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Economic Impacts Assessment for

Revisions to the Export Provisions of Cathode Ray Tubes (CRTs) 

Final Rule

Office of Resource Conservation and Recovery

Office of Solid Waste and Emergency Response

U.S. Environmental Protection Agency

June 2013
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EXECUTIVE SUMMARY

With this Final Rule, the Environmental Protection Agency (EPA or the Agency) is 

revising the export provisions of the Cathode Ray Tube (CRT) final rule published on July 28, 

2006 (71 FR 42928). The purpose of these revisions is to address certain implementation 

concerns with the current export provisions in the 2006 rule. These changes will facilitate 

compliance with the requirements and will enable the Agency to obtain additional information 

on the export of this class of used electronics. This rule affects only the export provisions of the 

CRT rule. It does not affect any requirements applicable to domestic management of used 

CRTs. Nor does this action affect households or conditionally exempt small quantity generators 

(CESQGs). Therefore, entities potentially affected by today’s action are limited to those persons 

or companies who export used CRTs and CRT glass for reuse or recycling. 

In the proposed rule published on March 15, 2012, EPA proposed to add a definition of 

“CRT exporter” to the CRT rule, in order to clarify the responsibilities of brokers and other 

intermediaries in fulfilling the export notice requirements. EPA also proposed revising the 

notifications that must be submitted to EPA when CRTs are exported for reuse or recycling, 

while requiring that new annual reports now also be submitted by exporters of CRTs for 

recycling. Based on feedback from public comments and input from Agency workgroup 

members, all of the proposed rule changes were adopted for the final rule. In addition, this final 

rule also adopts requirements for the translation of foreign language business documents into 

English so that they may be more readily reviewed if necessary.

This document assesses the potential economic impacts of these final CRT Rule 

revisions.

Summary of Results

Given the minor changes being imposed by this rule, the results of our cost assessment 

reveal very modest cost impacts.

1) All exporters of CRTs (regardless of whether they are sending CRTs for Recycling or 

Reuse), will face a new one-time up-front cost to familiarize themselves with the new 

CRT rule requirements. This one-time cost is expected to be incurred by 140 CRT 

exporters.

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 The total one-time cost is estimated to be $42,904 in the first year following 

promulgation of the rule.

2) Exporters of CRTs sent for recycling will face a new requirement to produce and 

submit an Annual Report regarding their actual recycling exports. However, because 

this new requirement is expected to result in only approximately 12 new reports each 

 

1

 Please see Section 3.1 for more information about the number of entities used in the impact analyses to follow.
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year, the total cost to both exporters and EPA is very low and equals a total of just $2,454

per year. 

3) Added to these costs are additional annual costs to 140 Exporters of CRTs for reuse,

which range from $2,575 to $4,782 for adhering to the additional information 

requirements for Reuse Notices. These costs, in combination with the added costs for 

EPA's receipt and processing of these notices (estimated to be between $1,548 and

$2,876), brings the total annual cost for this feature of the rule to a range of 

approximately $4,123 to $7,658.

4) Finally, costs associated with translating normal business records into English (as 

necessary upon request) are estimated to range from $3,200 to $7,250 per year. 

In conclusion, the total estimated cost impacts from this rule are estimated to be $42,904

in year one only, plus annual costs in the range of $9,777 to 17,362, starting in year one and 

continuing each year thereafter. 
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TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Background on Existing Cathode Ray Tube (CRT) Rule

1.2 Need for Regulatory Action

2.0 OVERVIEW OF NEW REGULATORY REQUIREMENTS

2.1 Definition of “CRT Exporter”

2.2 Rule Changes Specific to the “Export of CRTs for Recycling”

2.2.1 New Annual Report Required by “Exporters of CRTs Sent for Recycling”

2.2.2 Additional Destination Data Requested as Part of the Recycling Notice

2.3 Changes Specific to the “Export of CRTs for Reuse”

2.3.1 Changes to Notification Requirements

2.3.2 English Translation of Normal Business Records

3.0 METHODOLOGY AND ASSUMPTIONS

3.1 Estimated Number of Potentially Impacted CRT Exporters

3.2 Labor Rate Estimates and Assumptions

3.3 Burden Hour Estimates and Assumptions

3.4 Material Cost Estimates and Assumptions

3.5 Notification Estimates and Assumptions

3.6 Estimated Type and Quantity of Normal Business Records Requiring Translation

3.7 English Translation Rates and Assumptions

4.0 ASSESSMENT OF POTENTIAL COSTS

4.1 Estimated Costs for Reading the Rule

4.2 Estimated Costs for New Annual Reporting by CRT Export Recyclers

4.3 Estimated Costs for Additional Reuse and Recycling Notification Requirements

4.4 Estimated Costs for English Translation of Normal Business Records

4.5 Total Cost Impact of the Proposed CRT Rule Revisions 

5.0 QUALITATIVE DISCUSSION OF BENEFITS

ATTACHMENT A: Supporting Documentation for Cost Assessments

Exhibit A-1: Estimated Costs for Reading & Understanding the New Rule Requirements

Exhibit A-2: Estimated Costs for Annual Reporting by Exporters of CRTs for Recycling

Exhibit A-3: Estimated Costs for Meeting Proposed Reuse Notification Changes

Exhibit A-4: Estimated Costs for Translating Foreign Language Records into English

ATTACHMENT B: Summary of Regulatory Flexibility Analyses
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1.0 INTRODUCTION

1.1 Background on Existing Cathode Ray Tube (CRT) Rule

The Agency promulgated the CRT rule on July 28, 2006 (71 FR 42928). In that rule, 

EPA amended its regulations under the Resource Conservation and Recovery Act (RCRA) to 

streamline management requirements for used CRTs and glass removed from CRTs, with the 

intent of encouraging their recycling and reuse. Under 40 CFR 261.39, these materials are 

excluded from the definition of solid waste if certain conditions are met. Used CRTs (intact or 

broken) sent for reuse and recycling are subject to the speculative accumulation requirements of 

261.1(c) (8). Facilities that send used, broken CRTs for recycling are subject to packaging and 

labeling requirements, as are CRT glass processors. CRT glass processors are also subject to 

speculative accumulation requirements and may not use temperatures high enough to volatilize 

lead.

In addition to these domestic requirements, the CRT rule also contains requirements (at 

40 CFR 261.39 (a)(5)) for used CRTs exported for recycling. Exporters of used CRTs for 

recycling must notify EPA of an intended shipment 60 days before the shipment. Notifications 

may cover exports extending over a 12-month or shorter period. The notification must include 

contact information about the exporter and recycler, and an alternate recycler. It must also 

include a description of the recycling, frequency and rate of export, means of transport, total 

quantity of CRTs, and information about transit countries.

With respect to used intact CRTs that are exported for reuse, 40 CFR 261.41 requires 

exporters to submit a one-time notification to EPA with contact information and a statement that 

they are exporting the CRTs for reuse. They must keep copies of normal business records 

demonstrating that each shipment will be reused. Records must be retained for three years from 

the date of export. 

1.2 Need for Regulatory Action

Since promulgation of the CRT rule in 2006, exports of CRTs and CRT glass have 

continued, whether for reuse or recycling. As EPA implemented the rule, two principal concerns 

became apparent. The first was that when CRTs and CRT glass are exported for recycling or 

reuse, several parties may be involved in the transaction. This multi-party involvement has 

sometimes led to confusion about which party is responsible for fulfilling the export notice 

requirements. The second concern involves CRTs that are ostensibly exported for reuse but that 

are actually disassembled and recycled when they reach the receiving country, sometimes under 

unsafe conditions. To address these concerns, EPA is adopting minor changes to the current 

CRT Rule as described in Section 2.0 below. 
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2.0 OVERVIEW OF NEW REGULATORY REQUIREMENTS

2.1 Definition of “CRT Exporter” (applicable to both CRTs for Reuse or Recycling)

When CRTs are exported for recycling or reuse, there are often several parties involved 

and this can cause considerable confusion over exactly who must file the export notices required 

under 40 CFR 261.39(a)(5)(for CRTs exported for recycling) and 40 CFR 261.41(for CRTs 

exported for reuse). To reduce this confusion, the Agency is adding a definition of “CRT 

exporter” to 40 CFR 260.10, which states that a CRT exporter is “any person or entity in the 

United States who initiates a transaction to send used CRTs outside the United States and its 

territories for recycling or reuse, or any intermediary in the United States arranging for such 

export. The reference to “any intermediary arranging for the export” is modeled on the 

definition of “primary exporter” of hazardous waste in 40 CFR 260.10. As described above, 

there may be multiple parties who participate in the exporting of CRTs. To avoid duplicative 

submissions, the Agency expects only one party for a given export shipment to perform the 

exporter duties under 40 CFR 261.39(a)(5) and 40 CFR 261.41 Lastly, EPA emphasizes that 

this definition would clarify rather than change current liability for violations of the CRT export 

requirements. [Note: EPA considers there to be no economic costs associated with this 

definitional change.]

2.2 Rule Changes Specific to the “Export of CRTs for Recycling”

Under the provisions of this rule, parties that “Export CRTs for purposes of Recycling”

shall face the following additional requirements.

2.2.1 New Annual Report Required from Exporters of CRTs Sent for Recycling

Per the existing CRT Rule, parties that export CRTs for recycling currently have 

notification requirements regarding their projected exports, but are not required to submit 

any retrospective documentation regarding the amount of their actual exports in a given 

year. To help ensure that CRTs exported for recycling are handled as commodities and 

not otherwise discarded, EPA is requiring that such parties now submit Annual Reports 

of their exports. [Note: This annual report requirement has been modeled after the annual 

report required for exporters of hazardous waste under 40 CFR 262.56 (Also see cited 

reference and web URL provided in Footnote 2).]

2.2.2 Additional Destination Data Requested as Part of the Recycling Notice

Per the current CRT Rule (40 CFR 261.39(a)(5)(F)), exporters of CRTs sent for 

recycling are required to state the name and address of the recycler and any alternate 

recycler. Because CRTs are sometimes exported to more than one recycler in the 

receiving country, EPA is now requiring that the exporter state the name and address of 

the recycler or recyclers and the estimated quantity of CRTs to be sent to each facility, as 

well as the names of any alternate recyclers. In this way EPA will be able to provide the 
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receiving country with the most accurate information available about the ultimate fate of 

the CRTs entering their country.

2.3 Changes Specific to the “Export of CRTs for Reuse”

Under the provisions of the final rule, parties that “Export CRTs for Reuse” shall face the 

following additional requirements.

2.3.1 Changes to Notification Requirements

Per the current CRT Rule, exporters of CRTs sent for reuse are already required 

to submit a one-time notice to EPA with minimal information under 40 CFR 261.41. 

Since original promulgation of this requirement, the Agency has become aware that some 

CRTs, ostensibly exported for reuse, are actually recycled in the receiving country, 

sometimes under unsafe conditions. In response, EPA is expanding the current reuse 

notice to provide more complete information about the potential reuse of the exported 

CRTs. The added items to the reuse notice are modeled on those required in the notice 

for CRTs exported for recycling, and will help the Agency determine whether exported 

CRTs are actually products which are ultimately sent for reuse. [Note: For more detail 

on the additional data elements that are being proposed for the CRT Reuse Notice, please 

see the appropriate section of the preamble for the Final Rule.]

[Note: For each export shipment, the Agency expects only one party to perform the 

exporter duties under 40 CFR 261.39(a)(5) and 40 CFR 261.41 (notifications to EPA, and 

the annual reports as proposed and described above).]

2.3.2 English Translation of Normal Business Records

Under § 261.41(b), persons who export CRTs for reuse must keep copies of 

normal business records, such as contracts, demonstrating their exported CRTs will in 

fact be reused. The documentation must be retained for a period of at least three years 

from the date the CRTs were exported. In the March 2012 proposal, EPA requested 

comment regarding whether to require persons who export CRTs for reuse to provide a 

third-party translation of the documents into English if the documents are written in a 

language other than English and if EPA requests such a translation. EPA believes that 

requiring CRT exporters to provide an English translation of normal business records 

upon request by EPA is inherent in the demonstration that each shipment of CRTs will be 

reused. English translation will also assist with compliance monitoring of this provision. 

Specifically, the regulatory language reads:

[(b) CRT exporters of used CRTs for reuse must keep copies of normal business 

records, such as contracts, demonstrating that each shipment of exported CRTs 

will be reused. This documentation must be retained for a period of at least three 

years from the date the CRTs were exported. If the documents are written in a 

language other than English, CRT exporters of used CRTs for reuse must also 
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provide a third-party translation of the normal business records into English upon 

request by EPA.]

[Note: Normal business records are further described in the preamble of the CRT Rule to 

be “contracts, invoices, and bills of lading” which “would likely contain the appropriate 

information for meeting the various requirements of the rule.”]

3.0 METHODOLOGY AND ASSUMPTIONS

Described below are the key data and assumptions underlying the cost analyses that were 

conducted for the final rule. 

In assessing the cost impacts, we estimated the incremental annual costs of the final

requirements upon U.S. exporters, as well as EPA. In estimating these costs, EPA first reviewed 

the provisions under the existing regulations and the new requirements being enacted in this 

rule. We estimated the costs of these new requirements using the following inputs:

 Number of affected entities 

 Hourly labor rates

 Burden hours

 Material costs

 Number of Annual Reuse/Recycling Notifications

 Number & type of normal business records requiring translation

 Costs for English translation services 

Section 3.1 describes the sources used in identifying the “number of entities” involved in 

the exporting of CRTs who will be directly affected by this Final Rule. Section 3.2 describes the 

“hourly labor rates” that are used in our calculations. Section 3.3 describes the “burden hours” 

(e.g. staff hours) assumptions that EPA utilized in its analysis. Section 3.4 outlines the 

“material” costs that EPA envisions may be incurred in association with the Final CRT Rule 

requirements. Section 3.5 details the total “number of reuse and recycling notices” that EPA 

projects will be submitted per year. Lastly, Sections 3.6 and 3.7 outline available information

collected as necessary to develop cost estimates for meeting the additional rule requirement that 

calls for the English translation of normal business records by “Exporters of CRTs for Reuse”

upon request.

Underlying unit costs discussed in Sections 3.1 through 3.5, as well as the estimated costs 

explained later in Sections 4.1 through 4.3, were previously developed as part of the Economic 

Impact Assessment (EIA) conducted in November of 2011 for the initial proposed CRT rule. 

For purposes of consistency and simplicity, the unit costs for the earlier estimated costs of these 

specific requirements remain unchanged. EPA did not receive any public comments on the 2011 

EIA that would have called for revising the unit cost estimates. Also, because there was very

little inflation between November, 2011 and now, the Agency decided that adjustments to certain 

of the 2011 estimates were unnecessary. 
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Sections 3.6, 3.7, and 4.4 cover the underlying assumptions and estimated costs 

associated with the additional rule requirement that calls for English translation of normal 

business records as necessary upon request for those who “Export CRTs for Reuse”. The cost 

estimates associated with this new requirement are therefore newly developed and were not 

covered in the earlier EIA for the proposed rule. 

3.1 Estimated Number of Potentially Impacted CRT Exporters

For the proposed rule, the Agency estimated that a total of approximately 12 entities 

exported CRTs for recycling during 2011 (i.e., per EPA data on the number of approved 

exporters and the number of export notices that were submitted during 2011). Based on the 

number of CRT Reuse Notifications submitted during 2011, there existed approximately 126 

CRT exporters for reuse in the U.S. (i.e., based on Sept. 14th, 2011 CRT data published on EPA’s 

website at [http://www.epa.gov/epawaste/hazard/international/crts/recycling.htm]).

As of 2013, the number of entities who export CRTs for recycling appears to have 

dropped from a total of 12 in 2011 to 4 in 2013. As in 2011, the number for 2013 is based on the 

current number of export notices and associated consents received from CRT recyclers in 2013. 

While this is an excellent barometer for the current number of subject exporters, EPA has chosen 

to use the larger 2011 estimate of 12 for the number of “Exporters of CRTs for Recycling”, as a 

more conservative number for the purposes of the current EIA. 

Evaluation of updated 2013 data from the same sources used in our 2011 analyses, 

reveals that the number of potentially impacted “CRT Exporters for Reuse” has not changed 

dramatically from that of 2011. The number of “Exporters of CRTs for Reuse” has risen from 

126 entities to just 140 since 2011. However, there is no means within the Agency’s tracking 

system for officially identifying who has exited from the business of exporting CRTs for reuse. 

As a result, there is no clear way to confirm with certainty how many practicing CRT reuse 

exporters there are at any given point in time. We have therefore adopted the more recent 2013 

estimate of CRT reuse exporters for this EIA. As a result, all newly added or modified estimates

within this EIA are based on the larger estimates of exporters, based on either 2011 or 2013 data. 

As such, we assume that there are 12 Recycling Exporters and 140 Reuse Exporters.

3.2 Labor Rate Estimates and Assumptions

Exhibit 3-1 presents the hourly labor rates used in this analysis. As shown in the exhibit, for 

U.S. exporters, EPA estimated an average hourly labor rate (including fringe and overhead) of 

$103.84 for managerial staff, $64.71 for technical staff, and $33.85 for clerical staff. These labor 
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rates were originally obtained by relying on prior EPA Cost Assessments and then updated to 

2011 using Employment Cost Indices developed by the U.S. Bureau of Labor Statistics.2

For EPA’s involvement and review/approval responsibilities, we estimated an average 

hourly labor rate of $74.67 for managerial staff (GS-14, Step 1), $63.20 for technical staff (GS13, Step 1), and $36.64 for clerical staff (GS-9, Step 1). To derive these hourly estimates, we 

referred to the General Schedule (GS) Salary Table 2011. This publication summarizes the 

unloaded (base) hourly rate for various labor categories in the Federal Government.3 We then 

applied the standard government overhead factor of 1.6 to the unloaded rate to derive loaded 

hourly labor rates.

Exhibit 3-1

Average Hourly Labor Rates Used to Assess the Cost Impacts of the Rule

Labor Category Exporters

(2011 dollars)

EPA

(2011 dollars)

Managerial $107.06 $74.67

Technical $70.08 $63.20

Clerical $36.60 $36.64

 

2

 To obtain hourly labor rates for this EIA, we relied on readily available cost analyses conducted for the SLAB Rule 

(which in turn also relied on labor rates from an earlier relevant EPA Cost Assessment from September 27, 2004 

(revised February 24, 2005) titled, “ Cost Assessment in Support of the Proposed Rule on exports and Imports of 

Hazardous Waste Destined for Recovery among OECD Countries”). To update the 2007 hourly rates (used in the 

SLAB Rule Cost Assessment) to 2011 levels, EPA referred to Table 9. Employment Cost Index for Wages and 

Salaries, for Private Industry Workers by Occupation Group and Industry (Not seasonally adjusted) of Employment 

Cost Index: Historical Listing (December 2005 = 100), U.S. Bureau of Labor Statistics (Oct. 28, 2011). This table 

presents employment cost indices for private industry workers, by annual quarter (i.e., for March, June, and 

September). EPA used the June 2007 Index (105.1) from the SLAB Rule Cost Analyses, in combination with the 

June 2011 Index (113.8) to develop an adjustment factor of 1.083 (i.e., 113.8 / 105.1 = 1.083 ). Available at: 

http://www.bls.gov/ncs/ect/home.htm.

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“Loaded hourly rate” is defined as the direct hourly labor rate along with appropriate load factors, inclusive of 

profit or fees. Other load factors include overhead, fringe, and general & administrative (G&A) costs. Loaded 

hourly rates are therefore inclusive of both the direct costs and indirect costs characterized as follows: 

 Direct Costs are costs created and necessitated by the existence of a project or contract (Consultant working on a contract):

Calculate the Hourly Labor Rate (annual salary divided by billable hours

Calculate Fringe Benefit Costs and prorate per employee

 Indirect Costs are costs that are occurring even if there is no project or contract in place:

Labor costs of support staff: human resources, budget, computer help desk, and management/administrative

Costs of operating the office: rent, utilities, equipment depreciation, repairs, maintenance, and other costs

These indirect costs (overhead) are added up and distributed to the direct costs by using calculated overhead rate.

To calculate Overhead Rate divide Indirect Costs by Direct Costs
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3.3 Burden Hour Estimates and Assumptions

As with other components of the methodology underlying our analyses, to estimate the 

total number of hours (“burden hours”) required to meet the annual notification and reporting 

requirements of this rule, EPA relied heavily upon previous cost analyses conducted for the 2009 

SLAB Rule (See Footnote 1). Since the new CRT annual reporting and notification 

requirements are nearly the same as those called for in the Agency’s 2009 SLAB rule, we used 

the same burden hour estimates in our cost assumptions for this proposal. 

3.4 Material Cost Estimates and Assumptions

Minimal material costs were assumed to be associated with the production and 

submission of new Annual Reports and Notification requirements for this revision of the CRT 

Rule. These costs are described below:

 Mailing costs: The Agency estimated that affected entities would incur a cost of 

approximately $5.20 to mail a five ounce package by certified mail ($2.20 for 

postage, $2.85 for the certified mail fee, and $0.15 for a 9 x 12 manila envelope). 

Affected entities are expected to incur a cost of $0.49 for each standard letter mailed 

($0.44 for first class postage and $0.05 for a standard envelope). 

 Copying Costs: The agency estimated that affected entities would incur a cost of 

$0.11 per page for copying. 

 Faxing costs: The Agency estimated that affected entities would incur a cost of $0.15 

for each international fax they send. This cost was derived from the average revenues 

per minute for a telephone call from the U.S. to an OECD Country (excluding Canada 

and Mexico). Revenue figures were obtained from the 2005 International 

Telecommunications Data Report issued by the Federal Communications 

Commission on April 24, 2007. The cost estimate assumes that the fax transmission 

will take one-minute. 

 Domestic telephone call costs: The Agency estimates that affected entities will incur a 

cost of $0.90 for each domestic telephone call they make. This cost was derived by 

averaging the advertised rates of a 15-minute State-to-State telephone call from four 

large U.S. long distance carriers. 

3.5 Notification Estimates and Assumptions

The number of export notifications used in our cost assessment was based on EPA’s 

professional experience, in combination with historical records associated with the submission of 

reuse/recycling notices by CRT exporters. 

In EPA’s experience, most CRT recyclers seldom have cause to submit more than 1

notice per year. The number of Recycling Notices has never exceeded 60% of the number of 

Recycling Exporters themselves. This means that the ratio of Recycling Notices to CRT 
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Recycling Exporters is less than 2 to 1. So, while the number of notices may increase 

subsequent to the proposed rule, EPA assumed for the purposes of this analyses that each CRT 

recycler would submit only 1 to 2 notices annually. Accordingly, this results in approximately

12 to 24 Notices being submitted per year for this category of exporters.

Exporters that send CRTs abroad for purposes of reuse tend to have a broader list of 

potential destinations for their CRTs. For instance, one reuse exporter may ship their CRTs to 

schools, charitable organizations, and resale facilities, or any combination thereof. Therefore, 

for purposes of this analysis, EPA assumed:

 75% of reuse exporters (105) would submit 2-4 reuse notifications per year; and 

 25% of reuse exporters (35) would submit 1 reuse notification per year. 

When added together with the projected recycling notices, the total estimated number of 

notices ranges from 245 to 455. 

3.6 Estimated Type and Quantity of Normal Business Records in Need of Translation

As discussed above, 40 CFR 261.41 requires exporters of used intact CRTs to submit a 

one-time notification to EPA with contact information and a statement that they are exporting the 

CRTs for reuse. They must also keep copies of normal business records demonstrating that each 

shipment will be reused. These records must be retained for three years from the date of export. 

The only change to these requirements in this Final Rule, calls for English translation of any 

business records written in a foreign language that help document their shipments are being 

reused. 

Such translations would only be required upon request. However, in reality there may be 

relatively few such foreign records that require English translation. All of the U.S. source 

documents as well as much of the return documentation from abroad are presumed to already be 

written in English. All one-time notifications by U.S. exporters should already be in English, as 

well as any of their own U.S. based business records. This only leaves business records that may

originate from receiving countries that are then retained by the U.S. exporters as evidence that 

their shipped CRTs are in fact being reused. But, it is also reasonable to assume that many of 

these records from foreign countries would already be written in English. 

Unfortunately, there are no records available on the actual number of CRT exports for 

reuse that occur annually. In fact, the collection of such data is a primary objective of the 

requirements being called for under this final rule. In the absence of this data, EPA uses the 

estimated number of reuse notifications (discussed in Section 3.5 above) as a direct proxy for the 

number of shipments that also occur each year. Based on information from regional experts on 

the Agency’s Workgroup for this rule, EPA conservatively assumes that approximately 25

percent of exporters and their export shipments would be subject to review in any given year. 

Moreover, we also assume that as many as 50% of these export shipments may be subject to 

review and might ultimately require some limited translation of their business records into 

English. EPA further assumes that either 1 return invoice, 1 return bill of lading or similar 
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would be provided to the exporter for each shipment sent abroad (as evidence of the shipped 

CRTs going for reuse). 

With these as our underlying assumptions, the number of such invoices and billing 

documents that would require translation annually is approximately 32 to 58, which represents a 

combined total of the calculations as shown below:

 75% of the 140 current reuse exporters (105) are assumed to conduct 2-4 reuse shipments 

per year, 25% of which are audited, with 50% of those requiring translation of just 1 

document,

[(105)(2 to 4 shipments per yr)(.25 audits)(.50 foreign)(1 document/shipment) 

= 27 to 53 potential documents needing translation]; 

 25% of the 140 current reuse exporters (35) conduct only 1 reuse shipment per year, 25% 

of which are audited, with 50% of those requiring translation of just 1 document,

[(35)(1 shipment per yr)(.25 audits)(.50 foreign texts)(1 document/shipment) 

= 5 potential documents needing translation]. 

3.7 English Translation Rates and Assumptions

Pricing for translation projects and services can vary widely and depend on several 

factors including for example; the number of source words, the complexity of the subject matter, 

the combination of languages, the amount of turnaround time for completion, and the need for 

special formating and processing requirements, etc.

To gauge the ultimate rates that might be charged in the case of CRT export records, online resources and rate quotes were relied upon.

4

 Costs were generally based on an hourly rate or 

by the number of source words in the document to be translated. Rates were highly dependent 

upon the type of languages that were being translated. One vendor supplied a quote (specifically 

tailored to the translation of shipping receipts and contractual types of documents from Spanish 

into English) of 18 cents, 22 cents, and 38 cents per word depending upon the necessary

turnaround time. Since the final rule allows for up to 30 days for CRT exporters to provide 

English translation upon request, this RIA does not assume costs associated with rushed 

turnaround. Therefore, we used a baseline cost of 20 cents per word for basic translations of 

foreign languages such as Spanish. 

For the purpose of our analyses, Spanish was assumed to be the predominant text 

requiring translation, since many exports of CRTs for reuse and recycling go to Mexico and 

South America. However, the cost may be higher for translation of more complex Asian and 

African texts. To account for this, we conservatively assume that these costs could double to as 

high as 40 cents per word. To arrive at a range of ultimate costs, the low range assumes that 

 

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Rate Quote requested on May 29, 2013 at “www.betranslated.com”, for Spanish translation of basic contracts, 

bills of lading, shipping documents, and purchase & sales agreements, as well as descriptions of computer 

materials. Additional on-line resources were also consulted for rates and terms at www.trustedtranslations.com, 

etc.
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there are no high cost translations necessary, while the upper bound estimate assumes that as 

many as 1⁄2 of the documents may require translations at the higher rate. As such, at the low end 

our cost remains at 20 cents per word and goes to 25 cents per word on average under the high 

end of our cost range.

4.0 ASSESSMENT OF POTENTIAL COSTS

Discussed below is the Agency’s best projection of the costs associated with this final 

rule. Since the subject provisions currently being proposed apply only to the export of CRTs , 

U.S. importers will not experience any costs from these revisions. 

4.1 Estimated Costs for Reading the Rule

As noted above, the Agency estimates that a total of approximately 12 entities exported 

CRTs for recycling and 140 entities exported CRTs for reuse. Therefore, we estimated that 152

U.S. exporters will need to read the rule in order to understand and comply with the new 

requirements. For purposes of this analysis, we assumed that the hours required for 

reading/reviewing this new rule would be similar to the hours used in EPA’s assessment of the 

impacts associated with reading/reviewing the 2009 SLAB rule. The one-time cost for of 

reading/reviewing this new rule was then estimated to be $282.26. (See Exhibit A-1in

Attachment A). 5Thus, U.S. exporters may experience a one-time cost of approximately

$42,904 (i.e., 152 entities x $282.26/entity) for this activity.

4.2 Estimated Costs for New Annual Reporting by CRT Export Recyclers

Under this rule, U.S. entities who export CRTs for the purpose of recycling must now 

submit detailed annual reports on their CRT exports to EPA. This annual reporting is in addition 

to the current notice requirements and represents a new requirement for CRT Recycling 

Exporters not called for in the current CRT Rule. The following paragraphs discuss the 

estimated costs associated with this newly required annual report. 

U.S. Exporters of CRTs for Recycling

As noted above, EPA estimates that approximately 12 U.S. exporters of CRTs sent for 

recycling will be required to prepare and submit an annual report in accordance with this 

provision of the proposed rule. Furthermore, this new annual report for CRT Export Recyclers 

has been fashioned after other existing annual reporting requirements recently codified in the 

2009 Final Rule governing the Exporting of Spent Lead-Acid Batteries (SLAB) from the U.S. 

Therefore, EPA used the cost estimates for annual reporting already available in the May 2009 

Cost Assessment prepared for the “SLAB Rule”, as the best and most relevant reference (See 

Footnote 2). Based on these figures, EPA estimates that the cost for a CRT Exporter to prepare 

 

5

Estimated costs for Reading the Rule were drawn from the May 2009 Cost Assessment for the Final Rule on 

Exports and Imports of Hazardous Waste Destined for Recovery Among OECD Countries, Exports of Spent LeadAcid Batteries from the U.S., and Import Consent Documentation. 
15

and submit an annual report ranges from $156.07 to $203.36, depending upon whether the size of 

the exporter is large vs. small. For purposes of analysis, EPA assumed a 50/50 distribution of 

these exporters (e.g. with half considered large and half considered small). Thus, EPA estimated

that the total cost of the annual reporting requirement for exporting CRTs for recycling is 

$2,158 (i.e.,$203.36/ annual report x 6 Large Recycling Exporters, plus $156.07 / annual report x 

6 Small Recycling Exporters) (See Exhibit A-2 in Attachment A).

EPA 

EPA estimates that it will receive 12 annual reports per year. EPA estimates that it will 

incur $24.64 to receive and record each annual report (See Exhibit A-2 in Attachment A). Thus, 

EPA estimates that the Agency will experience an annual cost of $296 (i.e., 12 annual 

reports/year x $24.64/report) to meet this requirement of the proposed rule. 

In total, the estimated cost to CRT Exporters and the EPA for the new annual reporting 

requirement for recyclers totals $2,454 per year (See Exhibit A-2 in Attachment A). 

4.3 Estimated Costs for Additional Reuse and Recycling Notification Requirements

Under the current CRT Rule, exporters already must submit notifications to EPA 

indicating their intent to export CRTs. As noted above, the final CRT Rule revisions call for 

very minor additional reporting elements to the current CRT rule requirements. The following 

paragraphs discuss the estimated costs associated specifically with the added notification 

elements for reuse notices. [Note: In the case of Recycling Notices, only one additional data 

element has been added. As such, the subject cost attributable to this change is considered 

DeMinimus and does not appear in any of the following impact analyses.]

U.S. Exporters of CRTs for Reuse

To calculate the notification-related cost impacts, EPA started by relying on the original 

burden hour estimates associated with the current notification requirements. EPA then adjusted 

these burden hour estimates to reflect our best estimate of the potential burden associated with 

the proposed changes in the notification requirements. Our best estimate is that these burden 

estimates would not exceed 10% of the burden attributable to the current notification 

requirements. Then EPA utilized the adjusted burden estimates and labor rates in combination 

with the projected quantity of CRT Notices to derive costs associated with the relevant proposed 

changes to the CRT notification process.

Based on the assumptions and calculations above, EPA estimated that CRT reuse 

exporters submit between 245 and 455 notices each year. We estimated that each notice will 

cost an additional $10.51 (See Exhibit A-3 in Attachment A). In total, EPA estimates that the 

additional costs to Exporters will be in the range of $2,575 to $4,782 (i.e., 245 to 455 notices per 

year x $10.51 per notice) under the final rule. 

EPA 

We estimate that EPA will incur an additional cost of $6.32 per notice to receive and 

process these notices (See Exhibit A-3 in Attachment A). Thus, we estimate that the Agency will 
16

experience a total incremental annual cost in the range of $1,548 to $2,876 (i.e., 245 to 455 

notices per year x $6.32 per notice) under the final rule. 

In total, the estimated costs to CRT Exporters and the EPA for meeting the proposed 

reuse and recycling notification changes are $4,123 to $7,658 per year (See Exhibit A-3 in 

Attachment A). 

4.4 Estimated Costs for English Translation of Normal Business Records (by 

“Exporters of CRTs for Reuse”)

In accordance with the rule’s definition of “normal business records,” several types of 

documents may need to be translated into English, such as contractual agreements. However, 

since the rule only requires translation of documents sufficient to demonstrate that the CRTs are 

ultimately shipped for purposes of reuse, exporters in most cases will choose not to conduct more 

costly and unnecessary translations of voluminous contract documents. EPA assumes rather, that 

any translations will be restricted to smaller-sized documents with an average word count of 

approximately 500 words, such as shipping receipts or pertinent excerpts only, from relevant 

contracts. 

As noted above, the Agency estimates that during 2013a total of approximately 140

entities exported CRTs for reuse. For purposes of this analysis, we established that as many as 

approximately 32 to 58 business records would need to be translated into English for review. 

The costs for such translations can be expected to vary widely depending upon the size of the 

exporter, the number of shipments and alternative destinations, and the quantity and complexity

of the normal business records associated with their reuse shipments abroad. Therefore as might 

be expected, the range of annual translation costs for these exporters are estimated to range from 

$3,200 to $7,250. (See Exhibit A4 in Attachment A).

4.5 Total Cost Impact of the Proposed CRT Rule Revisions

In total, EPA estimates that the costs of the proposed CRT Rule revisions include approximately

$42,904 in year one of the Rule, as well as annual costs in the range of $9,777 to 17,362 per year 

(starting in year one and continuing each year thereafter). Many of the assumptions used in the 

analysis may be characterized as “conservative.” Therefore these cost estimates are likely to be 

higher than in actuality. 

5.0 QUALITATIVE DISCUSSION OF BENEFITS

Promulgation of this rule will engender benefits, both internal and external to the U.S., 

including: (1) increased regulatory efficiency; (2) reduction of risks associated with treatment 

and disposal of hazardous wastes; (3) improved ability to acquire information regarding the 

quantities of CRTs exported from the U.S. and the destination facilities to which the CRTs are 

exported; and (4) better tracking of compliance with the terms of CRT export notices. 
17

More specifically, these CRT Rule revisions will help determine whether CRTs exported 

for recycling and reuse are handled as commodities and not inappropriately discarded. Such 

annual reports and notification enhancements improve the accuracy of our records and allow for 

proper documentation of the total amount of CRTs being exported for recycling and reuse. The

improved data that shall be collected will also enable EPA to compare actual vs. proposed 

shipments to ensure that these shipments are occurring under the terms approved by the receiving 

country. Finally, such data will enable EPA to provide summary information, if requested by a 

receiving country, which would assist the receiving country in better management of their CRT 

imports. 

In conclusion, while these benefits have not been expressly quantified as part of this 

Economic Assessment, the resultant improvements in information provision/transparency and 

CRT management practices from this Rule are believed to have benefits that significantly

outweigh its costs. 
18

ATTACHMENT A

SUPPORTING DOCUMENTATION

FOR COST ASSESSMENTS
19

Exhibit A-1

Estimated Costs for Reading & Understanding the New Rule Requirements

Cost per Entity Cost of All Entities

Activity Managerial 

Staff Hours a

Technical Staff 

Hours a

Clerical Staff 

Hours a

Hours Labor 

Cost b

Materials 

Cost c

Total Cost

per Entity

Number of 

Entities d

Total Cost 

Reading the Regulations 

U.S. Exporters 1.00 2.50 0.00 3.50 $282.26 $0.00 $282.26 152 $42,904

NOTES:

a

 Based on hourly burden estimates discussed in Section 3.3 above. 

b

 Based on hourly labor rates discussed in Section 3.2 above.

c

 Based on materials costs discussed in Section 3.4 above.

d

 Based on universe assumptions discussed in Section 3.1 above.
20

Exhibit A-2

Estimated Costs for New Annual Reporting by Exporters of CRTs for Recycling

Cost per Entity Cost for all Entities

Activity Managerial 

Staff Hours a

Technical Staff 

Hours a

Clerical Staff 

Hours a

Total 

Hours

Total Labor 

Cost b

Material 

Cost c

Total 

Cost

Number of 

Entities d

Total Cost 

Annual Report

Large U.S. Exporters

Research specific export 

information

0.00 1.00 1.00 2.00 $106.68 $0.00 $106.68 6 $640.08

Prepare and submit report 0.10 1.00 0.30 1.40 $91.77 $5.20 $96.97 6 $581.82

Subtotal: $198.45 $5.20 $203.65 6 $1,221.90

Small U.S. Exporters

Research specific export 

information

0.00 0.50 0.50 1.00 $70.08 $0.00 $70.08 6 $420.48

Prepare and submit report 0.10 0.50 0.50 1.10 $80.79 $5.20 $85.99 6 $515.94

Subtotal: $150.87 $5.20 $156.07 6 $936.42

Total for Exporters: $2,158.32

EPA

Receive and record report 0.00 0.10 0.50 0.60 $24.64 $0.00 $24.64 12 $295.68

Total for EPA: 0.00 0.10 0.50 0.60 $24.64 $0.00 $24.64 12 $295.68

TOTAL:

(for both Exporters & EPA) $2,454

NOTES:

a

 Based on hourly burden estimates discussed in Section 3.3 above. 

b

 Based on hourly labor rates discussed in Section 3.2 above.

c

 Based on material costs discussed in Section 3.4 above.

d

 Based on universe assumptions discussed in Section 3.1 above, which reveal a total of approximately 12 CRT Recycling Exporters in the U.S. And, we assume there is a 

50/50 Percent Ratio regarding the total number of Large vs. Small U.S. CRT Exporters, such that there are 6 of each type in the above calculations.
21

Exhibit A-3

Estimated Costs for Meeting Proposed Reuse Notification Changes

(calling for minor additional information)

Cost per Notice Cost of All Notices

Activity Manager

Staff 

Hours a

Technical 

Staff 

Hours a

Clerical 

Staff 

Hours a

Total Hours b

(10% of Orig. 

Hours)

Total 

Labor 

Cost c

Total 

Material 

Costs

d

Total 

Cost per 

Notice

Number 

of 

Entities e

Estimated 

Number of 

Notices f

Total Cost 

U.S. Exporters of CRTs for Reuse

Prepare & submit notification Subtotal for Exporters: 0.00 1.50 0.00 0.15 $10.51 $0.00 $10.51 140 245 to 455 $2,575 to $4,782

EPA

Receive and process notifications 0.00 1.00 0.00 0.10 $6.32 $0.00 $6.32 140 245 to 455 $1,548 to $2,876

Total for both Exporters & EPA 0.00 2.50 0.00 0.25 $16.83 $0.00 $16.83 140 245 to 455 $4,123 to $7,658

Notes:

a

 Staff level hourly burden estimates are discussed in Section 3.3 above.

b

 Total final hourly burden estimates are conservatively assumed to only involve an additional burden equal to 10% of the overall burden from

the notification requirements under the current CRT Rule. 

c

 Based on hourly labor rates discussed in Section 3.2 above.

d Since entities are already required to submit Recycling and Reuse Notices, the effected entities face no additional costs associated with mailings, 

copies, facsimiles, etc. due to the newly proposed modifications to the existing notices.

e

 The projections for the total number of entities potentially impacted by the rule are discussed in Section 3.1 above.

f

 The projections for the total number of notifications that may be submitted annually is discussed in Section 3.5 above.

.
22

Exhibit A-4

Estimated Costs for Translating Foreign Language Records into English

Breakout of 

Entities that 

Conduct More vs. 

Less Annual 

Shipments of CRTs 

for Reuse a 

Assumed Number 

of Shipments 

per Year 

(Equals Assumed 

Number of 

Business Records 

that Must be 

Retained 

per Year 

b 

Assumed 

Percentage of 

Shipment

Records 

Potentially 

Subject to an 

Audit and 

Review c 

Assumed 

Proportion of 

Audited 

Records that 

are in Foreign 

Text and 

Require 

English 

Translation c 

Estimated 

Number of 

Business 

Records that 

will Need 

Translation c

Average 

Word Count 

per 

Record 

Translated c

Total Estimated 

Unit Cost 

per Word Count 

& Level of 

Complexity d

(Low Estimate) 

of Total Cost 

per 

Record 

Translated

(High Estimate) 

of Total Cost 

per 

Record 

Translated 

Total Estimated 

Range of Costs 

Per Year 

105 

(or 75% of 140) 

Entities Make 2 to 

4 Shipments per 

Year

2 to 4 25 % 50 % 27 to 53 500 $ 0.20 to $ 0.25 $100 $125 $2,700 to $6,625

35 

(or 25% of 140) 

Entities Make Only 

1 Shipment

1 25 % 50 % 5 500 $ 0.20 to $ 0.25 $100 $125 $500 to $625

Totals 1 to 4

Overall Totals: 1 to 4 NA NA 32 to 58 NA NA NA NA $3,200 to $7,250

NOTES:

a Based on using the assumed number of reuse notifications (presented in Section 3.5) as a direct proxy for the number of annual shipments potentially subject to review.

b

 Based on assumption that every shipment will only need 1 English language business record as documentation/proof that their CRTs were shipped for purposes of reuse. 

C

 See Section 3.6 for further explanation of underlying assumptions and the estimated quantity of Normal Business Records that will Need Translation.

d

 Based on range of potential costs for attaining third party translation of foreign language documents into English, as discussed in Section 3.7 above.
23

Attachment B

Summary of Regulatory Flexibility Analyses

Conducted in Coordination with the

Economic Impacts Assessment for Revisions to the

Export Provisions of the Cathode Ray Tube (CRT) Final Rule

1.0 Regulatory Flexibility Act Requirements

The Regulatory Flexibility Act of 1980 (RFA), as amended by the Small Business

Regulatory Enforcement Fairness Act of 1996 (SBREFA), requires EPA to prepare a regulatory

flexibility analysis for any rule that will have a significant economic impact on a substantial 

number of small entities (i.e., small businesses, small governments, and small non-profit 

organizations). However, a regulatory flexibility analysis is not required if the Administrator 

certifies that the rule will not have a significant economic impact on a substantial number of 

small entities. SBREFA further requires EPA to provide a statement of the factual basis for 

certifying that a rule will not have a significant economic impact on a substantial number of 

small entities. 

2.0 Summary Discussion of Analyses and Results

In the Nov. 2011 Economic Impact Assessment (EIA) for the proposed CRT rule, the 

Agency examined the rule's potential effects on small entities as required by the RFA/SBREFA. 

At that time, we determined that the rule would not result in a significant impact on a substantial 

number of small entities. This determination was made by comparing annual compliance costs 

under the rule to the relative average annual sales of small businesses in the industrial sectors 

most likely to be affected by the rule. Summarized below is a description of our earlier analyses, 

as well as a discussion of the minimal change in the overall economic impacts associated with 

this final rule. 

According to the U.S. Small Business Administration's small business size standards, 

firms in most of these industry sectors are classified as a "small business" if they have fewer than 

750 employees. However, for purposes of this analysis, we determined that this threshold may

be too high and could mask the potential effects on the smallest, most vulnerable firms. 

Therefore, the Agency relied upon a far more conservative approach and selected a threshold for 

firms with fewer than 20 employees instead of the official standard of 750. 

As summarized in the Executive Summary of the Economic Impact Assessment 

conducted in Nov. 2011 for the proposed revisions to the Export Provisions of the Cathode Ray

Tube (CRT) Rule, the estimated costs of the rule were shown to be very low. Our analyses 

found that only approximately 138 CRT Exporters would be affected by the proposed revisions 

(including roughly 12 whom export CRTs for recycling with the remaining 126 exporting CRTs 

for purposes of reuse). 
24

The subject rule revisions vary for those exporters that recycle vs. those that reuse CRTs. 

The baseline annual compliance costs for all CRTs exporters (including both those that export 

for purposes of recycling and/or reuse) ranged from $2,286 to $4,453 in the baseline. Then, an 

additional total annual cost of approximately $2,500 is incurred by just those 12 firms that export 

CRTs for recycling. Lastly, the one-time cost expected to be incurred by all exporters to 

familiarize themselves with the rule totaled $39,000. When annualized and considered on a per 

facility basis, the costs for “CRT Reusers” ranges from $57.54 to $72.51 per facility, while that 

for “CRT Recyclers” ranges from $265.87 to $280.84. As reflected in Exhibit 1, when 

considered together, this results in costs as low as $57.54 and as high as $280.84 (depending on 

the type of exports that are occurring). 

Further displayed in Exhibit 1 are typical numbers of facilities in 4 specific industrial 

sectors viewed to be most representative of CRT Exporters. The numbers shown reflect 

estimates of the numbers of facilities with less than 20 employees, as well as their Annual Sales. 

As shown in Exhibit 1, for firms with fewer than 20 employees, the annual compliance cost as a 

percentage of annual sales is less than 0.1 percent. It was therefore determined that rule would 

not have a significant economic impact on a substantial number of small entities. 

Exhibit B-1

Evaluation of the Economic Impacts on Small Businesses

(as Conducted in the Nov. 2011 EIA for the Proposed CRT Rule)

Industry Sector NAICS 

Code

Number of 

Firms with 

Fewer than 

20 

Employees

Annual 

Sales Per 

Facility 

(2007$) 

a

Range of Annual 

Compliance Costs for 

both CRT Recyclers 

& Reusers

($) 

b

Annual 

Compliance Cost 

as a Percentage 

of Sales

CRT Rule Low High

Recyclable Material 

Wholesaler 

423930 5133 2,636,310 57.54 280.84 0.002% to 0.01% 

Materials Recovery 

Facilities 

562920 621 971,543 57.54 280.84 0.006% to 0.03% 

Recyclable Material 

Collection Services, 

Solid Waste Collection 

562111 5620 1,014,036 57.54 280.84 0.006% to 0.03% 

Other Waste Collection 562119 457 423,059 57.54 280.84 0.015% to 0.07% 

a

 Based on 2002 U.S. Census Bureau data, updated to 2007 dollars using the GDP Implicit Price Deflator (1.15).

b

 Based on an annual compliance cost calculated as the aggregate annual costs incurred by all CRT exporters, importers and 

transporters, divided by the total number of affected entities. First year costs were annualized over 10 years using a discount 

factor of seven percent.

Additional analyses were conducted to evaluate the incremental increase in the costs of 

the rule as a means of validating our earlier determination. As already revealed in the results of 

our EIA analyses, the total estimate costs of the final rule are very similar to those that were 
25

projected by our earlier analyses for the proposed rule in November of 2011. Based on the 

updated analyses, annual compliance costs for exporters or CRTs for purposes of reuse ranged 

from $5,775 to $12,032 in the baseline. Then, an additional total annual cost of approximately

$2,450 is incurred by just those firms that export CRTs for recycling. Lastly, the one-time cost 

expected to be incurred by all exporters to familiarize themselves with the rule totaled $42,900. 

When annualized and considered on a per facility basis, the costs for “CRT Reusers” ranges from 

$84.88 to $129.57 per facility, while that for “CRT Recyclers” totals approximately $713.50 per 

facility. Therefore, under the final rule, the estimated annual costs are typically going to be as 

low as $56.88 for the 140 reuse exporters, as compared to $713.50 per facility for recycling 

exporters. 

The costs results from our updated analyses are very similar to those observed in our 

earlier analyses. The assumptions and methodology underlying these analyses were furthermore 

highly conservative. As such, the results help reaffirm that, for firms with fewer than 20 

employees, annual compliance cost as a percentage of annual sales should be less than 0.1 

percent. Based on the above, EPA projects that rule will not have a significant economic impact 

on a substantial number of small entities.