2015 GNYADA MEMBERSHIP DIRECTORY

SHOP SUPPLIES AND WASTE DISPOSAL CHARGES

Dealers often ask GNYADA about waste disposal (or environmental fees) and shop supply fees. Here are some tips to help you avoid violations. DMV’s Repair Shop Regulations require dealers to provide customers with an invoice that contains a list of every part supplied and labor performed, including the cost for each part used on the repair. Dealers must list every bolt, screw, amount of oil, or any other item for which you charge separately on the invoice. DMV will look for substantiation if you list every nut and bolt or pint of windshield washer fluid on your invoices. Charges for the disposal of other wastes (anti-freeze, brake fluid, solvents, etc.) must be clearly identified and itemized in all estimates, repair orders and advertising. Dealers may not use pre-printed fees or percentage based fees.

HOT TOPICS 2015 GNYADA Membership Directory 89

Used Oil New York State Environmental Conservation Law prohibits dealers from charging for waste oil. During regular business hours, dealers must accept up to five gallons of used oil per day from an individual. Dealers are required to post a conspicuous sign stating We Accept Used Oil for Recycling at No Charge.

Batteries New York Environmental Conservation Law requires retailers to accept up to two batteries per month from an individual at no charge. Again, a conspicuous sign is required that states: “It is illegal to discard vehicle batteries. State law requires us to accept vehicle batteries at no charge for recycling.”

Hazardous Wastes Be careful not to label your disposal fees as a hazardous waste fee. A lot of the waste you are generating is not hazardous, and labeling it hazardous could require you to treat it differently. For instance, oil filters are not hazardous waste if properly drained and crushed prior to disposal.