Hewlett-Packard Company 3000 Hanover Street Palo Alto, CA 94304-1185 www.hp.com

Tony Morabito

December 17, 2008

8000 Foothills Blvd. Bldg. RN Roseville, CA 95747 916.785.9153Tel 916.785.2683 Fax [email protected]

Department of Environmental Quality Land Protection Division Attention: Fenton Rood Oklahoma Department of Environmental Quality 707 North Robinson P.O. Box 1677 Oklahoma City, OK 73101-1677

Compliance Implementation Americas Environmental Leadership Team Hewlett-Packard

Computer Recycling Notification and Recovery Plan for Hewlett-Packard Company Notification to Oklahoma Department of Environmental Hewlett-Packard will have, starting on January 1, 2009, a compliant collection program in the form of a mail-back program. Section 5 of Law - Recovery Plan C. The recovery plan shall fully explain how the manufacturer will collect from a consumer and recover each covered device that is labeled with the manufacturer’s brand, at no charge to the consumer. The manufacturer’s recovery plan under this subsection may use existing collection and consolidation infrastructure for handling covered devices and may include electronic recyclers and repair shops, recyclers of other commodities, reuse organizations, nonprofit corporations, retailers, recyclers, or other suitable operations. HP owned brands include the following:  HP  Hewlett Packard  Compaq  Digital Equipment Corporation (DEC)  Apollo Computers  VooDoo PC Devices covered under the law or Covered Electronic Devices (CEDs):  Computers (desktop and notebook)  Computer monitors

Oklahoma DEQ – Computer Recycling Notification and Recovery Plan for Hewlett-Packard – Dec 2008

Hewlett-Packard Company 3000 Hanover Street Palo Alto, CA 94304-1185 www.hp.com

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HP’s program will provide collection and recycling services of CEDs to Oklahoma consumers at no charge to them through the use of a mail-back program. D. The recovery plan shall provide for covered device collection services that are reasonably convenient and available, and designed to meet the collection needs of consumers in this state. Nonexclusive examples of collection methods that alone or in combination meet the convenience requirements of this section include: HP’s program for Oklahoma consumers consists of a free mail-back program. HP believes that this service is both reasonably convenient and available, and meets the collection needs of consumers in the state of Oklahoma. 1. A mail-back system, at no cost to the consumer, whereby the consumer can return a covered device through the mail, including, but not limited to, a system in which the consumer can go online, print a prepaid shipping label, package the product, and schedule an at-home pickup for shipment back to the manufacturer; As mentioned above, HP is contracting with a recycling vendor who provides a free mail-back system to consumers. HP has chosen to route all consumers through www.hp.com/recycle so that we can maintain one place to send all consumers interested in finding out more about how to redeem recycling services. Customers can visit www.hp.com/recycle and from there click “Go” under Hardware Products while selecting “United States”. That page directs them to a website dedicated to states in the United States with mandatory Takeback laws. That website is: http://www.hp.com/hpinfo/globalcitizenship/environment/recycle/us/index.html

From this page, the consumer selects their state (Oklahoma) and is directed to an HP website that will describe the basics of the law, and how to redeem collection and recycling services. The HP Oklahoma webpage will be live as of January 1, 2009 and will be at the following URL: http://www.hp.com/hpinfo/globalcitizenship/environment/recycle/us/ok.html

Oklahoma DEQ – Computer Recycling Notification and Recovery Plan for Hewlett-Packard – Dec 2008

Hewlett-Packard Company 3000 Hanover Street Palo Alto, CA 94304-1185 www.hp.com

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From the HP Oklahoma web page, the consumer will click on the “recycle covered products” button if they want to redeem collection and recycling services for HP branded equipment. The link takes them to one of our contracted recycling vendors, ECO International. That website is: http://hp.ecotakeback.com/ The ECO website is live for Texas consumers at this point, and will be live for valid Oklahoma zip codes beginning January 1, 2009. The ECO website is managed by ECO specifically on behalf of HP to provide collection and recycling services to Oklahoma consumers who desire to return HP branded Covered Electronic Devices. At the ECO website, the consumer enters the brand, type of product and their zip code. If the consumer enters a valid Oklahoma zip code, they will receive the following message:

Ship us your product for free via UPS Consumers can receive a FREE UPS return shipping label for qualified products. After entering key information our web application will generate a free shipping label mailed to valid email address. For your convenience, our web application will provide a listing of nearest UPS drop off centers for returning your end of life electronics.

The consumer then clicks on the “View Details” button (not shown on the above graphic) and is provided with a list of UPS locations that are nearest to their zip code. The consumer can select any shown location and is then prompted to fill out their personal information in order to get to a pre-paid UPS mailing label. The consumer then packages their equipment in a box, affixes the pre-paid label, and then simply drops the package off at any UPS service location. Important Note: The consumer can take the package to any location that UPS services. The list of UPS stores is provided merely as a convenience to the customer, and it does not mean the consumer is limited to mailing their package exclusively from a UPS store.

Oklahoma DEQ – Computer Recycling Notification and Recovery Plan for Hewlett-Packard – Dec 2008

Hewlett-Packard Company 3000 Hanover Street Palo Alto, CA 94304-1185 www.hp.com

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2. The providing of staffed physical collection sites at which consumers may return covered devices, sited in locations that are geographically central to the consumers served; and Since HP is providing a free mail-back program to Oklahoma consumers, we will not be providing staffed physical collection sites in the state. All consumers in Oklahoma are eligible to utilize the free mail-back program provided for HP branded covered electronic devices.

3. Collection events at which consumers may return covered devices, sited in locations that are geographically central to the people served and conducted with sufficient frequency to reasonably meet the needs of the consumers served. Since HP is providing a free mail-back program to Oklahoma consumers, we will not be conducting collection events. All consumers in Oklahoma are eligible to utilize the free mail-back program provided for HP branded covered electronic devices. E. If a manufacturer does not offer a mail-back system, it shall submit for approval by the Department of Environmental Quality a plan that offers reasonably convenient collections as set forth in paragraph 2 or 3 of subsection D of this section. The Department shall review the plan for geographic distribution and frequency of collections. The Department shall notify the manufacturer within 30 days of receipt of the plan whether or not the manufacturer’s plan complies with the requirements of this section. If the Department does not approve the plan, the Department shall state the reasons the plan does not comply. The manufacturer shall respond to the Department within 20 days of receipt of notification of the disapproval of the plan. If the Department and the manufacturer do no agree on whether the plan should be approved, the manufacturer may seek review in a declaratory ruling proceeding under the provisions of Section 307 of Title 75 of the Oklahoma Statutes. Section E not applicable to HP since we are offering a mail-back system.

Oklahoma DEQ – Computer Recycling Notification and Recovery Plan for Hewlett-Packard – Dec 2008

Hewlett-Packard Company 3000 Hanover Street Palo Alto, CA 94304-1185 www.hp.com

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F. The recovery plan shall also include a statement that the manufacturer will not dispose of covered devices in landfills or transfer covered devices to computer equipment recycling facilities that dispose of covered devices in landfills other than necessary incidental disposal in de minimis amounts. As HP is not the recycler but the manufacturer, we have asked our recycler ECO International to provide a response to the statement specified in Section F that the manufacturer (recycler)

“ will not dispose of covered devices in landfills or transfer covered devices to computer equipment recycling facilities that dispose of covered devices in landfills other than necessary incidental disposal in de minimis amounts.”

ECO International made the statement that they could accept the above language as stated and will not dispose of covered devices in landfills or transfer covered devices to computer equipment recycling facilities that dispose of covered devices in landfills other than necessary incidental disposal in de minimis amounts. The only material ECO landfills are the wood casings from projection TVs (which HP does not manufacture).

Oklahoma DEQ – Computer Recycling Notification and Recovery Plan for Hewlett-Packard – Dec 2008

Hewlett-Packard Company 3000 Hanover Street Palo Alto, CA 94304-1185 www.hp.com

December 17, 2008 Page 6

Contact Information Tony Morabito Americas Environmental Leadership Team Compliance Group Hewlett-Packard [email protected] Tel: (916) 785-9153 Fax: (916) 785-2683

Street Address of Corporate Headquarters Hewlett-Packard Company 3000 Hanover Street Palo Alto, CA 94304-1185

Mailing Address (of contact for this program) Hewlett Packard Attn: Tony Morabito 8000 Foothills Boulevard, BLDG. RN Roseville, CA 95747

Sincerely yours,

Tony Morabito Hewlett-Packard Company

Oklahoma DEQ – Computer Recycling Notification and Recovery Plan for Hewlett-Packard – Dec 2008