For original equipment manufacturers (OEMs), compliance with state-legislated electronics recycling programs protects their right to sell products in those states. However, constantly evolving technologies, coupled with complex individual state requirements, can challenge an OEM’s ability to do the job right, especially at a time when internal resources may be stretched to the limit.

Increasingly, electronics manufacturers, even smaller industry players, have shifted the e-waste recycling burden to a company specializing in OEM legislative compliance. However, deciding to outsource is just the first step — there are significant disparities in the attributes and capabilities of OEM legislative compliance partners.

With so much at stake, you simply can’t afford to make the wrong choice. Following are 10 crucial questions to ask potential partners during your evaluation process:


  • “Will you help us meet the requirements of all the states where our products are sold?”
    This is a huge consideration — and a major area of risk. Every state with a legislated e-waste recycling program lays out a unique set of requirements. Your OEM partner should understand precisely what’s required and help you comply, safeguarding your interests in those states.


  • “How comprehensive is the scope of your services?”
    Managing legislative compliance across multiple states consumes a high level of expertise and an enormous deployment of resources. The most capable OEM partners will be able to competently handle a full spectrum of activities, from registration of your company with each state that has a legislative program to satisfying state reporting requirements.


  • “Can you tailor your services to our specific needs?”
    Perhaps you need a focused set of services to help fill gaps in your internal program. The partner you choose should possess the flexibility to accommodate your specific needs and work seamlessly with your team to achieve compliance.


  • “What’s your level of experience in OEM legislative compliance?”
    Steer clear of companies that offer OEM legislative compliance as an add-on service. Why? Because an industry-leading legislative compliance program requires a major corporate commitment, coupled with years of experience and a significant investment in dedicated resources.


  • “What are your capabilities and safeguards to mitigate the risks associated with sensitive data?”
    You definitely don’t want your partner to cut corners here, given the huge risks associated with data breaches. Make certain that data security is one of the partner’s top priorities. Moreover, verify that data on all devices will be comprehensively wiped, shredded, or destroyed, in accordance with standards spelled out by NIST 800-88, NAID, and the Department of Defense. In addition, the partner must carry adequate cyber liability insurance.


  • “Do your collection sites meet each state’s convenience requirements?”
    Confirm that the partner’s collection sites comply with state-specific program requirements. Besides supporting the proper handling and processing of electronics, a robust nationwide network of conveniently located and compliant collection sites eliminates the time-consuming task of piecing together your own network.


  • “If we have an urgent need or question, how responsive will you be?”
    Critical situations and questions can arise at a moment’s notice. Not getting prompt answers or assistance may lead to a variety of detrimental outcomes, including penalties, damage to the brand, and revocation of your right to sell products in a state.


  • “Will you keep us in the loop about current or pending legislation that’s relevant to us?”
    Who has time to constantly monitor and interpret federal and state legislation pertaining to OEM e-waste recycling? You may not, but your OEM legislative compliance partner should. Even better is a partner that communicates must-know updates to you on a timely basis.


  • “What’s your track record for meeting regulatory and contractual deadlines?”
    In the world of OEM legislative compliance, there’s a deadline around every corner — and it’s usually breathing down your neck. Your partner should possess the ability and internal controls to make sure every deadline is met.


  • “Do you offer solutions or advice beyond legislative compliance and e-waste recycling?”
    Look for a partner that adds value to your relationship with them — potentially even yielding a return on your investment. Examples of value-added services include electronics refurbishing and remarketing and the recovery and resale of precious metals, non-ferrous scrap, and other non-metal materials.

Author: Dynamic Lifecycle Innovations