Download Available: Hazardous Waste Disposal Charges Update 2013
We wrote to you in November 2012 regarding compliance with charging customers for hazardous waste disposal charges on the invoice. A copy of the Dealer Alert from November 2012 (without the attachments) is enclosed with this letter. Following the letter, we sought a regulatory and legislative review from experts in this area.
The experts have stated that the hazardous charges to customers must be direct costs related to hazardous waste disposal and these costs must be offset by any money the dealership receives from selling oil. Depending upon the size of the dealership or dealership group, this amount can be anywhere from $0.75 to $1.00 per gallon of used oil. For example, if the dealership receives $12,000 per year from the used oil hauler and the net expenses directly related to hazardous waste are $10,000, then the dealership should not charge customers for hazardous waste. If the net expenses are more than the money received from selling used oil, then the dealership can recover the excess costs.
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