EXCLUSIONS The following are not classified as CBE: • Certain medical devices • Covered electronic devices (already subject to California’s e-waste fee) • Certain energy storage systems • Certain electronic nicotine delivery systems The following transactions are not subject to the CBE waste recycling fee: • A sale for resale • A sale to Native Americans on Indian country • A sale of CBE products that the retailer ships directly to a location outside California when the transaction is not subject to California sales or use tax. The fee will apply if the buyer takes possession of the CBE products in California. CBE FEE RATES CalRecycle has now finalized the 2026 fee structure. This will be revised annually in October and will take effect Jan. 1 of the following year. • 1.5% of the retail sales price • Capped at $15 per product • Effective Jan. 1, 2026 • Dealership POS systems will need to incorporate the percentage-based calculation and the per-item cap. They may retain 3% of the CBE waste recycling fee collected to reimburse all fee collection costs. REGISTRATION TIMELINE CDTFA opened online registration for the CBE Waste Recycling Fee account on Nov. 19, 2025. Dealerships without CDTFA credentials (username, password or seller’s permit) must create them using the “Sign Up Now” feature in the CDTFA Online Services Portal. FILING REQUIREMENTS AND DUE DATES Returns and payments are due on the last day of the month following each calendar quarter. For example, the first required reporting period was for the first quarter, Jan. 1 through March 31, for which the return and fee payment were due on or before April 30. The return is due on either a quarterly or yearly filing basis, and filing frequency is assigned when you register. You are required to file a return even if you did not have any reportable activity or do not owe an amount during the reporting period. DEALERSHIP RESPONSIBILITIES • Fee collection at POS (including leases) • Filing CBE returns at assigned frequency • Timely remittance of fees to CDTFA • Retain 3% of fees as reimbursement for all fee collection costs • Inventory review and system updates Non-compliance may result in CDTFA penalties, interest and enforcement action. DISCLAIMER: The contents of this article are merely for informational purposes only and are not to be considered as legal advice. Employers must consult their lawyer for legal matters and accountants for tax and fee-related matters. Sam Celly of Celly Services Inc. has been helping automobile dealers comply with EPA and OSHA regulations since 1987. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a JD from Southwestern University School of Law (1997). Your comments/questions are always welcome. Please send them to sam@cellyservices.com. NCDA.COM 19
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