1. What does electronics recycling have to do with me?
Amendments to the Government of Newfoundland and Labrador’s Waste Management Regulations require all “first sellers” of regulated electronic products to be part of an approved industry take-back and recycling program. EPRA Newfoundland and Labrador manages a not-for-profit and government-approved program.
If you sell, distribute, manufacture or import regulated electronic products in or into Newfoundland and Labrador (including online sales) you must be part of an approved program.
2. How is the program funded?
Stewards of the EPRA Newfoundland and Labrador program will pay Environmental Handling Fees (EHFs) to EPRA based on the number of units sold or distributed in or into Newfoundland and Labrador.
3. Can I recover the fees?
It is expected that EPRA Newfoundland and Labrador program stewards will recover the EHFs they pay EPRA by charging the EHFs to their customers, whether wholesale or retail.
4. What about HST?
All EHFs are subject to applicable sales taxes. Stewards should seek professional tax advice to ensure applicable taxes are correctly applied.
5. Will my suppliers and customers also have to pay EHFs?
By default, the first supply of obligated product in or into the province is subject to reporting and EHF remittance, and the EHF is only remitted once per obligated product.
If the supply of an obligated product is to another Remitter in the applicable province, the supplying Remitter is exempt from reporting the supply or remitting the EHF. Instead, the Remitter receiving the product accepts full responsibility for reporting and remitting the EHF on their subsequent supply of the product.
In order to exempt a Remitter from the EHF, the supplier must maintain evidence of the receiving Remitter’s status (i.e. Remitter number) at the time of supply and the amount of the EHF exempted. The list of Remitters subject to this exemption is maintained by the program.
The Remitter and Pay On Purchase (POP) Remitter may choose to recover the EHF by charging it to their customer.
6. Do fees apply to used equipment?
EHFs do not apply to the sale or distribution of used or refurbished equipment.