A 2015 amendment required all registered manufacturers to do a special report on PY8 sales to set a minimum recycling obligation for PY9 reporting.
Amendment affecting manufacturer obligation for program year 9 (ending June 2016) and requiring a special report on sales of video display devices, due July 15, 2015. [Laws 2015, chapter 4, article 4, section 106]
At a glance
- Submit sales data for the period July 1, 2014, through June 30, 2015
- Due July 15, 2015
- Why: Establishes a minimum total recycling obligation of 16 million pounds for Program Year 9 (July 1, 2015, through June 30, 2016) based on the sales data from the previous year (PY8). Individual manufacturers will be assigned a minimum recycling obligation for PY9 based on their reported share of PY8-reported sales.
- July 15: Submit form to MPCA
- July 30: MPCA will provide calculated PY9 recycling obligation to individual manufacturers
- September 1: Full program year reporting due to Minnesota Department of Revenue (forms EW-1) as usual (sales period July 1, 2014, through June 30, 2015)
Q0: Is this reporting optional?
A0: No. This report is required of registered manufacturers through the amendment.
Q1: Is this data confidential?
A1: Manufacturers must declare their data as "not public" using the checkboxes on the form.
Q2: What if I submit my sales data after the July 15 due date?
A2: The amendment requires all manufacturers to submit sales data to the MPCA by July 15, 2015.
- The agency must provide calculated minimum recycling obligations to all manufacturers by July 30, 2015.
- Any manufacturer that does not submit the required sales data by the deadline will be referred to compliance and enforcement staff.
Q3: Do I need to collect additional data?
A3: No. This is a shorter treatment of data due in September in reporting to the state Department of Revenue.
Q4: Why is this required so early?
A4: To provide manufacturers with their minimum obligation early in Program Year 9.
Q5. Does this replace reporting to the Department of Revenue?
A5. No. Manufacturer reporting on program year 8 is due, as normal, September 1.
Q6: What if I cannot provide final sales data by July 15, 2015?
A6. MPCA will accept estimates for the final weeks of PY8 if exact sales data are not available. Provide an explanation of how sales were estimated on the form.
Q7: Does this cap my recycling obligation in Minnesota?
A7: No. If a manufacturer calculates a recycling obligation based on their sales that is higher than their calculated share, they have to use the higher figure.
Q8: How will manufacturers meet PY9 recycling obligation?
A8: The calculated amount is a minimum target; recycling obligation is to be met as normal, using recycled pounds, manufacturer recycling credits (limit 25% of recycling obligation), and recycling fees.
Q9. My company is not going to register as a manufacturer for PY9. Do I need to report our sales of video display devices by July 15?
A9. No. Companies that expect to have no recycling obligation in Minnesota in PY9 should not submit sales data.
Q10: Is this July report the new normal?
A10: The 2015 amendment applies only to Program Year 9 recycling obligation, and specifies this one special report by July 15, 2015.