1

Economic Impacts Assessment for Proposed Revisions to the

Export Provisions of the Cathode Ray Tube (CRT) Rule

Office of Resource Conservation and Recovery

Office of Solid Waste and Emergency Response

U.S. Environmental Protection Agency

November 2011
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EXECUTIVE SUMMARY

The Environmental Protection Agency (EPA or the Agency) is proposing to revise the 

export provisions of the Cathode Ray Tube (CRT) final rule published on July 28, 2006 (71 FR 

42928). The purpose of these proposed revisions is to address certain implementation concerns 

with the current export provisions of the 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. The proposed rule would affect only the export provisions of the CRT 

rule. It would not affect any requirements applicable to domestic management of used CRTs. 

Nor does this proposed 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. 

EPA is proposing to add a definition of “CRT exporter” to the CRT rule. This proposed 

definition will clarify the responsibilities of brokers and other intermediaries in fulfilling the 

export notice requirements. EPA is also proposing to revise the notifications that must be 

submitted to EPA when CRTs are exported for reuse or recycling, and to require annual reports 

from exporters of CRTs for recycling. This document assesses the potential economic impacts 

of the proposed 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 proposed CRT rule 

revisions. This one-time cost is expected to be incurred by 138 CRT exporters. The total cost of 

this provision equals approximately $39,000 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 the new proposed 

requirement is expected to result in only 12 new reports each year, the total costs to exporters 

and EPA are very low and equal a total of approximately $2,500 per year. 

3) Added to these costs are additional annual costs to all 138 CRT Exporters ranging from 

$2,386 to $4,453 for adhering to the additional information requirements proposed for both of 

the current Recycling & Reuse Notices. These costs, in combination with the added costs for 

EPA's review of these notices (estimated to be between $2,449 and $4,572), brings the total 

annual cost for this feature of the proposed rule to a range of approximately $4,835 to $9,025.

In conclusion, the total estimated cost impacts from this rule are estimated to be $39,000 

in year one only, plus annual costs in the range of $7,300 to $11,500 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 Proposed Regulatory Action

2.0 OVERVIEW OF PROPOSED REGULATORY REQUIREMENTS

2.1 Definition of “CRT Exporter”

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

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

2.2.2 Additional Destination Data Requested as Part of the Recycling Notice

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

2.3.1 Proposed Changes to Notification Requirements

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

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 Total Cost Impact of the Proposed CRT Rule Revisions 

5.0 QUALITATIVE DISCUSSION OF BENEFITS

A. ATTACHMENTS Supporting Documentation For Assessment of Costs
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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). Used, broken CRTs sent 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 Proposed 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 proposing minor changes to the current 

CRT Rule as described in Section 2.0 below. 
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2.0 OVERVIEW OF PROPOSED 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 proposing to add a definition of 

“CRT exporter” to 40 CFR 260.10, which states that a CRT exporter is “any person who decides 

that CRTs will be sent outside the United States or its territories for recycling or reuse (including 

reuse after refurbishment in the receiving country), and any intermediary arranging for the 

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 to perform the exporter duties under 40 CFR 

261.39(a)(5) and 40 CFR 261.41 Lastly, EPA emphasizes that this proposed 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 Proposed Rule Changes Specific to the “Export of CRTs for Recycling”

Under the provisions of this proposed 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 proposing that such parties submit Annual Reports of their exports. [Note: 

This annual report requirement has been modeled after the annual reporting requirement for 

exporters of spent lead-acid batteries under 40 CFR 262 Subpart E (See cited reference in 

Footnote 1 on page 7).]

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 

proposing to require 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 receiving country with the most accurate 

information available about the ultimate fate of the CRTs when they reach that country.
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2.3 Proposed Changes Specific to the “Export of CRTs for Reuse”

Under the provisions of this proposed rule, parties that “Export CRTs for Reuse” shall 

face the following additional requirements.

2.3.1 Proposed 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. EPA is proposing to expand 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 Proposed Rule.]

[Note: 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).]

3.0 METHODOLOGY AND ASSUMPTIONS

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

conducted for this rule. 

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

rule to U.S. exporters and to EPA. In estimating these costs, EPA first reviewed the provisions 

under the existing regulations and under the proposed rule to determine what new requirements 

were being proposed in this rule. We estimated the costs of these new requirements using the 

following inputs:

 Number of affected entities 

 Hourly labor rates

 Burden hours

 Materials costs

 Number of Annual Reuse/Recycling Notifications

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 the proposed rule changes. 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 
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proposed CRT Rule revisions. Lastly, Section 3.5 details the total “number of reuse and 

recycling notices” the EPA projects will be submitted per year.

3.1 Estimated Number of Potentially Impacted CRT Exporters

The Agency estimates 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). However, far more entities are on record as 

being exporters of CRTs for purposes of reuse. Based on the number of CRT Reuse 

Notifications submitted during 2011, there exists approximately 126 such entities in the U.S. 

(i.e., according to data from Sept. 14th, 2011 published on EPA’s CRT informational website at 

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

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 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.1

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. We then 

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

hourly labor rates.

 

1

 To obtain hourly labor rates for this proposal, 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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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

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 proposed CRT annual reporting and notification 

requirements are virtually 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 Materials Cost Estimates and Assumptions

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

submission of new Annual Reports and Notification requirements proposed 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
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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 

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 made the following assumptions:

 75% of reuse exporters (95) would submit 2-4 reuse notifications per year; and 

 25% of reuse exporters (31) would submit 1 reuse notification per year. 

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

notices ranges from as low as 233 to as many as 435. 

4.0 ASSESSMENT OF POTENTIAL COSTS

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

proposed 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 during 2011a total of approximately 12 

entities exported CRTs for recycling and 126 entities exported CRTs for reuse. Therefore, we 

estimated that 138 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
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Attachment A). 2Thus, U.S. exporters may experience a one-time cost of approximately

$38,952 (i.e., 138 entities x $282.26/entity) for this activity.

4.2 Estimated Costs for New Annual Reporting by CRT Export Recyclers

Under this proposed 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 

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 recent relevant reference

(See Footnote 1). Based on these figures, EPA estimates that the cost for a CRT Exporter to 

prepare 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 $2,158.32 (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 $295.68 (i.e., 12 annual 

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

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

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

 

2

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. 
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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 proposed CRT Rule revisions call 

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

following paragraphs discuss the estimated costs associated with these added notification 

elements. 

U.S. Exporters 

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 calculations above, EPA estimated that CRT exporters submit between 233 

and 435 notices each year. We estimated that each notice will cost an additional $10.26 (See 

Exhibit A-3 in Attachment A). In total, EPA estimates that the additional costs to Exporters will 

be in the range of $2,386 to $4,453 (i.e., 233 to 435 notices per year x $10.26 per notice) under 

the proposed rule. 

EPA 

We estimate that EPA will incur an additional cost of $10.51 per notice to receive and 

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

experience a total incremental annual cost in the range of $2,449 to $4,572 (i.e., 233 to 435 

notices per year x $10.51 per notice) under the proposed rule. 

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

reuse and recycling notification changes are $4,835 to $9,025 per year (See Exhibit A-3 in 

Attachment A). 

4.4 Total Cost Impact of the Proposed CRT Rule Revisions

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

approximately $39,000 in year one of the Rule, as well as annual costs in the range of $7,300 to 

$11,500 in year one and beyond. Based on the methodology and cost calculations described 

above in Sections 3.0 and 4.0, the results of our cost assessment reveal very modest cost impacts. 

Furthermore, many of the assumptions used in the analyses could be characterized as 

“conservative” assumptions, resulting in cost estimates that may be higher than those that would 

actually be incurred. 
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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) reduced storage cost for hazardous wastes 

destined for recovery; (3) reduction of risks associated with treatment and disposal of hazardous 

wastes; (4) 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; (5) better tracking of 

returns and compliance with exception reporting requirements; and (6) better tracking of 

compliance with the terms of CRT export notices. 

More specifically, the proposed CRT Rule Revisions will help determine that CRTs 

exported for recycling 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 is collected will also enable EPA to compare actual vs. proposed shipments to 

ensure that the shipments occurred 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 CRTs 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 outweigh the costs. 
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ATTACHMENT A

SUPPORTING DOCUMENTATION

FOR ASSESSMENT OF COSTS
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Exhibit A-1

Costs for Reading the Rule

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 $282.26 138 $38,952

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.
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Exhibit A-2

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.
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Exhibit A-3

Costs for Meeting Proposed Reuse & Recycling 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

Prepare & submit notification Subtotal for Exporters: 0.00 1.50 0.00 0.15 $10.51 $0.00 $10.51 138 233 to 435 $2,449 to $4,572

EPA

Receive and process notification 0.00 1.00 0.00 0.10 $6.32 $0.00 $6.32 138 233 to 435 $1,473 to $2,749

Prepare and transmit confirmation of receipt to U.S. 0.00 0.00 0.25 0.025 $0.92 $0.00 $0.92 138 233 to 435 $213 to $398

Forward notification to the competent authorities of 

the countries of import and transit 

0.00 0.00 0.16 0.016 $0.59 $0.00 $0.59 138 233 to 435 $137 to $255

Receive and process Acknowledgement of Receipt 

from the competent authority of the country of 

import

0.00 0.00 0.25 0.025 $0.92 $0.00 $0.92 138 233 to 435 $213 to $398

Receive and process consent/objection from the 

competent authorities of the countries of import and 

0.00 0.00 0.16 0.016 $0.59 $0.00 $0.59 138 233 to 435 $137 to $255

Forward written Acknowledgement of Consent or 

objection to U.S. exporter 

0.00 0.00 0.25 0.025 $0.92 $0.00 $0.92 138 233 to 435 $213 to $398

Subtotal for EPA: 0.00 1.00 1.07 0.207 $10.26 $0.00 $10.26 138 233 to 435 $2,386 to $4,453

Total for both Exporters & EPA 0.00 2.50 1.07 0.357 $20.77 $0.00 $20.77 138 233 to 435 $4,835 to $9,025

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.
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