All producers are required to register with LightRecycle Washington as a participant and report and remit EHCs to PCA. The EHC must be remitted on all mercury-containing lights sold or supplied by the producer in or into Washington State and intended for retail sale on or after January 1, 2015, with the exception noted below.
Sometimes it is more practical for a company that is not the legally obligated producer, such as the retailer or the distributor, to join the program and report and remit their sales directly to the program. The program is flexible in terms of which company in the supply chain becomes a participant, so long as there is assurance that the program receives the EHC for every mercury-containing light sold in Washington State at retail.
To formalize the option where the retailer or distributor remits on behalf of the producer, the producer must have a binding agreement in place with the retailer or distributor and must notify PCA of any such arrangements to ensure all EHCs are properly recorded and remitted. A Supplier – Customer Remitter Determination Form must be provided to PCA as evidence that a binding agreement has been established.