How would the exclusion for certain tolling arrangements work?
A. This exclusion addresses a particular type of recycling arrangement between two companies that have a contractual relationship. Specifically, the exclusion would apply in situations where a “tolling” company contracts 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 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, the material would be excluded from regulation under this proposal. In these types of situations, management and recycling of the material is in essence done under the control of the tolling company, even though the material is generated by another company. Top of Page Q. What is the scope of the proposed conditional exclusion for hazardous secondary materials that are generated and then transferred to another company for the pur
