responsibility, described under s. 287.17 (8)(c)3. Wis. Stats., ensuring that sufficient funds are available to cover reasonably estimated costs for a third party to clean up and close a recycling facility, including managing any remaining electronics or materials derived from electronics.
Form 4400-320 is the form specified by the DNR for a recycler to report an itemized statement of the estimated costs. If a recycler has its closure cost estimate in another form, it should consult with E-Cycle Wisconsin staff at the DNR to determine whether substitution for Form 4400-320 is acceptable.
Warning: Due to the fillable nature of these PDF forms, many current browsers will not open them properly.
- From a desktop computer, download the PDF form (right-click on the link, then select "Save link as" or "Save target as")
- Make a note of the file location and file name so you can access the file from your device.
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- Registered Recycler Cost Estimate (4400-320)
- Performance Bond for Closure for Use by Registered E-Cycle Wisconsin Recyclers (4400-318)
- Irrevocable Letter of Credit for Closure for Use by Registered E-Cycle Wisconsin Recyclers (4400-319)
Suspension or revocation of recycler registration
If a recycler fails to meet program requirements, the DNR may suspend or revoke its E-Cycle Wisconsin registration.
Register and Report
To participate in E-Cycle Wisconsin, recyclers must register annually with the DNR. Recyclers who choose not to participate in this program are not subject to its regulations and do not have to register with the DNR.
If you are registering as a recycler for the first time, contact us via email to get information and a registration form.
Re-registration and annual report
Registered recyclers must submit a report to the DNR by Feb. 1 each year. By completing the online report form, a recycler re-registers for another program year unless it indicates otherwise on the form.
As part of the combined registration and report, a recycler must report the weights of eligible electronics received and recycled on behalf of manufacturers under E-Cycle Wisconsin during the previous program year, along with the name(s) of the manufacturer(s). Only eligible electronics collected and received by the recycler during that program year may be counted. See Guidance on Reporting EEDs Collected and Recycled over Program Year Transitions (WA-1435) for more information.
If you have not previously completed online forms for the DNR recycling program, please contact us so we can help you set up a user account.
Recyclers must also submit a mid-year report. The report must include the weight of eligible electronics received for recycling on behalf of manufacturers during the first six months of the current program year, along with the manufacturer names, and the total weight of eligible electronics the recycler has received in anticipation of selling the pounds to a manufacturer. The report is due Aug. 1 each year beginning in 2024.
Recordkeeping and Audits
Special recycler recordkeeping requirements under E-Cycle Wisconsin
Recyclers participating in E-Cycle Wisconsin need to maintain a number of records tracking the materials they handle under the program. All records related to the operation of E-Cycle Wisconsin must be kept on file by a recycler for three years and made accessible to DNR staff upon request. A recycler must also make certain records available to a manufacturer on whose behalf the eligible electronics were recycled, upon the manufacturer's request.
Recyclers must keep the following records for each program year.
- Sources of eligible electronics received for recycling under E-Cycle Wisconsin.
- The total weight of eligible electronics recycled on behalf of each manufacturer.
- The total weight of eligible electronics or materials derived from eligible electronics sent to another entity for use in a manufacturing process or for the recovery of usable materials (i.e., another recycler or processor).
- The total weight of materials derived from eligible electronics sent for disposal.
- Identities of the first, and second if applicable, "downstream" recipients of material derived from eligible electronics recycled on behalf of a manufacturer.
- Records that demonstrate actions undertaken to ensure that downstream markets use the materials derived from the eligible electronics in a manufacturing process or for the recovery of usable materials.
Recyclers must also use and maintain copies of bills of lading when transporting electronics and components from the point of collection or consolidation to the recycler's facility, and from the recycler's facility to other recyclers or end users. Each bill of lading must include:
- the date the load was picked up from the originating facility;
- a description of the load, including the type of materials and number of pallets or containers;
- either the weight of the load, if a scale is available, or the estimated weight of the load, if a scale is not available; and
- signatures from the shipper and receiver.
Any operations to collect and recycle devices (e.g., electronics from businesses or other recyclables) not covered by E-Cycle Wisconsin must be kept separate and cannot be counted toward manufacturer recycling obligations.
DNR inspections and audits of registered recyclers
The DNR regularly inspects registered recyclers located in Wisconsin, and may conduct desktop inspections or audits of out-of-state registered recyclers. The electronics recycling law also has a provision for more intensive recycler audits if necessary.
Free outreach and educational materials
The DNR has a wide variety of free outreach materials available for recyclers to use. You can view electronic files or order print publications on our outreach page. In addition, we have special signs available for registered collectors and recyclers to use. To request electronic or print copies of these, email us.
Additional program resources
- List of registered manufacturers and brands
- List of unregistered manufacturers
- List of registered manufacturers with contact information
- List of registered collection sites
- List of registered collectors
- List of registered recyclers
- Map of collection sites
- Map of urban and rural counties as designated under E-Cycle Wisconsin.
DNR guidance on state and federal requirements
- Information for businesses that handle electronic waste
- Managing Used Electronics and Components
- Management of Universal Waste in Wisconsin
- Definitions of Covered Devices
- Determining Whether Materials Are “Recyclable” Under E-Cycle Wisconsin
- Landfill and Incineration Ban Enforcement
- Limitation on Use of Prison Labor
- Proof of Financial Responsibility for Electronic Recyclers
- Reporting EEDs Collected and Recycled over Program Year Transitions
- Reporting and Recordkeeping for Recyclers and Collectors Working with Other Collectors (WA-1475)
- Requirements for Landfill Disposal of Processed CRT Glass and E-Cycle Wisconsin Eligibility
- Sale of “Paper Weight” Among Registered Recyclers and Authorized Brokers (WA-1476
Third-party recycler certification programs
An independent certification is not required for participation in E-Cycle Wisconsin, but the DNR will include this information on its list of registered recyclers. If you would like more information about certification programs, below are two examples of commonly used programs: