How does the exclusion for certain tolling arrangements work?
This exclusion addresses a particular type of recycling contract between two companies. Specifically, the exclusion applies in situations where a “tolling” company certifies that it has a contract with a manufacturer to produce a product, and that manufacturing process generates a residual material that can be recycled by the tolling company. If the tolling company certifies that the contract specifies that the tolling company owns and has responsibility for the recyclable material once it is generated, and the material is returned to the tolling company for reclamation, and subsequently recycled, the material is excluded from regulation. In these situations, management and recycling of the material are in essence done under the control of the tolling company, even though the material is physically generated by another company. Top of Page Q: What is the scope of the conditional exclusion for hazardous secondary materials that are generated and then transferred for the purpose of legit
