Summary of Regulatory Flexibility Analyses

Conducted in Coordination with the

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
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. 

Summary Discussion of Analyses and Results

The Agency has examined the final rule's potential effects on small entities as required by

the RFA/SBREFA. We have determined that the rule will 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. 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 are very minor. 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). The proposed revisions vary for those exporters that recycle vs. those that 

reuse CRTs. 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, 

there is an additional total annual cost of approximately $2,500 for 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 totals $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). 

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. Therefore, the final rule will not have a 

significant economic impact on these firms. Based on the above, the Agency has determined that 

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

 Exhibit 1

 Evaluation of the Economic Impacts on Small Businesses

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.