id author title date pages extension mime words sentence flesch summary cache txt cjel-3573 Buseman, Nicole A Second-Generation Solution to Electronic Waste: The New York Approach 2019 46 .pdf application/pdf 16492 901 47 Manufacturers rarely establish consumer-‐friendly recycling programs voluntarily because accepting an unrestricted volume of discarded products burdens them with high recycling costs.27 Even where manufacturers have created independent programs to recycle used products, retailers rarely participate in these programs and manufacturers often fail to provide convenient e-‐waste disposal options.28 Consumers face similar disincentives to recycle e-‐waste. Id. (noting the Swiss approach—a collective system that does not distinguish by manufacturer—enhanced consumer convenience by allowing centralized drop-‐off of different types of electronics, compared to separation by manufacturing brand or type of waste). 112 COLUMBIA JOURNAL OF ENVIRONMENTAL LAW [Vol. 37:2 Two different e-‐waste systems have been implemented in the United States, and each addresses the divide between actors in differing ways—the Producer Responsibility System (PRS) and the Advanced Recovery Fee System (ARF).63 The PRS approach places responsibility for recycling and disposal costs on manufacturers, while the ARF approach charges consumers a recycling fee at the point of sale.64 All but one state e-‐waste program implements a form of a PRS; California is the only state that has adopted an ARF system.65 New York continued this trend with the adoption of a PRS program that requires manufacturers to implement and finance e-‐ waste disposal systems.66 C. EERRA: The New York Approach New York’s EERRA has received praise as “the most progressive, best researched e-‐waste bill in the country. cache/cjel-3573.pdf txt/cjel-3573.txt