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Wisconsin RoHS

A few states in the USA have adopted regulations similar to EU RoHS to protect the environment and human health. According to Wisconsin RoHS, manufacturers of certain electronics must register with the state before selling their products to households and schools.

Scope of Application

The Wisconsin Statute Chapter 287.17, Electronic Waste Recycling, requires manufacturers of specific electronics to register with the Wisconsin Department of Natural Resources (DNR).  This registration applies to the products intended for sale to households or k-12 schools (kindergarten to 12th grade) in Wisconsin State. Like the EU WEEE Directive, this requirement follows the extended producer responsibility (EPR) principle. Furthermore, according to the statute, Wisconsin manufacturers must disclose their compliance with the hazardous substances restrictions outlined in the EU RoHS Directive.

Wisconsin RoHS

Products Covered by Wisconsin RoHS

According to the statute, Covered Electronic Devices (CEDs) are the following products intended for use in households or schools:

  1. Consumer video display devices: A television or monitor with a screen size of at least 7 inches. Notably, screens integrated into motor vehicles or part of appliances such as washers, dryers, refrigerators, freezers, ovens, microwaves, dishwashers, air conditioners, dehumidifiers, or air purifiers are not in this category.
  2. Consumer computers: Fast data processing devices performing logical, arithmetic, or storage tasks, such as desktops, laptops, netbooks, and tablets. Additionally, consumer computers do not encompass automated typewriters or typesetters, portable hand-held calculators, or similar devices.
  3. Consumer printers: Desktop printers or printing devices designed for placement on a desk or similar work surfaces. Notably, calculators with printing capabilities, label makers, or similar devices used for household printing, floor-standing printers, Automated Teller Machines (ATMs), and point-of-sale receipt printers are not in this category.

Declarable Substances Under Wisconsin RoHS

Manufacturers must declare whether the covered electronic device sold to households or schools in the state exceeds the maximum concentration values set by the EU RoHS for the following substances:

  • Lead (Pb)
  • Mercury (Hg)
  • Hexavalent chromium (Cr 6+)
  • Cadmium (Cd)
  • Polybrominated biphenyls (PBBs)
  • Polybrominated diphenyl ethers (PBDEs)
  • Di(2-ethylhexyl) phthalate (DEHP)
  • Butyl benzyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Diisobutyl phthalate (DIBP)

Manufacturer Responsibilities under Wisconsin RoHS

Since February 1, 2010, manufacturers should adhere to the following requirements when selling covered electronic devices to households or schools in Wisconsin State:

  1. Permanently affixing a visible label to the eligible products displaying the brand
  2. Registering annually with the DNR department
  3. Paying annual registration fees, if applicable (see detailed requirements below)
  4. Arranging recycling CEDs used by households or schools in the state
  5. Submitting an annual report on sales of CEDs


Additionally, a manufacturer can collaborate with others to fulfill its obligations. They can form an entity dedicated to collecting and recycling covered electronic devices.

Moreover, since July 1, 2010, retailers cannot sell or advertise for sale a CED to a household or school in Wisconsin State unless they have confirmed that the manufacturer has listed its brand on the DNR website.

Furthermore, the registration fee depends on how many covered electronics units a manufacturer sold to Wisconsin households and schools in the previous program year. There is no registration fee for manufacturers sold only a few units of CEDs.

Manufacturers Exempted from Wisconsin RoHS

A manufacturer is exempt from registration if it:

  1. Does not intend to sell covered electronics to Wisconsin households or schools in the current program year,
  2. Produces devices not included in the list of CEDs, or
  3. Remanufactures or refurbishes covered electronics.

Registration Requirements

A manufacturer must submit a registration to the department by March 1 of each program year (usually from January through December). This registration must include the following information:

  1. A list of manufacturer’s brands of covered electronic devices available for sale in the Wisconsin State
  2. The name, address, and contact details of a person responsible for ensuring compliance with this regulation
  3. A certification that confirms compliance with the current and ongoing requirements outlined in this regulation, including declaring whether the device adheres to RoHS. In case of non-compliance to EU RoHS, the manufacturer must also declare it.

Moreover, manufacturers must submit their registration within ten days of starting to sell a CED in this state.

Recycling Requirements

Manufacturers must cover the recycling costs for a specific amount of electronics collected in Wisconsin during each program year. This obligation, known as the recycling target, is calculated based on the manufacturer’s market share of the weight of covered electronics received for recycling through E-Cycle Wisconsin (a statewide program funded by manufacturers designed to collect and recycle covered electronics used by households and k-12 schools) during a recent program year.

Manufacturers must collaborate with registered collectors or registered recyclers to achieve their recycling targets. Alternatively, they can register as recyclers or collectors and handle their collection and recycling operations.

Manufacturers who recycle more than required under the program accumulate carryover credits. Conversely, those who do not meet their recycling targets must pay shortfall fees to the department.

RoHS in Other US States

Other US states have implemented similar RoHS regulations, including:

To know more about RoHS regulation in Wisconsin or other US states, contact Enviropass!