Testimony before the Environment Committee of the New Jersey Senate on Monday, January 30, 2006

Good morning Mr. Chairman and members of the Committee. I want to thank you for giving me the opportunity to speak on the important topic of Electronics Waste Recycling. My name is Linda Klose. I am the executive director of the New Jersey-Pennsylvania Council of AeA, Advancing the Business of Technology and a resident of the state of New Jersey. AeA, formerly called the American Electronics Association, is the world’s largest industry association representing the high technology community. With approximately 2,500 members in the United States, our unique grassroots structure and overseas presence is not duplicated in any other high technology industry association. The New Jersey-Pennsylvania Council of AeA serves member companies in its two-state area through educational programs, network opportunities, and public policy advocacy. We are committed to ensuring a strong and healthy business climate in which high technology companies can grow and thrive.

Industry Background

Providing service to our members is our primary focus. But as the leading industry association for high technology companies, we also have access to a great deal of information about the growth of technology industries and what that means to the economic vitality of a given region. Technology, and the manufacturing associated with it, is an important part of New Jersey’s economy. In 2003, based on U.S. Bureau of Labor Statistics, there were 202,587 citizens employed in high-tech sectors by 14,611 firms in New Jersey. In fact, New Jersey was ninth in high technology employment and R&D spending in the US. There was also $3.5 Billion in high technology goods exported from New Jersey to other countries in 2004. That’s 18% of all of New Jersey’s exports. Clearly, technology is not just something bought and sold in New Jersey but something that is actually produced here which means jobs and revenue for the state. In addition, there is a great deal of high technology retail activity in this state which generates still more jobs and tax revenue for our state.

AeA’s members include every aspect of high technology from the raw materials of our industry to the manufacturer of its finished goods. Here in New Jersey, I represent members who have high technology businesses from a few employees up to multi-billion dollar, global corporations. These business people are happy and proud to call New Jersey home for their families and their businesses.

All of my association’s member companies, whether headquartered in New Jersey or elsewhere, want you to know how concerned we are with protecting our environment. As responsible citizens, we want to protect our families and our future. We also want to protect the economic vitality of our state. It is a tricky balance.

I thank the members of this committee for proceeding so carefully. Senate Bill 554 shows a great deal of thought. Still, the biggest problem that I foresee with the bill is that is will set New Jersey apart and make it less competitive with its neighboring states.

AeA has been in the forefront of working with the European Union on it RoHS and WEEE directives over the last few years. In doing so, we have become aware of how difficult a process this is. After years of working on the regulations, there is still a great deal of work to do.

Hazardous Materials Restrictions

In regard to Hazardous Materials Restrictions, because of the existing European Union directives, US electronics’ manufacturers have moved to a standard based on the EU’s RoHS directives. When California updated its hazardous materials restrictions last year, it opted to harmonize their standards to the EU’s. This eliminated the need for extensive testing and regulations by the state.

For New Jersey to ask for a separate set of standards on Hazardous Materials Restrictions from the rest of the world, seems counter-productive. At best, it will create an enormous amount of bureaucracy and regulations. At worst, it could mean that some manufacturers would fail to sell their product in our state. Certainly, it would raise the cost of goods sold in New Jersey. I can see no purpose of any kind for setting a separate New Jersey standard.

In addition, if the electronic components are to be collected and recycled, why do the materials need to be restricted? Manufacturers are already designing their products with recycling in mind.

I ask that you eliminate the section on Hazardous Materials Restrictions from Senate Bill 554. But, if New Jersey must restrict materials, it should be considered separately from recycling and be harmonized with the European standard.

Electronics Recycling

The high-tech industry is committed to reducing the environmental impacts of our products throughout their lifecycle: from design, to use, to end-of-life. Many high-tech manufacturers have made significant investment in design for the environment (DfE) over the past several years in an effort to minimize the use of certain materials, as well as allow for the ease of recycling of the electronic products. Several companies have on-going company recycling programs or provide sponsorship and support to aid in the development of local recycling infrastructure.

The recycling of unneeded electronics products is complicated. There are so many products with a wide variety of materials and construction. AeA cannot take a position on the financing model in this bill due to divided membership. However, individual member companies are present here today and will be submitting written letters stating their position on the financing mechanism.

Labeling Requirements

Pick-up your laptop and take a look underneath. At least six labels are probably there. Adding more labels will not improve consumer knowledge, just consumer confusion, especially if each state must be listed separately. Since this bill covers items even smaller than a laptop, in some cases, it is impossible to affix a sufficiently large label to meet the proposed requirements of Senate Bill 554. It is also inflexible in that it cannot be updated after the label is printed. In addition, it is useless for orphaned or historic waste. A label that lists the manufacturers’ information is sufficient for the consumer to find the latest information via its website. And, since counties and municipalities must have a recycling plan, why not let them distribute the information along with existing instructions on other recyclables?

Summary

As a citizen of New Jersey, I worry that Senate Bill 564 will set New Jersey apart but not in a good way. It will raise costs and limit choices.

Thank you again for permitting me to testify on this important issue.

Linda K. Klose, Executive Director
New Jersey-Pennsylvania Council
AeA, Advancing the Business of Technology
732-340-1530
linda_klose@aeanet.org

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