In Chapter 3 of this RIA EPA calculated the average costs per entity by NAICS code, grouped by type to capture the fact that these different groups face different compliance costs.  The groups include waste exporters and importers to Canada, Mexico, OECD and non-OECD nations, described below.  Exhibit 5-3 shows the NAICS codes associated with entities of each type (exporters and importers), and the number of potentially small entities that fall under each NAICS code.
 For entities that report NAICS codes relevant to exporters, EPA calculated the average annual revenue by NAICS code from Census data, referencing reported revenues for entities associated with the midpoint SBA threshold.  The average annual revenue across NAICS codes for exporters is $520 million (minimum $5.7 million, maximum $7,700 million).  For entities that report NAICS codes relevant to importers, EPA repeated this process, and calculated an average annual revenue of $16 million (minimum $7.8 million, maximum $20 million; all values in $2015).
 For small entities with unknown NAICS codes (by entity type), EPA assigned average annual revenues derived above based on the entity type (exporter or importer).
 For each entity, EPA compared the average annual costs (by entity type) to the estimated annual revenues for small entities in that NAICS sector.
EXHIBIT 5-3.PROFILE OF SMALL ENTITIES BY NAICS CODE
                                  Entity type
                                  NAICS Code
                               NAICS Description
                       Number of Potentially Small Firms
Exporters
                                    211111
Crude Petroleum and Natural Gas Extraction
                                       4

                                    324110
Petroleum Refineries
                                      10

                                    325180
Other Basic Inorganic Chemical Manufacturing
                                       1

                                    325199
All Other Basic Organic Chemical Manufacturing
                                       3

                                    325211
Plastics Material and Resin Manufacturing
                                       2

                                    325510
Paint and Coating Manufacturing
                                       1

                                    325992
Photographic Film, Paper, Plate, and Chemical Manufacturing
                                       1

                                    326150
Urethane and Other Foam Product (except Polystyrene) Manufacturing
                                       1

                                    327213
Glass Container Manufacturing
                                       1

                                    331110
Iron and Steel Mills and Ferroalloy Manufacturing
                                       5

                                    331512
Steel Investment Foundries
                                       1

                                    332911
Industrial Valve Manufacturing
                                       1

                                    334519
Other Measuring and Controlling Device Manufacturing
                                       1

                                    335314
Relay and Industrial Control Manufacturing
                                       2

                                    335912
Primary Battery Manufacturing
                                       4

                                    336320
Motor Vehicle Electrical and Electronic Equipment Manufacturing
                                       1

                                    336360
Motor Vehicle Seating and Interior Trim Manufacturing
                                       1

                                    336412
Aircraft Engine and Engine Parts Manufacturing
                                       1

                                    339112
Surgical and Medical Instrument Manufacturing
                                       1

                                    423930
Recyclable Material Merchant Wholesalers
                                      14

                                    424690
Other Chemical and Allied Products Merchant Wholesalers
                                       3

                                    522220
Sales Financing
                                       2

                                    541512
Computer Systems Design Services
                                       2

                                    541710
Research and Development in the Physical, Engineering, and Life Sciences
                                       1

                                    541711
Research and Development in Biotechnology
                                       4

                                    561210
Facilities Support Services
                                       2

                                    561910
Packaging and Labeling Services
                                       1

                                    561990
All Other Support Services
                                       1

                                    562112
Hazardous Waste Collection
                                       3

                                    562211
Hazardous Waste Treatment and Disposal
                                       8

                                    562920
Materials Recovery Facilities
                                       1

                                    721110
Hotels (except Casino Hotels) and Motels
                                       1

Unknown
                                       2

EXPORTERS TOTAL
                                      87
Importers
                                    212291
Uranium-Radium-Vanadium Ore Mining
                                       1

                                    423930
Recyclable Material Merchant Wholesalers
                                       1

                                    541711
Research and Development in Biotechnology
                                       1

                                    562119
Other Waste Collection
                                       2

                                    562211
Hazardous Waste Treatment and Disposal
                                       5

Unknown
                                       6

IMPORTERS TOTAL
                                      16
TOTAL ACROSS ENTITY TYPES
                                      103

As discussed in Chapter 3, the industry costs of the rule are estimated to be higher in the first year than in later years due to the one-time, upfront costs of the rule (e.g., reading and understanding the rule and setting up a website). Therefore, to assess whether the costs of rule represent a significant impact to a substantial number of small entities, this regulatory flexibility analysis compares the first-year costs (as opposed to the annualized costs) with the average annual revenues of small entities.  Furthermore, to be conservative, we compare the total costs of the rule (rather than the net costs) against annual revenues to make this determination.
Using the total universe of potentially small firms, EPA then determined a weighted average first year total cost for the exporter and importer entity types, based on the proportion of entities exporting or importing to Canada, Mexico, OECD, or non-OECD nations. EPA compared these conservative first year total costs to the average revenues of potentially small entities by NAICS code, using the average revenues per entity established through the steps listed above. EPA found that none of the 103 small firms evaluated were affected at ether the one percent or the three percent level. As a result this analysis finds that the final rule will not result in SISNOSE. These results are presented by NAICS code in Exhibit 5-4.

EXHIBIT 5-4.PROFILE OF SMALL BUSINESSES AFFECTED BY THE RULE AND ASSOCIATED FIRST YEAR COSTS AS A PERCENT OF AVERAGE ANNUAL REVENUES
                                  Entity type
                                  NAICS Code
                               NAICS Description
                       Number of Potentially Small Firms
                    Average NAICS revenue ($2015 Millions)
               Average first year cost of compliance ($2015)[1]
                  Average cost as percent of average revenue
                      Firms affected at
1 percent level
                      Firms affected at
3 percent level
Exporters
                                    211111
Crude Petroleum and Natural Gas Extraction
                                       4
                                   $520 [2]
                                    $971.58
                                    0.0002%
                                     None
                                     None

                                    324110
Petroleum Refineries
                                      10
                                    $7,700
                                    $971.58
                                   0.00001%
                                     None
                                     None

                                    325180
Other Basic Inorganic Chemical Manufacturing
                                       1
                                   $520 [2]
                                    $971.58
                                    0.0002%
                                     None
                                     None

                                    325199
All Other Basic Organic Chemical Manufacturing
                                       3
                                    $1,200
                                    $971.58
                                   0.00008%
                                     None
                                     None

                                    325211
Plastics Material and Resin Manufacturing
                                       2
                                    $1,100
                                    $971.58
                                   0.00009%
                                     None
                                     None

                                    325510
Paint and Coating Manufacturing
                                       1
                                     $210
                                    $971.58
                                    0.0005%
                                     None
                                     None

                                    325992
Photographic Film, Paper, Plate, and Chemical Manufacturing
                                       1
                                     $420
                                    $971.58
                                    0.0002%
                                     None
                                     None

                                    326150
Urethane and Other Foam Product (except Polystyrene) Manufacturing
                                       1
                                      $83
                                    $971.58
                                    0.0012%
                                     None
                                     None

                                    327213
Glass Container Manufacturing
                                       1
                                     $120
                                    $971.58
                                    0.0008%
                                     None
                                     None

                                    331110
Iron and Steel Mills and Ferroalloy Manufacturing
                                       5
                                    $1,000
                                    $971.58
                                    0.0001%
                                     None
                                     None

                                    331512
Steel Investment Foundries
                                       1
                                      $77
                                    $971.58
                                    0.0013%
                                     None
                                     None

                                    332911
Industrial Valve Manufacturing
                                       1
                                     $120
                                    $971.58
                                    0.0008%
                                     None
                                     None

                                    334519
Other Measuring and Controlling Device Manufacturing
                                       1
                                      $46
                                    $971.58
                                    0.0021%
                                     None
                                     None

                                    335314
Relay and Industrial Control Manufacturing
                                       2
                                     $160
                                    $971.58
                                    0.0006%
                                     None
                                     None

                                    335912
Primary Battery Manufacturing
                                       4
                                     $310
                                    $971.58
                                    0.0003%
                                     None
                                     None

                                    336320
Motor Vehicle Electrical and Electronic Equipment Manufacturing
                                       1
                                   $520 [2]
                                    $971.58
                                    0.0002%
                                     None
                                     None

                                    336360
Motor Vehicle Seating and Interior Trim Manufacturing
                                       1
                                     $320
                                    $971.58
                                    0.0003%
                                     None
                                     None

                                    336412
Aircraft Engine and Engine Parts Manufacturing
                                       1
                                     $400
                                    $971.58
                                    0.0002%
                                     None
                                     None
Exporters (Continued)
                                    339112
Surgical and Medical Instrument Manufacturing
                                       1
                                     $130
                                    $971.58
                                    0.0007%
                                     None
                                     None

                                    423930
Recyclable Material Merchant Wholesalers
                                      14
                                   $520 [2]
                                    $971.58
                                    0.0002%
                                     None
                                     None

                                    424690
Other Chemical and Allied Products Merchant Wholesalers
                                       3
                                   $520 [2]
                                    $971.58
                                    0.0002%
                                     None
                                     None

                                    522220
Sales Financing
                                       2
                                      $20
                                    $971.58
                                    0.0049%
                                     None
                                     None

                                    541512
Computer Systems Design Services
                                       2
                                      $14
                                    $971.58
                                     0. %
                                     None
                                     None

                                    541710
Research and Development in the Physical, Engineering, and Life Sciences
                                       1
                                   $520 [2]
                                    $971.58
                                    0.0002%
                                     None
                                     None

                                    541711
Research and Development in Biotechnology
                                       4
                                     $7.8
                                    $971.58
                                    0.013%
                                     None
                                     None

                                    561210
Facilities Support Services
                                       2
                                      $20
                                    $971.58
                                    0.0049%
                                     None
                                     None

                                    561910
Packaging and Labeling Services
                                       1
                                     $5.7
                                    $971.58
                                    0.017%
                                     None
                                     None

                                    561990
All Other Support Services
                                       1
                                     $5.7
                                    $971.58
                                    0.017%
                                     None
                                     None

                                    562112
Hazardous Waste Collection
                                       3
                                      $20
                                    $971.58
                                    0.0049%
                                     None
                                     None

                                    562211
Hazardous Waste Treatment and Disposal
                                       8
                                      $20
                                    $971.58
                                    0.0049%
                                     None
                                     None

                                    562920
Materials Recovery Facilities
                                       1
                                      $11
                                    $971.58
                                    0.0088%
                                     None
                                     None

                                    721110
Hotels (except Casino Hotels) and Motels
                                       1
                                      $17
                                    $971.58
                                    0.0057%
                                     None
                                     None

Unknown
                                       2
                                   $520 [2]
                                    $971.58

                                     None
                                     None

EXPORTERS TOTAL
                                      87

Importers
                                    212291
Uranium-Radium-Vanadium Ore Mining
                                       1
                                    $16 [2]
                                    $723.67
                                    0.0045%
                                     None
                                     None

                                    423930
Recyclable Material Merchant Wholesalers
                                       1
                                    $16 [2]
                                    $723.67
                                    0.0045%
                                     None
                                     None

                                    541711
Research and Development in Biotechnology
                                       1
                                     $7.8
                                    $723.67
                                    0.0093%
                                     None
                                     None

                                    562119
Other Waste Collection
                                       2
                                      $20
                                    $723.67
                                    0.0036%
                                     None
                                     None

                                    562211
Hazardous Waste Treatment and Disposal
                                       5
                                      $20
                                    $723.67
                                    0.0036%
                                     None
                                     None

Unknown
                                       6
                                    $16 [2]
                                    $723.67
                                    0.0045%
                                     None
                                     None

IMPORTERS TOTAL
                                      16

Notes:
1.  Average first year cost of compliance for each Exporter and Importer firm was calculated as a weighted average within each entity type. The components of the weighted average are the average costs per entity exporting or importing to Canada, Mexico, OECD nations, and non-OECD nations. Each of these cost values were weighted based on the proportion of the total potentially small entity universe exporting or importing to each of these categories.
2.  Within each Exporters and Importers, the average annual revenue calculated from all known NAICS code entities was applied to entities in NAICS codes with unknown annual revenues, and to entities with unknown NAICS codes. This value is $520 million for Exporters and $16 million for Importers.

5.3  Employment Impact Analysis
Executive Order 13563 "Improving Regulation and Regulatory Review" (76 FR 3821; January 18, 2011) requires Federal agencies to consider the employment impacts of regulatory policy. Specifically, Executive Order 13563 states, "Our regulatory system must protect public health, welfare, safety, and our environment while promoting economic growth, innovation, competitiveness, and job creation." Consistent with the requirements of the Executive Order, this RIA considers the employment impacts of the rule. Ideally, this RIA would include a quantitative assessment of these impacts, but insufficient data are available to quantify changes in employment associated with the rule. This RIA, therefore, presents a qualitative assessment of the rule's potential employment impacts.
In general, an environmental regulation can be understood as an increase in demand for a particular output: environmental quality. Meeting this new demand can result in increased demand for the various factors of production (including labor) available to the economy. However, the regulated sector generally relies on revenues generated by their other market outputs to cover the costs of supplying increased environmental quality. This can lead to reduced demand for labor and other factors of production used to produce the market output. Thus, as described in Berman and Bui (2001), the net effect of an environmental regulation on employment in regulated sectors and the overall economy is indeterminate. The costs imposed on directly regulated sectors may raise production costs and put some specific jobs at risk, while at the same time environmental regulation may create jobs in the regulated sector or other sectors, such as the environmental protection sector. Because the costs of this rule are relatively low and because the number of effected entities is relatively low, EPA believes it is unlikely that it would result in significant employment impacts.
5.4  Unfunded Mandates Analysis
Among its other purposes and federal agency rulemaking requirements, the Unfunded Mandates Reform Act (UMRA) requires federal agencies, unless otherwise prohibited by law, to assess the effects of their regulatory actions on state, local, and tribal governments and on the private sector, to determine whether any rulemaking may result in "any Federal mandate that may result in the expenditure by State, local, and tribal governments, in the aggregate, or by the private sector, of $100 million or more in any one year."
Section 202 of UMRA requires federal agencies that rules that are likely to exceed this expenditure threshold to prepare a "Written Statement" containing the following five components, supply the statement to OMB, and summarize it in the Federal Register:
 Identification of the applicable authorizing federal law;
 Qualitative and quantitative assessment of the anticipated costs and benefits of the rule including the costs and benefits to state, local, and tribal governments or the private sector, and an analysis of whether federal resources may be available to pay these costs;
 Estimates of future compliance costs and any disproportionate budgetary effects;
 Estimates of effects on the national economy such as productivity, economic growth, employment, job creation, international competitiveness; and
 Description and summary of agency's prior consultation with elected representatives of the affected state, local, and tribal governments.
Determining the private sector and state/local/tribal government shares of the proposed rule's compliance costs requires information on the extent to which regulated entities are owned by these three groups. In compiling the list of U.S. importers and exporters, this RIA did not identify any entities that were owned by state, local, or tribal governments. Nonetheless, based on the magnitude of the rule's estimated cost impacts as reported earlier in this chapter, the estimated cost of the rule would not result in annual expenditures exceeding $100 million for the private sector or state, local, and tribal governments, separately or in aggregate.
5.5  Federalism Analysis
The 1999 Federalism Executive Order 13132 furthers the policies of UMRA by establishing federalism principles, federalism policymaking criteria, and a state and local government consultation process for the development of federal regulations with implications for federalism. These include regulations and other federal policies and actions that have substantial direct effects on states, on the relationship between the federal government and the states, or on the distribution of power and responsibilities among the various levels of government.
Pursuant to the consultation process of Executive Order 13132, this section evaluates whether the rule may "impose substantial direct compliance costs" on state and local governments. EPA's 2008 guidance for compliance with Executive Order 13132 describes two numerical methods for evaluating whether an EPA rule may have federalism implications with respect to "substantial direct compliance costs":
 The $25 million test. Annualized direct compliance cost expenditures to state and local governments in aggregate of $25 million or more.
 The one percent test. Annualized direct compliance costs faced by state and local governments are likely to equal or exceed 1percent of their annual revenues.
As indicated in the UMRA discussion above, this RIA does not estimate any costs of the rule for state and local governments because there are no direct costs anticipated for state agencies and no government-owned entities were identified in the regulated universe. Thus, the rule would not result in substantial direct compliance costs, as defined in the EPA guidance, for entities owned by state and local governments.
EPA does not estimate that the rule would affect the relationship between the federal government and the states or on the distribution of power and responsibilities among the various levels of government.

5.6  Tribal Governments Analysis
Executive Order 13175, entitled "Consultation and Coordination with Indian Tribal Governments" (65 FR 67249, November 9, 2000), requires EPA to develop an accountable process to ensure "meaningful and timely input by tribal officials in the development of regulatory policies that have tribal implications." As indicated in the UMRA discussion above, EPA does not estimate any costs of the rule for state and local governments. Based on these results, the rule is not expected to impose a substantial burden on tribal governments.
5.7  Environmental Justice Analysis
Executive Order 12898 (59 FR 7629, Feb. 16, 1994) directs federal agencies, to the greatest extent practicable and permitted by law, to make environmental justice part of their mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of their programs, policies, and activities on minority populations and low-income populations in the United States. Among other actions, the Order directs agencies to improve research and data collection regarding health and environmental effects in minority and low-income communities.
EPA does not estimate that the rule would result in disproportionately high or adverse impacts for minority or low-income populations. Overall, the Agency anticipates that the rule would reduce any adverse effects associated with the management of hazardous waste, thus benefiting minority and low-income populations. As the rule encourages environmentally sound recovery of hazardous wastes, it will likely reduce the risks associated with treatment, disposal, and recovery. In addition, by strengthening notification, tracking, and reporting requirements, the rule will ensure that hazardous wastes are managed at facilities with appropriate technologies and controls.
5.8  Children's Health Protection Analysis
Executive Order 13045, entitled "Protection of Children from Environmental Health Risks and Safety Risks" (62 FR. 19885, April 23, 1997) applies to any rule that: (1) is determined to be "economically significant" as defined under Executive Order 12866, or (2) concerns an environmental health or safety risk that EPA has reason to believe may have a disproportionate effect on children. If the regulatory action meets both criteria, the Agency must evaluate the environmental health or safety effects of the planned rule on children, and explain why the planned regulation is preferable to other potentially effective and reasonably feasible alternatives considered by the Agency.
EPA does not anticipate that the rule would lead to a disproportionate negative impact on children. As described in the Environmental Justice section above, the rule improves the information available to EPA through notification, tracking, and reporting requirements, and provides for environmentally sound disposal and recovery. Therefore, EPA expects that the rule would reduce adverse impacts on children's health, both in the United States and in foreign countries.
5.9  Energy Impact Analysis
Executive Order 13211, "Actions Concerning Regulations that Affect Energy Supply, Distribution, or Use" (May 18, 2001), addresses the need for regulators to more fully consider the potential energy impacts of regulatory action. Under this Executive Order, agencies are required to prepare a Statement of Energy Effects when a regulatory action may have significant adverse effects on energy supply, distribution, or use, including impacts on price and foreign supplies. Additionally, the requirements obligate agencies to consider reasonable alternatives to regulatory actions with adverse effects and the impacts that such alternatives might have on energy supply, distribution, or use.
The rule would not directly regulate energy production or consumption. In addition, with annualized costs of approximately $99,000 to $334,000, this rule is not considered an economically significant action under Executive Order 12866.
Changes in the management of hazardous waste resulting from the rule are not expected to significantly impact energy production or distribution, as these changes relate only to reporting. More stringent reporting requirements may lead to changes in the management practices of hazardous waste in foreign countries, although the effect of these changes on energy use and generation is uncertain and likely to be minimal. Aside from the potential change in waste management practices described above, the requirements of the rule would have minimal impact on energy consumption; therefore, the rule is not expected to have a significant adverse effect on energy supply, distribution, or use. In addition, no measurable adverse impacts are expected on energy prices or foreign supplies.
5.10  Joint Impacts of Rules
The joint impacts of the Website and Revisions rules are presented in this RIA (see Chapter 6).  In addition, some of the exporters and importers regulated by the Website rule are also subject to other RCRA requirements. Combined, the change to the import-export requirements and existing regulations for hazardous waste generators and transporters would ensure that the management of waste by these entities subject to both sets of regulations is protective of human health and the environment.

CHAPTER 6  |  Joint Impacts of Rules
This chapter presents the cumulative cost impacts of both the Revisions and Website rule for two potential implementation dates. Exhibit 6-1 presents the total annualized costs and cost savings of the proposed Website rule and Revisions rule by provision using a seven percent discount rate and assuming the electronic system is implemented in 2018. Exhibit 6-2 presents the total annualized costs and cost savings of the rules by provision using a seven percent discount rate and assuming the electronic system is implemented in 2022. Exhibit 6-3 presents the cumulative cost of compliance as compared with the average NAICS revenue of potentially affected small businesses. This analysis supplements the regulatory flexibility analysis reported in Section 5.2 and estimates the burden on small businesses as a result of joint impacts of both rules.
EXHIBIT 6-1.	Total Annualized Costs of the Proposed Website Rule and Revisions Rule by Provision ($2015) using a seven percent discount rate  -  2018 Electronic System Implementation Year
                                    ROW[A]
                                 PROVISION[B]
                           TOTAL ANNUALIZED COSTS[C]
                       TOTAL ANNUALIZED COST SAVINGS[D]
                               NET COSTS[E=C-D]
                                REVISIONS RULE
                                       1
Reading the Rule
                                                                       $12,804
                                                                            $0
                                                                       $12,804
                                       2
CDX Registration
                                                                        $5,386
                                                                            $0
                                                                        $5,386
                                       3
Export/Import Notices
                                                                       $24,693
                                                                        $3,058
                                                                       $21,635
                                       4
Re-notifications
                                                                          $184
                                                                            $0
                                                                          $184
                                       5
Annual Report
                                                                          $232
                                                                        $2,184
                                                                       ($1,951)
                                       6
Contracts
                                                                       $31,161
                                                                            $0
                                                                       $31,161
                                       7
Provide Acknowledgment of Consent to Transporter
                                                                            $0
                                                                      $467,034
                                                                     ($467,034)
                                       8
Exception Report[2]
                                                                           $11
                                                                           $10
                                                                            $0
                                       9
Movement Document
                                                                    $1,361,947
                                                                           $35
                                                                    $1,361,912
                                      10
Certificate of Recovery
                                                                      $180,176
                                                                           $35
                                                                      $180,141
                                      11
Return of Wastes
                                                                            $0
                                                                            $0
                                                                            $0
                                      12
Exemption for Wastes Destined for Laboratory Analysis
                                                                          $338
                                                                           $18
                                                                          $320
                                      13
AES Requirements
                                                                            $0
                                                                            $0
                                                                            $0
                                      14
Obtain EPA IDs (recognized traders)
                                                                           $14
                                                                            $0
                                                                           $14
                                      15
Sub-total: Industry Costs
                                                                    $1,616,945
                                                                      $472,374
                                                                    $1,144,571
                                      16
Agency Costs
                                                                      $824,877
                                                                      $238,416
                                                                      $586,461
                                      17
Revisions Rule Sub-Total[3]
                                                                    $2,441,822
                                                                      $710,790
                                                                    $1,731,032
                             PROPOSED WEBSITE RULE
                                      18
Reading the rule
                                                                       $11,077
                                                                            $0
                                                                       $11,077
                                      19
Posting confirmations of receipts and recovery to website
                                                                       $69,285
                                                                            $0
                                                                       $69,285
                                      20
Website development
                                                                       $18,947
                                                                            $0
                                                                       $18,947
                                      21
Proposed Website Rule Sub-Total[3]
                                                                       $99,309
                                                                            $0
                                                                       $99,309
                     REVISIONS AND PROPOSED WEBSITE  RULES
                                      22
Total Costs[3]
                                                                     $2,541,132
                                                                       $710,790
                                                                     $1,830,341
Notes:
 Costs and cost savings for the Revisions rule are annualized over 20-year time horizon. Costs and cost savings for the Proposed website rule are annualized over 5-year time horizon.
 Unless otherwise noted, values in this RIA reflect the assumption that 20 exception reports will be submitted.  The companion Revisions rule RIA includes an additional cost estimate for the submittal of 200 exception reports.
 Totals may not sum due to rounding. Numbers in parentheses indicate a net cost savings.

Exhibit 6-2.	Total Annualized Costs of the Proposed Website Rule and Revisions Rule by Provision ($2015) using a seven percent discount rate  -  2022 Electronic System Implementation Year
                                    ROW[A]
                                 PROVISION[B]
                           TOTAL ANNUALIZED COSTS[C]
                       TOTAL ANNUALIZED COST SAVINGS[D]
                               NET COSTS[E=C-D]
                                REVISIONS RULE
                                       1
Reading the Rule
                                                                       $12,804
                                                                            $0
                                                                       $12,804
                                       2
CDX Registration
                                                                        $5,214
                                                                            $0
                                                                        $5,214
                                       3
Export/Import Notices
                                                                       $22,729
                                                                        $3,058
                                                                       $19,671
                                       4
Re-notifications
                                                                          $184
                                                                            $0
                                                                          $184
                                       5
Annual Report
                                                                          $232
                                                                        $2,184
                                                                       ($1,951)
                                       6
Contracts
                                                                       $31,161
                                                                            $0
                                                                       $31,161
                                       7
Provide Acknowledgment of Consent to Transporter
                                                                            $0
                                                                      $467,034
                                                                     ($467,034)
                                       8
Exception Report[2]
                                                                            $7
                                                                           $10
                                                                           ($3)
                                       9
Movement Document
                                                                    $1,361,947
                                                                           $24
                                                                    $1,361,923
                                      10
Certificate of Recovery
                                                                      $121,128
                                                                           $24
                                                                      $121,104
                                      11
Return of Wastes
                                                                            $0
                                                                            $0
                                                                            $0
                                      12
Exemption for Wastes Destined for Laboratory Analysis
                                                                          $338
                                                                           $12
                                                                          $326
                                      13
AES Requirements
                                                                            $0
                                                                            $0
                                                                            $0
                                      14
Obtain EPA IDs (recognized traders)
                                                                           $14
                                                                            $0
                                                                           $14
                                      15
Sub-total: Industry Costs
                                                                    $1,555,758
                                                                      $472,345
                                                                    $1,083,412
                                      16
Agency Costs
                                                                      $824,874
                                                                      $238,416
                                                                      $586,458
                                      17
Revisions Rule Sub-Total[3]
                                                                    $2,380,632
                                                                      $710,762
                                                                    $1,669,871
                             PROPOSED WEBSITE RULE
                                      18
Reading the rule
                                                                       $11,077
                                                                            $0
                                                                       $11,077
                                      19
Posting confirmations of receipts and recovery to website
                                                                      $303,968
                                                                            $0
                                                                      $303,968
                                      20
Website development
                                                                       $18,947
                                                                            $0
                                                                       $18,947
                                      21
Proposed Website Rule Sub-Total[3]
                                                                      $333,993
                                                                            $0
                                                                      $333,993
                     REVISIONS AND PROPOSED WEBSITE  RULES
                                      22
Total Costs[3]
                                                                     $2,714,625
                                                                       $710,762
                                                                     $2,003,863
Notes:
 Costs and cost savings for the Revisions rule are annualized over 20-year time horizon. Costs and cost savings for the Proposed website rule are annualized over 5-year time horizon.
 Unless otherwise noted, values in this RIA reflect the assumption that 20 exception reports will be submitted.  The companion Revisions rule RIA includes an additional cost estimate for the submittal of 200 exception reports.
 Totals may not sum due to rounding. Numbers in parentheses indicate a net cost savings.

EXHIBIT 6-3.	PROFILE of small businesses affected by the rules and associated joint cost of compliance as a percent of Average annual revenues
                                  Entity type
                                  NAICS Code
                               NAICS Description
                       Number of Potentially Small Firms
                    Average NAICS revenue ($2015 Millions)
               combined first year cost of compliance ($2015)[1]
            combined first year cost as percent of average revenue
                      Firms affected at
1 percent level
                      Firms affected at
3 percent level
Exporters
                                    211111
Crude Petroleum and Natural Gas Extraction
                                       4
                                   $520 [2]
                                  $2,809.27
                                    0.0005%
                                     None
                                     None

                                    324110
Petroleum Refineries
                                      10
                                    $7,700
                                  $2,809.27
                                   0.00004%
                                     None
                                     None

                                    325180
Other Basic Inorganic Chemical Manufacturing
                                       1
                                   $520 [2]
                                  $2,809.27
                                    0.0005%
                                     None
                                     None

                                    325199
All Other Basic Organic Chemical Manufacturing
                                       3
                                    $1,200
                                  $2,809.27
                                    0.0002%
                                     None
                                     None

                                    325211
Plastics Material and Resin Manufacturing
                                       2
                                    $1,100
                                  $2,809.27
                                    0.0003%
                                     None
                                     None

                                    325510
Paint and Coating Manufacturing
                                       1
                                     $210
                                  $2,809.27
                                    0.0013%
                                     None
                                     None

                                    325992
Photographic Film, Paper, Plate, and Chemical Manufacturing
                                       1
                                     $420
                                  $2,809.27
                                    0.0007%
                                     None
                                     None

                                    326150
Urethane and Other Foam Product (except Polystyrene) Manufacturing
                                       1
                                      $83
                                  $2,809.27
                                    0.0034%
                                     None
                                     None

                                    327213
Glass Container Manufacturing
                                       1
                                     $120
                                  $2,809.27
                                    0.0023%
                                     None
                                     None

                                    331110
Iron and Steel Mills and Ferroalloy Manufacturing
                                       5
                                    $1,000
                                  $2,809.27
                                    0.0003%
                                     None
                                     None

                                    331512
Steel Investment Foundries
                                       1
                                      $77
                                  $2,809.27
                                    0.0036%
                                     None
                                     None

                                    332911
Industrial Valve Manufacturing
                                       1
                                     $120
                                  $2,809.27
                                    0.0023%
                                     None
                                     None

                                    334519
Other Measuring and Controlling Device Manufacturing
                                       1
                                      $46
                                  $2,809.27
                                    0.0061%
                                     None
                                     None

                                    335314
Relay and Industrial Control Manufacturing
                                       2
                                     $160
                                  $2,809.27
                                    0.0018%
                                     None
                                     None

                                    335912
Primary Battery Manufacturing
                                       4
                                     $310
                                  $2,809.27
                                    0.0009%
                                     None
                                     None

                                    336320
Motor Vehicle Electrical and Electronic Equipment Manufacturing
                                       1
                                   $520 [2]
                                  $2,809.27
                                    0.0005%
                                     None
                                     None

                                    336360
Motor Vehicle Seating and Interior Trim Manufacturing
                                       1
                                     $320
                                  $2,809.27
                                    0.0009%
                                     None
                                     None

                                    336412
Aircraft Engine and Engine Parts Manufacturing
                                       1
                                     $400
                                  $2,809.27
                                    0.0007%
                                     None
                                     None
Exporters (Continued)
                                    339112
Surgical and Medical Instrument Manufacturing
                                       1
                                     $130
                                  $2,809.27
                                    0.0022%
                                     None
                                     None

                                    423930
Recyclable Material Merchant Wholesalers
                                      14
                                   $520 [2]
                                  $2,809.27
                                    0.0005%
                                     None
                                     None

                                    424690
Other Chemical and Allied Products Merchant Wholesalers
                                       3
                                   $520 [2]
                                  $2,809.27
                                    0.0005%
                                     None
                                     None

                                    522220
Sales Financing
                                       2
                                      $20
                                  $2,809.27
                                    0.014%
                                     None
                                     None

                                    541512
Computer Systems Design Services
                                       2
                                      $14
                                  $2,809.27
                                    0.020%
                                     None
                                     None

                                    541710
Research and Development in the Physical, Engineering, and Life Sciences
                                       1
                                   $520 [2]
                                  $2,809.27
                                    0.0005%
                                     None
                                     None

                                    541711
Research and Development in Biotechnology
                                       4
                                     $7.8
                                  $2,809.27
                                    0.036%
                                     None
                                     None

                                    561210
Facilities Support Services
                                       2
                                      $20
                                  $2,809.27
                                    0.014%
                                     None
                                     None

                                    561910
Packaging and Labeling Services
                                       1
                                     $5.7
                                  $2,809.27
                                    0.049%
                                     None
                                     None

                                    561990
All Other Support Services
                                       1
                                     $5.7
                                  $2,809.27
                                    0.049%
                                     None
                                     None

                                    562112
Hazardous Waste Collection
                                       3
                                      $20
                                  $2,809.27
                                    0.014%
                                     None
                                     None

                                    562211
Hazardous Waste Treatment and Disposal
                                       8
                                      $20
                                  $2,809.27
                                    0.014%
                                     None
                                     None

                                    562920
Materials Recovery Facilities
                                       1
                                      $11
                                  $2,809.27
                                    0.026%
                                     None
                                     None

                                    721110
Hotels (except Casino Hotels) and Motels
                                       1
                                      $17
                                  $2,809.27
                                    0.017%
                                     None
                                     None

Unknown
                                       2
                                   $520 [2]
                                  $2,809.27
                                    0.0005%
                                     None
                                     None

EXPORTERS TOTAL
                                      87

Importers
                                    212291
Uranium-Radium-Vanadium Ore Mining
                                       1
                                    $16 [2]
                                  $6,534.36
                                    0.041%
                                     None
                                     None

                                    423930
Recyclable Material Merchant Wholesalers
                                       1
                                    $16 [2]
                                  $6,534.36
                                    0.041%
                                     None
                                     None

                                    541711
Research and Development in Biotechnology
                                       1
                                     $7.8
                                  $6,534.36
                                    0.084%
                                     None
                                     None

                                    562119
Other Waste Collection
                                       2
                                      $20
                                  $6,534.36
                                    0.033%
                                     None
                                     None

                                    562211
Hazardous Waste Treatment and Disposal
                                       5
                                      $20
                                   $6,534.36
                                    0.033%
                                     None
                                     None

Unknown
                                       6
                                    $16 [2]
                                   $6,534.36
                                    0.041%
                                     None
                                     None

IMPORTERS TOTAL
                                      16

Notes:
1.  Average first year cost of compliance for each Exporter and Importer firm was calculated as a weighted average within each entity type. The components of the weighted average are the average costs per entity exporting or importing to Canada, Mexico, OECD nations, and non-OECD nations. Each of these cost values were weighted based on the proportion of the total potentially small entity universe exporting or importing to each of these categories.
2.  Within each Exporters and Importers, the average annual revenue calculated from all known NAICS code entities was applied to entities in NAICS codes with unknown annual revenues, and to entities with unknown NAICS codes. This value is $520 million for Exporters and $16 million for Importers.

APPENDIX A  |  Cost Impacts by Year
Exhibits A-1 and A-2 report the cost impacts of the proposed Website rule by year using discount rates of three and seven percent .
EXHIBIT A-1.COSTS OF THE PROPOSED RULE BY ENTITY TYPE AND YEAR - 2018 ELECTRONIC SYSTEM IMPLEMENTATION DATE
                                  TOTAL COSTS
                                     YEAR
                                  ENTITY TYPE
                                     TOTAL

                              Exporters - Canada
                              Exporters - Mexico
                             Exporters - Non-OECD
                               Exporters - OECD
                              Importers - Canada
                              Importers - Mexico
                             Importers - Non-OECD
                               Importers - OECD

                                                                           2017
                                                                      $228,711
                                                                      $142,646
                                                                            $0
                                                                       $20,190
                                                                       $33,800
                                                                        $7,727
                                                                        $1,541
                                                                         $1,076
                                                                      $435,692
                                                         Total
(Undiscounted)
                                                                       $228,711
                                                                       $142,646
                                                                             $0
                                                                        $20,190
                                                                        $33,800
                                                                         $7,727
                                                                         $1,541
                                                                         $1,076
                                                                       $435,692
                                                   PV Total
(3% discount rate)
                                                                       $228,711
                                                                       $142,646
                                                                             $0
                                                                        $20,190
                                                                        $33,800
                                                                         $7,727
                                                                         $1,541
                                                                         $1,076
                                                                       $435,692
                                                    PV Total
(7% discount rate)
                                                                       $228,711
                                                                       $142,646
                                                                             $0
                                                                        $20,190
                                                                        $33,800
                                                                         $7,727
                                                                         $1,541
                                                                         $1,076
                                                                       $435,692
                                          Annualized Cost[1]
(3% discount rate)
                                                                        $48,486
                                                                        $30,240
                                                                             $0
                                                                         $4,280
                                                                         $7,165
                                                                         $1,638
                                                                           $327
                                                                           $228
                                                                        $92,364
                                        Annualized Cost[1]
(7% discount rate)
                                                                        $52,131
                                                                        $32,514
                                                                             $0
                                                                         $4,602
                                                                         $7,704
                                                                         $1,761
                                                                           $351
                                                                           $245
                                                                        $99,309
Notes:
 Costs and cost savings are annualized over five years.
EXHIBIT A-2.COSTS OF THE PROPOSED RULE BY ENTITY TYPE AND YEAR - 2022 ELECTRONIC SYSTEM IMPLEMENTATION DATE
                                  TOTAL COSTS
                                     YEAR
                                  ENTITY TYPE
                                     TOTAL

                              Exporters - Canada
                              Exporters - Mexico
                             Exporters - Non-OECD
                               Exporters - OECD
                              Importers - Canada
                              Importers - Mexico
                             Importers - Non-OECD
                               Importers - OECD

                                                                           2017
                                                                      $228,711
                                                                      $142,646
                                                                            $0
                                                                       $20,190
                                                                       $33,800
                                                                        $7,727
                                                                        $1,541
                                                                        $1,076
                                                                      $435,692
                                                                           2018
                                                                      $135,093
                                                                      $137,069
                                                                            $0
                                                                       $11,310
                                                                       $18,087
                                                                        $1,509
                                                                          $478
                                                                          $421
                                                                      $303,968
                                                                           2019
                                                                      $135,093
                                                                      $137,069
                                                                            $0
                                                                       $11,310
                                                                       $18,087
                                                                        $1,509
                                                                          $478
                                                                          $421
                                                                      $303,968
                                                                           2020
                                                                      $135,093
                                                                      $137,069
                                                                            $0
                                                                       $11,310
                                                                       $18,087
                                                                        $1,509
                                                                          $478
                                                                          $421
                                                                      $303,968
                                                                           2021
                                                                      $135,093
                                                                      $137,069
                                                                            $0
                                                                       $11,310
                                                                       $18,087
                                                                        $1,509
                                                                          $478
                                                                          $421
                                                                      $303,968
                                                          Total
(Undiscounted)
                                                                       $769,084
                                                                       $690,923
                                                                             $0
                                                                        $65,430
                                                                       $106,148
                                                                        $13,764
                                                                         $3,454
                                                                         $2,761
                                                                      $435,692
                                                   PV Total
(3% discount rate)
                                                                       $730,866
                                                                       $652,146
                                                                             $0
                                                                        $62,230
                                                                       $101,031
                                                                        $13,337
                                                                         $3,319
                                                                         $2,642
                                                                     $1,565,571
                                                    PV Total
(7% discount rate)
                                                                       $686,300
                                                                       $606,929
                                                                             $0
                                                                        $58,499
                                                                        $95,064
                                                                        $12,839
                                                                         $3,161
                                                                         $2,503
                                                                     $1,465,296
                                          Annualized Cost[1]
(3% discount rate)
                                                                       $154,940
                                                                       $138,252
                                                                             $0
                                                                        $13,192
                                                                        $21,418
                                                                         $2,827
                                                                           $704
                                                                           $560
                                                                       $331,893
                                         Annualized Cost[1]
(7% discount rate)
                                                                       $156,432
                                                                       $138,340
                                                                             $0
                                                                        $13,334
                                                                        $21,668
                                                                         $2,926
                                                                           $721
                                                                           $571
                                                                       $333,993
Notes:
 Costs and cost savings are annualized over five years.