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Environmental Design and Product Management

NEMA Member companies uniformly include sustainability and environmental considerations among their principal corporate values.  More than a decade ago, they joined in adopting a voluntary, industry-wide commitment known as the NEMA “Call to Action,” which was designed to reduce - and where possible eliminate - the use of certain toxic substances from electrical products.  This proactive initiative drew upon hazardous substance thresholds enacted in the European Union under the 2003 European RoHS Directive.  

Through the Call to Action, NEMA sought to ensure that NEMA products would comply with the RoHS thresholds in ALL markets in which they were sold, to the extent it was technically feasible to do so.  RoHS thus became a de facto global standard for the electro-product industry, highlighting NEMA's leadership in the environmental arena.

In addition to promoting environmentally sensitive design, NEMA supports proper management of spent products at end-of-life.  While most electro-industry products are long lived and used in commercial and industrial settings, others are consumer oriented and sold primarily for residential applications.  Some products require small amounts of hazardous substances to operate efficiently and meet  performance specifications.  These products must be handled properly at time of disposal, with collection and recycling being the optimal management choice.  For example, many widely used, energy efficient lamps operate on mercury-based technologies and NEMA Members avidly encourage recycling these products at end-of-life. 

In general, NEMA believes that policies governing end-of-life management of electrical products should stem from objective review of viable alternatives, guided by sound science and careful balance of costs and benefits.  The following document outlines the principles that should guide these determinations.  

NEMA EoL Policy Principles Oct 2018.pdf

NEMA recognizes that each stakeholder – manufacturers, distributors, retailers, consumers, and all levels of government – has a role and function to play in ensuring products are handled appropriately at end-of-life and none should bear the sole responsibility for collection and recycling programs.  On that basis, NEMA opposes  Extended Producer Responsibility (EPR) as a one-size-fits-all prescription for managing products in the waste stream. 

EPR is a more rigid, mandatory form of Product Stewardship, a broader sustainability concept that NEMA supports.  Most EPR proposals seek to impose virtually all legal and financial responsibility for collecting and recycling products onto manufacturers, even though producers have little, if any, control or authority over consumers at the time of disposal.  

NEMA Member companies currently fund and operate recycling programs for mercury-containing lamps, mercury-switch thermostats, and consumer batteries in various jurisdictions - each under a program framework crafted specifically for that product. 

Contact Mark Kohorst at NEMA Government Relations for information on recycling programs as well as NEMA's engagement on regulatory and legislative issues.


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