Thermostat Manufacturer Requirements

By January 1, 2011, thermostat manufacturers must establish and maintain a program for collection, transportation and proper management of out-of-service mercury thermostats. Most thermostat manufacturers support the Thermostat Recycling Corporation(TRC), which is a industry-sponsored non-profit organization originally established by General Electric, Honeywell and White-Rodgers. TRC facilitates the collection of all brands of used, wall-mounted mercury-switch thermostats so that mercury can be separated and recycled. A list of participating manufacturers as well as collection locations are available on the TRC website.

Specific requirements for thermostat manufacturers are:

• January 1, 2011 – Contact wholesalers and offer them a collection container.
• January 1, 2011 – Make collection containers available to all qualified contractors, wholesalers, retailers and qualified local government authorities.
• Handle and manage out-of-service mercury thermostats as universal waste.
• Manufacturers cannot impose any fees to participants, except for a one-time start-up fee for each collection bin not to exceed $75.
• Between January 1, 2011 to December 31, 2013, manufacturers must conduct education and outreach that, at a minimum, includes the following activities:
  • Create a public service announcement and make available to the Illinois EPA for use to promote collection and recycling programs for mercury-switch thermostats.
  • Establish and maintain a website for dissemination of educational materials that will promote the collection of out-of-service mercury thermostats.
  • Contact wholesalers at least once a year to encourage their support and participation in educating customers on importance of and statutory requirements for collecting out-of-service mercury-switch thermostats.
  • Develop and implement strategies to encourage participating thermostat retailers to educate their customers on the importance of and opportunities for collecting and recycling out-of-service mercury thermostats.
  • Create and maintain a web-based program that allows contractors and consumers to identify collection sites by zip code areas.
  • Prepare and mailing to contractor associations a postcard or other notice that provides information on the collection program for out-of-service mercury thermostats.
  • Develop informational articles, press releases and news stories, pertaining to the importance of an opportunities for collecting and recycling out-of-service mercury thermostats and distribute those materials to trade publications, local media and stakeholder groups.
• January 1, 2011 – Develop and update as necessary educational and other outreach materials for distribution to contractors, contractor associations and consumers. The materials shall be made available for use by participating thermostat wholesalers, retailers, contractors and qualified local government authorities. Materials must include:
  • Signage, such as posters and cling signage, that can prominently displayed to promote the collection of out-of-service mercury thermostats to contractors and consumers.
  • Written materials or templates of written materials for reproduction by thermostat wholesalers and retailers to be provided to consumers at the point of purchase or delivery of a thermostat. Materials must include information on the importance of properly managing out-of-service mercury thermostats and opportunities for the collection of those thermostats.
• Propose and submit to the IL EPA revisions to the collection program if collection goals are not met in 2013, 2015, or 2017. Provide an opportunity for the IL EPA and other stakeholders to offer feedback and suggestions on the collection program.
• Submit mid-term reports to the IL EPA by September 1st of every year. Mid-term reports must include
  • Number of mercury thermostats collected.
  • Listing of all collection sites in Illinois.
• Submit annual reports to the Illinois EPA by April 1st of every year, beginning in 2012. Annual reports must include
  • Number of mercury thermostats collected during the previous calendar year.
  • Estimated total amount of mercury collected during the previous calendar year.
  • Evaluation of the effectiveness of the collection program
  • Listing of all wholesalers, contractors, local government authorities, and retailers participating in the program and number of thermostats returned by each.
  • Accounting of administrative costs.
  • Description of educational outreach conducted.
  • Examples of outreach and educational materials use during the previous calendar year.
  • Internet website address or addresses where the annual report may be viewed online.
  • Description of how out-of-service thermostats were managed.
  • Modifications being made to the collection program.
  • Collection program contact person with contact information.