Manufacturers, importers, and sellers of electronics are subject to a changing array of federal and state communications and environmental requirements governing the marketing and disposal of such devices. To help clients stay on top of these requirements, GT’s Debra McGuire Mercer and Bernadette Rappold hosted a webinar on March 7 entitled, “Marketing and Disposal of Electronics: Understanding FCC Rules Governing Radiofrequency Devices and e-Waste Regulations.”
Mercer began the session by outlining amended FCC regulations codified at 47 C.F.R. Parts 2 and 15. The amended regulations, which went into effect last November, govern radiofrequency devices, including most electronic goods. The new rules streamline the methods for obtaining FCC equipment authorizations by combining into one method two authorization methods that permit responsible parties to test certain types of devices (rather than have an FCC accredited lab test the devices). The amended rules also eliminate a FCC form that had been required in order to import electronic devices and increased the quantity of devices that can be imported without obtaining an equipment authorization for trade shows or personal use. In addition, the new rules provide guidance as to when required labels may be included on an electronic display, rather than permanently affixed to a device.
Companies re-evaluating their FCC compliance in light of the new Parts 2 and 15 rules may also want to review their compliance e-waste requirements, Rappold suggested. E-waste regulations are becoming increasingly relevant as U.S. consumers, on average, replace their cell phones every 18 months, their televisions every two years, and their computers every three years. While federal regulation of e-waste is limited, 25 states and the District of Columbia presently have requirements either mandating or encouraging recycling of electronic waste. Some states impose a duty on manufacturers to register, while other states place more of the burden on sellers or retailers. Still other states, including California, have declared e-waste “hazardous,” effectively forbidding its placement in ordinary landfills, and have imposed mandatory deposits to encourage end-users to recycle.
As the market for electronic goods continues to grow, continuing regulatory interest in the authorization and disposal of these devices is expected. GT will continue to monitor developments. Subscribe to our blog for updates.