Enviro Watch



If you have any questions in regards to the above, please do not hesitate to contact our offices so that we may explain the amendments to the provisions of the Code in more detail. Our address is:


Fiddler González & Rodríguez, P.S.C., P.O. Box 363507, San Juan, PR 00936-3507. Our fax (787) 759-3108.


We welcome your questions and comments.

Juan Carlos Gómez Escarce
(787) 759-3166


María L. González Hernández
(787) 759-3173



Eduardo Negrón Navas

(787) 759-3106


Pedro J. Reyes Bibiloni

(787) 759-3208





On September 11, 2014, the Governor of Puerto Rico signed into law Act No. 155 (the “Act”), amending Act No. 18-2012 known as the Act to Promote the Recycling and Disposal of Electronic Devices in Puerto Rico. The Act substituted the standard applicable to the certification required from companies that manage electronic devices, added requirements regarding export documentation and compliance with identity theft and confidential information protection.


Under the Act, any natural person, business, corporation, partnership, non-profit organization, or governmental entity that discards electronic devices for its reuse or recycling, must assure the destruction of confidential information contained in such devices, and comply with applicable regulations to avoid identity theft and the protection of confidential information.


The Act also establishes new requirements applicable to the operations plan required from facilities where the recycling, processing, or final disposal of disposed, discarded, obsolete, or unusable electronic devices occurs. The new requirements include providing information on efforts to reuse, repair or recondition before recycling the materials, orientation policy to clients, employee health and safety issues, and documentation evidencing compliance.


In addition, exporters of electronic waste must now provide to the Environmental Quality Board (EQB) copy of the manifests for each shipment of electronic materials and equipment to evidence compliance with state and federal export requirements.


According to the Act, EQB must publish regulations within six months, clearly establishing the handling, processing and recycling standards of electronic materials and equipment, modeled after those recommended by the United States Environmental Protection Agency. The Act also requires EQB to eventually establish a certification, periodic audit and enforcement processes for entities subject to these requirements. The purpose of this new electronic device processing standard is to establish guidelines for the complete recycling process and the chain of custody through its final disposal. The new EQB-issued certification will replace the existing e-Stewards certification currently required to be obtained from Based Action Network.


If you have questions regarding this matter or would like to know more of our Firm's experience in this area, please call us. If you know anyone that would like to receive the FGR Environmental Watch, please feel free to forward this newsletter or reply to this e-mail in order to be added as recipient. Stay tuned for further updates of FGR ENVIRONMENTAL WATCH.


 ©2014 Fiddler, González & Rodríguez, P.S.C. This Watch has been prepared by Fiddler, González & Rodríguez, P.S.C. for informational purposes only and does not constitute legal advice. This information does not create, and receipt of it does not constitute, a lawyer-client relationship. Readers should not act upon this without seeking advice from professional advisers. Fiddler, González & Rodríguez, P.S.C. and its members assume no responsibility to inform you of additional changes in law or any other legal issues related to the matters discussed in this e-mail.



Office Location:

254 Muñoz Rivera Ave. 6th Floor

Hato Rey, Puerto Rico 00918


Mailing Address:

PO Box 363507

San Juan, PR 00936-3507


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