1 Originally submitted on September 29, 2023

Originally submitted on September 29, 2023 | Revised and resubmitted February 26, 2024 and June 10, 2024

SUBMITTED BY:

Ryan Trainer

Mattress Recycling Council Oregon, LLC

501 Wythe Street

Alexandria, VA 22314

1-855-229-1691

SUBMITTED TO:

Oregon Department of Environmental Quality

Leah Feldon, Director

700 NE Multnomah St, Suite 600

Portland, OR 97232

June 10, 2024

Oregon Department of Environmental Quality

Leah Feldon, Director

700 NE Multnomah St, Suite 600

Portland, OR 97232

Dear Director Feldon,

The Mattress Recycling Council Oregon, LLC (MRC) is pleased to submit this Revised Mattress

Stewardship Program Plan.

By letter dated April 11, 2024, the Oregon Department of Environmental Quality (DEQ) informed

MRC that it had rejected MRC’s revised Program Plan submitted on February 26, 2024. This

Revised Program Plan addresses each of the points raised in DEQ’s letter.

MRC’s parent organization, the Mattress Recycling Council, Inc., is the largest mattress recycling

organization in North America. Its state programs in California, Connecticut and Rhode Island

have recycled over 13 million mattresses and box springs since 2015. As an organization, our

mission has evolved beyond the mechanics of mattress recycling to include collaborating with

the mattress industry on circular design and other sustainability initiatives and a variety of

research projects to improve mattress recycling processes and expand the markets for recycled

mattress materials. We look forward to working with DEQ to implement our program in Oregon.

Please contact me should you have any questions.

Sincerely,

Ryan Trainer

MRC President

PLAN OUTLINE .................................................................................................... 4

Part 1 – Definitions ........................................................................................................................... 4

Part 2 – Background ........................................................................................................................ 8

Part 3 - Implementation Timeline ..................................................................................................... 9

Part 4 - Program Operations .......................................................................................................... 14

Part 5 – Collection .......................................................................................................................... 21

Part 6 - Performance Goals ........................................................................................................... 29

Part 7 - Program Administration .................................................................................................... 29

Part 8 – Budget .............................................................................................................................. 35

Part 9 - Assessment Fee ................................................................................................................ 37

Part 10 - Illegal Dumping ............................................................................................................... 38

Part 11 - Public Education, Advertising, Promotion ....................................................................... 40

Part 12 - Closure Plan .................................................................................................................... 46

Part 13 – Coordination ................................................................................................................... 46

Part 14 - Program Changes ........................................................................................................... 46

Part 15 - Contact and Certifying Certification ................................................................................. 47

SUPPLEMENTAL INFORMATION .............................................................................. 48

Non-profit Status Documentation .................................................................................................. 48

Liability Insurance .......................................................................................................................... 48

APPENDICES ..................................................................................................... 50

A. Registered Producers, Renovators and Retailers ..................................................................... 50

B. Collection Site Requirements ............................................................................................................................ 65

C. Recycling Standards ................................................................................................................. 77

D. Interested Collection Site Participants ...................................................................................... 82

E. Prospective Site Information Examples .................................................................................... 84

F. Budget ....................................................................................................................................................................... 86

Table of Contents

The Mattress Recycling Council Oregon, LLC (MRC) hereby submits its Mattress

Stewardship Program Plan (Plan) to Oregon Department of Environmental Quality (DEQ),

following the format specified in DEQ’s Plan Guide for the Mattress Stewardship Program,

provided to MRC on August 29, 2023.

Part 1 - Definitions

a. The plan should state that it uses and incorporates the definitions from the Act and the related

administrative rules in Chapter 340, Division 98 of the Oregon Administrative Rules.

b. Definitions for all other terms used in the plan should be listed in this section.

This Plan uses and incorporates definitions from Section 2 of the Act, including the

following (which are quoted verbatim from the Act below):

Section 2(3):

“Discarded mattress” means a mattress that has been used, and abandoned or

discarded, in this state.

Section 2(4):

“Environmentally sound management” includes, but is not limited to, the following

management practices, implemented in a manner that is designed to protect public

health and safety and the environment:

(a) Adequate record keeping;

(b) Keeping detailed documentation of the methods used to:

(A) Manage discarded mattresses; and

(B) Track and document the fate of discarded mattresses from

collection through final disposition within this state and outside this

state;

parties as determined by a stewardship organization;

(d) Compliance with worker health and safety requirements; and

(e) Maintenance of adequate liability insurance for a stewardship

organization and contractors working for the stewardship organization.

Section 2(6):

“Foundation” means a ticking-covered structure that is used to support a mattress

or sleep surface and that may be constructed of frames, foam, box springs or other

materials, used alone or in combination.

Plan Outline

Section 2(7):

(a)

“Mattress” means:

(A)

A resilient material or combination of materials that is enclosed by a ticking, is

used alone or in combination with other products and is intended for or

promoted for sleeping upon; or

(B)

A foundation.

(b)

“Mattress” does not mean:

(A)

An unattached mattress pad or unattached mattress topper, with or without

resilient filling or ticking, that is intended to be used with or on top of a

mattress;

(B)

A sleeping bag;

(C)

A pillow;

(D)

A car bed, crib mattress or bassinet mattress;

(E)

A carriage, basket, dressing table, stroller, playpen, infant carrier, lounge pad,

crib bumper or other product manufactured for young children or the pad for a

product described in this subparagraph;

(F)

A waterbed, an air mattress or another that contains liquid- or gas-filled ticking

and that does not contain upholstery material between the ticking and the

mattress core, or

(G)

A foldout sofa bed, futon, futon mattress or upholstered furniture.

Section (2)(15):

“Producer” means any person, irrespective of the selling technique used, including

that of remote sale, that:

(A)

Manufactures a mattress that is sold, offered for sale or distributed in this

state;

(B)

Is the owner of a trademark or brand under which a mattress is sold, offered

for sale or distributed in this state, whether or not such trademark or brand is

registered in this state; or

(C)

Imports a mattress into the United States that is sold or offered for sale in the

state.

Section (2)(16):

(a) “Program mattress” means a discarded mattress that a stewardship organization

will provide environmentally sound management for under a mattress stewardship

program.

(b) “Program mattress” does not mean a mattress transported from outside this state

to be discarded in this state.

Section 2(17):

(a)

“Renovate” means to alter a discarded mattress for resale through replacing the

ticking or filling, adding additional filling or replacing components of the discarded

mattress with new or recycled materials.

(b)

“Renovate” does not mean:

(A)

Stripping a discarded mattress of the ticking or filling without adding new

material; or

(B)

The sanitization or sterilization of a discarded mattress without other

alteration to the discarded mattress.

Section 2(18):

"Renovator" means a person that renovates discarded mattresses.

Section 2(19):

“Retailer” means a person that offers new, used or renovated mattresses for retail

sale.

Section 2(20):

“Retail sale” means sale to a consumer in this state by any means and for any

purpose other than resale, including but not limited to sale by remote offerings such

as sales outlets, catalogs or the Internet.

Section 2(23):

“Stewardship organization” means a nonprofit organization designated by a

producer or group of producers to implement a mattress stewardship program.

In addition, the Plan uses and incorporates the following terms defined in Oregon Revised

Statutes (ORS):

ORS 174.116(1)(a):

“Local government” means all cities, counties and local service districts located in

this state, and all administrative subdivisions of those cities, counties and local

service districts.

ORS 459.005(3):

“Collection service” means a service that provides for collection of solid waste or

recyclable material or both but does not include that part of a business operated

under a certificate issued under ORS 822.110 (Dismantler certificate).

ORS 459.005(21):

“Recycling” means any process by which solid waste materials are transformed into

new products in a manner that the original products may lose their identity.

ORS 459.005(24):

“Reuse” means the return of a commodity into the economic stream for use in the

same kind of application as before without change in its identity.

ORS 459A.085:

"Collection service franchise holder” as described under ORS 459A.085.

In addition, for purposes of this Plan:

“Act” means the “Mattress Stewardship Act, SB 1576 (2022).”

“Collection Site” means a physical location designated by MRC for the purpose of

collecting or receiving Discarded Mattresses. Collection sites may include, but are

not limited to, Collection Events.

“Collector” means a party that collects one or more Mattresses discarded in

Oregon and delivers them to a Collection Site or Recycler.

“DEQ” refers to the Oregon Department of Environmental Quality.

“MRC Inc.” refers to Mattress Recycling Council, Inc., a tax-exempt non-profit

corporation incorporated in the state of Delaware.

“MRC” refers to Mattress Recycling Council Oregon, LLC, a limited liability company

that MRC Inc. created to design and implement the Oregon mattress stewardship

program.

“Plan” refers to a document filed with DEQ that describes how a stewardship

organization will develop and implement a mattress stewardship program in Oregon

and that contains the information specified in Section 4(1) of the Act.

“Program” refers to the Oregon mattress stewardship program that MRC will

implement.

“Rural areas” refers to counties that have a population of less than 10,000 people,

as described in Section 5(1) of the Act.

“Unit” is synonymous with the term “mattress,” and collectively refers to mattresses

and foundations.

“Urban areas” refers to counties that have a population of 10,000 people or more,

as described in Section 5(1) of the Act.

Part 2 - Background

Describe any relevant information about the stewardship organization, including but limited to, how

the organization meets the definition of “stewardship organization” under the Act, its organizational

structure, and its history and success with mattress stewardship programs in other jurisdictions

and relevant program experience.

Section 2(23) of the Act defines the term “stewardship organization” to mean “a nonprofit

organization designated by a producer or group of producers to implement a mattress

stewardship program.” MRC meets this definition.

The International Sleep Products Association (ISPA) is the trade association for mattress

manufacturers and suppliers of components and services to the mattress industry whose

members manufacture mattresses sold in the United States, including Oregon. In 2013,

ISPA formed the Mattress Recycling Council Inc. (MRC Inc.) to design, implement and

administer stewardship programs in three states that had enacted mattress stewardship

laws, California, Connecticut and Rhode Island. MRC Inc. is a tax-exempt non-profit

corporation incorporated in the state of Delaware.

Subsequently, MRC Inc. spun off each of these statewide programs into state-specific

limited liability company (LLC) affiliates. In 2022, MRC Inc. established another LLC

affiliate, the Mattress Recycling Council Oregon, LLC (MRC), as a separate limited liability

company to design and implement the Oregon mattress stewardship program (Program)

and submit this Plan. Both MRC Inc. and MRC are non-profit entities and MRC is

authorized to transact business in Oregon.

Therefore, as required by the Act’s definition of “stewardship organization,” MRC Inc. is a

non-profit organization created by ISPA (a group of mattress producers) to implement

mattress stewardship programs. MRC is a non-profit affiliate of MRC Inc. created

specifically to design and implement the Oregon mattress stewardship program. As such,

MRC meets the requirements of Section 2(23) of the Act.

MRC Inc. launched its first program in Connecticut in 2015, followed by the launch of the

California program later that year and the Rhode Island program in 2016. Since inception,

these state mattress recycling programs have collectively recycled over 13 million

mattresses and foundations (collectively Units), and recycled over 500 million pounds of

steel, foam, wood, fabric and fiber that can be used to make new products. If landfilled,

these units would have consumed over 12.9 million cubic yards of landfill capacity. On

average, the existing state-specific programs are recycling over 70% of the weight of each

unit collected.

Based on a recently completed study of the California mattress recycling program, each

unit recycled saves 500 gallons of water, enough energy to power an average household

for three days and the greenhouse gas emissions savings similar to driving 60 fewer miles.

MRC Inc. (including its state-specific affiliates) is internationally recognized as a leader in

mattress recycling. We look forward to bringing our experience to implementing the Oregon

mattress stewardship Program mandated by the Act.

Part 3 – Implementation Timeline

Provide an implementation timeline with deliverables and milestones from program initiation

through the term of the plan. Per the Act, a stewardship organization must implement a mattress

stewardship program as described in its initial plan no later than seven months after the plan is

approved by DEQ. The timeline should include dates and deliverables for the first seven months of

implementation.

MRC’s deliverables and milestones from Plan approval, through Program launch and the

end of the Plan term are as follows:

Completed Prior to Plan Submission

• In 2015, MRC launched an online registration and reporting portal

(MRCreporting.org) for retailers, manufactures, renovators and other obligated

entities to register their company, submit brand/URN information, report units sold

and remit collected mattress recycling fees. It is currently used by MRC’s California,

Connecticut and Rhode Island programs.

o In 2023, MRC scaled MRCreporting.org to allow obligated Oregon entities to

• Creation of websites to inform industry and consumer audiences –

MattressRecyclingCouncil.org (industry) launched in 2014 and ByeByeMattress.com

(consumers) in 2015.

o ByeByeMattress.com hosts a locator for consumers to find their nearest drop-

off location.

o Upon Oregon enacting its law in 2022, MRC added an Oregon page to the

State Programs section on MattressRecyclingCouncil.org.

• In 2022, MRC began gathering contact information from various sources for entities

fitting the Act’s definition of retailer, producer and renovator in order to build a

mailing list. Initial communications were issued once MRCreporting.org’s Oregon

registration functionality was completed.

• In 2023, MRC hired a program coordinator to prepare for a 2024 Program launch.

Completed tasks include:

o Surveyed all known Oregon solid waste facilities and other potential collection

sites to assess interest in becoming a public collection site.

o Created MRC branded marketing materials to aid the coordinator in

conversations and meetings.

o Released RFP for mattress recycling to assess interest, capabilities and costs

for recycling units collected by the Program.

o Released RFP for transportation to assess interest, capabilities and costs for

transporting units collected by the Program.

Following Plan Approval

Within the First 2 weeks of Receiving Plan Approval

These activities would start as soon as MRC’s Plan is approved:

• Issue a press release to mattress and home furnishing industry media and related

industry associations regarding important Program information including the start

date and assessment.

• Issue an email to already registered Oregon participants regarding important

Program information and begin preparing a direct mail campaign to identified,

unregistered retailers, producers and renovators.

• Publish Program start date and assessment amount on MRCreporting.org and

MattressRecyclingCouncil.org and MRC’s social media channels.

• Notify and initiate contracting process with collection sites, transporters and mattress

recyclers.

Within the First 3-4 weeks of Receiving Plan Approval

At this point, MRC expects to have completed these activities:

• Distributed a direct mail letter or postcard to all identified entities not yet registered,

but MRC assumes is obligated to do so. This notification would confirm the start date

and amount of the assessment and urge them to visit MRCreporting.org.

• Issued RFP for media relations consultant for Oregon communications.

Within 2-5 months of Receiving Plan Approval (5-2 Months Prior to Program

Launch)

At this point, MRC would be engaged in the following activities:

• Continue negotiating and securing contracts with collection sites, transporters and

recyclers.

o As collection site and recycler contracts are secured, MRC collects

information regarding desired signage, confirms information to be posted on

ByeByeMattress.com, and engages with city or local officials to prepare for

promoting the location’s participation. Meanwhile, the program coordinator is

sharing resources and conducting site visits to help collection sites

understand how to best accept, handle and prepare mattresses for pickup.

Recyclers and transporters are being onboarded during this time.

• Creating videos for collection sites, transporters and recyclers that accompany the

Program Requirements.

• Securing a contract with a media relations consultant and developing materials

needed to announce the start of the Program.

• Creating Oregon specific point-of-sale materials for retailers to share with their

customers.

• Continuing to issue registration reminders to identified, unregistered retailers,

producers and renovators.

Within 6 months of Receiving Plan Approval (One Month Prior to Program

Launch)

At this point, MRC would be engaged in the following activities:

• Updating MattressRecyclingCouncil.org’s Resources library with Oregon-specific

material including but not limited to Collection Site Requirements and related videos,

point-of-sale materials, publicity toolkits and information sheets.

• Activating Oregon reporting and assessment remittance capabilities in

MRCreporting.org.

• Distributing publicity toolkits to collection sites, recyclers, city/county officials and

interested community-based organizations.

• Delivering retailer point-of-sale materials to all registered retailers.

• Delivering containers and signage to all contracted collection sites.

• Continuing to finalize contracts with prospective collection sites.

• Continuing to issue registration reminders to identified, unregistered retailers,

producers and renovators.

• Establishing internal policies and procedures that outline how MRC will comply with

applicable laws and regulations.

Upon Program Launch

Within seven months of Plan approval, MRC will launch the Program.

On an ongoing basis, MRC will communicate with retailers, producers and renovators

about their legal obligations and recycling opportunities. MRC will also continue to finalize

contracts with interested collection sites and recruit new ones. In counties with a population

of more than 10,000 where MRC has not located at least one required collection site by

Program launch, MRC will schedule at least one collection event as required by Section

5(1)(a)(B) of the Act, to provide convenient collection service.

MRC will begin updating DEQ monthly on relevant changes (including number, name and

address of permanent collection sites, registered retailers and producers, Program

recyclers and reuse organizations managing discarded program mattresses).

Within 2 Weeks After Program Launch

At this point, MRC would be focused on the following activities:

• Publishing Oregon locator listings and Oregon page on ByeByeMattress.com (first

day of Program and ongoing as new sites join)

• Issuing another press release announcing the start of the Program to mattress,

home furnishings and recycling/solid waste industry media and related industry

associations.

• Publishing the Program start announcement on MRC’s websites and social media

channels (then used on an ongoing basis to keep consumer and industry audiences

informed).

• Continuing to assist publicity toolkit recipients as needed (ongoing as new sites join).

• Beginning to inform registered retailers, producers and renovators of how to

complete the reporting and assessment remittance process and recycle.

Within 6 Months After Program Launch

At this point, MRC would be focused on the following activities:

• Distributing a Public Service Announcement to TV and radio stations as described in

Part 11.

• Distributing a press release to Oregon media announcing Program’s availability as

described in Part 11.

Within 7 to 12 Months After Program Launch

At this point, MRC would be focused on the following activities:

• Organizing a media tour/press conference at a collection site or recycler.

• Conducting recycler audits for environmentally sound management practices (2025,

and each year thereafter).

• Identifying Earth Day (April 22) and America Recycles Day (November 15) events

and researching costs and sponsorship benefits.

• Submitting an annual report, annual fee payment, budget and financial audit to DEQ

(annually on July 1).

• Surveying Oregon retailers, producers and renovators regarding awareness of

obligations, use of resources including point-of-sale material and satisfaction with

MRC’s assistance.

• Discussing illegal dumping with Portland Metro and other select communities to

learn where additional resources or tactics might be helpful.

One Year After Program Launch

Once the Program has operated for a full year, MRC will:

• Survey Oregon consumers to collect baseline data regarding Program awareness,

mattress purchasing/disposal behavior, recycling attitudes and media habits that will

inform future communications strategies and materials (after first full year of

Program operations and each year thereafter).

• Begin discussions, research and other activities necessary to accomplish

deliverables included in the Act that must be completed before the end of the Plan’s

term.

Before End of Second Year to End of Plan Term (2026 – 2029)

Per the Act, MRC will:

• Propose Program performance goals to DEQ (no later than two years from Program

launch).

• Propose Program closure plan to DEQ (no later than two years from Program

launch).

• Submit life cycle assessment report to DEQ (include in 2026 annual report to be filed

July 1, 2027) (prior to initiating study, submit study scope of work to DEQ for review

and comment (no later than 90 days before initiating the study) and respond to DEQ

comments (no later than 30 days from the date DEQ sends comments to MRC)).

• Submit report on the scope of discarded mattresses that are not being collected as

part of the Program with recommendations on how to direct the discarded

mattresses to, and include them in the Program (include in 2026 annual report, to be

filed by July 1, 2027) (prior to initiating study, submit study scope of work to DEQ for

review and comment (no later than 90 days before initiating the study) and respond

to DEQ comments (no later than 30 days from the date DEQ sends comments to

MRC)).

• Conduct study in 2026 on most effective methods of providing discarded mattress

collection services to individuals and multifamily housing structures to DEQ (include

in 2026 annual report, to be filed by July 1, 2027) (prior to initiating study, submit

study scope of work to DEQ for review and comment (no later than 90 days before

initiating the study) and respond to DEQ comments (no later than 30 days from the

date DEQ sends comments to MRC).

• Complete statewide illegal mattress dumping census (by December 2026).

• Issue request for proposals for illegal mattress dumping pilot project funding

(annually from 2027 to 2029).

• Submit a Plan for Program years 2029 – 2034 to DEQ (no later than 180 days before

the expiration of the initial Plan).

Part 4 – Program Operations

a) Describe how the stewardship organization will manage a mattress stewardship

program that complies with all federal and state laws applicable to the operation

of the mattress stewardship program, including the Mattress Stewardship Act

and related rules in OAR Chapter 340, Division 98.

MRC will comply with all applicable federal and state laws, including the Mattress

Stewardship Act and OAR rules promulgated pursuant to that statutory authority to

implement the Act.

To comply with federal and state laws, MRC will take the following steps:

1. Understand the Laws: Familiarize ourselves with all applicable federal and state laws

and regulations that apply to mattress recycling.

2. Stay Updated: Given that laws and regulations can change over time, MRC will

promptly review any updates or amendments that may affect our compliance and

where necessary, seek professional advice.

3. Develop Compliance Policies and Procedures: MRC will establish internal policies

and procedures that outline how we will comply with applicable laws and regulations

prior to Program launch.

4. Train Employees and Contractors: As needed, MRC will educate employees and

contracted parties (collection sites, transporters and recyclers) about their roles and

responsibilities related to compliance.

5. Maintain Proper Documentation: MRC will maintain records of our compliance efforts,

including any licenses, contracts and other relevant documents as required by law.

6. Conduct Audits and Assessments: MRC will review and assess our compliance

practices annually to identify potential areas of weakness, non-compliance or

improvement.

b) Describe how program mattresses will be identified.

Section 2(7) of the Act provides a physical definition of a mattress, and includes

“foundations” (defined in Section 2(6) of the Act.) Section 2(16), which defines “program

mattresses,” reads as follows:

(a) “Program mattress” means a discarded mattress that a stewardship organization

will provide environmentally sound management for under a mattress

stewardship program.

(b) “Program mattress” does not mean a mattress transported from outside this

state to be discarded in this state.

Section 2(3) defines “discarded mattress” to mean “a mattress that has been used, and

abandoned or discarded, in this state.”

These provisions are intended to prevent the Program from being burdened by out-of-

state free riders. Therefore, consistent with these statutory definitions, MRC will

consider program mattresses to be those that are discarded in Oregon, provided they

were not transported from outside Oregon for purposes of disposal.

c) Describe how the program will handle discarded mattresses that are received

through collection sites or collection events and that are not program

mattresses, including mattresses from outside the state.

Mattresses are bulky but light weight products that are costly to move long

distances. Collection sites or collection events may receive mattresses that do not

meet the definition of program mattresses and may reject them or discard them as

solid waste at their discretion and at the expense of the delivering entity. If a

collection site places non-program items into Program trailers, the Recycler will

dispose of the items when they are offloaded at the recycling facility. MRC will notify

the collection site of the type and quantity of materials that were disposed and

retrain their staff on identifying non-program items. If a collection site persists in

placing non-program items in a container, MRC may terminate the collection site

from the Program.

Based on the experience of other mattress recycling programs, non-program

mattresses typically originate from neighboring states. The primary source of those

units are out-of-state solid waste haulers and other collectors seeking to free ride on

no-cost recycling services. Therefore, the most likely sources of non-program

mattresses will be from states whose borders are contiguous with Oregon’s.

Oregon shares borders with four states. Since California already has its own

statewide mattress recycling program, the risk of the Program being potentially

burdened by non-program mattresses from California is small. Likewise, the states

of Idaho and Nevada, which also share borders with Oregon, are unlikely sources

for non-program Mattresses because they lack significant population centers near

their border with Oregon. The nearest significant out-of-state population center is in

Washington state near Portland.

To prevent out-of-state free riding, MRC intends (as needed) to require:

• A collection site that accepts mattresses from Oregon and non-Oregon

sources may not participate in the Program unless it agrees in writing to

document which mattresses are Oregon-sourced, segregate those units from

all other solid waste that it collects and provide only the Oregon units to the

Program.

• A collection site that receives non-program mattresses from out of state

sources may reuse, renovate, recycle, landfill or incinerate those units at

their discretion. Non-program mattresses are not part of the Program, and

MRC will not compensate a collection site for handling non-program

mattresses.

• MRC will require that collection sites, transporters and recyclers accept units

from small commercial solid waste haulers that agree in writing to maintain a

compliance log indicating the source of the units they receive. Compliance logs

can help identify out-of-state mattresses entering Oregon for disposal, which are

not program mattresses.

• Commercial entities that provide units to the Program (such as retailers, lodging

establishments, etc.) must agree in writing to MRC not to provide units used and

discarded outside Oregon.

• MRC’s contracts with collection sites and recyclers will require them to

document that they are accepting units only from in-state Oregon sources

and will make clear that MRC will not compensate them for accepting,

handling or processing out-of-state units.

• Provide point-of-sale materials to inform purchasers that a mattress

transported from another state to be discarded in Oregon is ineligible for

MRC-funded recycling through the Program.

d) Identify each producer, renovator and retailer that is registered with the

stewardship organization, as of 30 days before the date of plan submission in

an appendix, that includes the business’ name, physical address, contact

name, phone number and email address.

Section 4(1)(d) of the Act requires that the Plan “[i]dentify each producer, renovator and

retailer that is registered with the stewardship organization.” Consistent with this

provision, MRC will provide the business name, address, contact name, phone number

and email address of these businesses. However, some businesses only have a

primary address at time of registration and may not have a physical address. If the

business does not provide a physical address, the primary address will be provided.

Appendix A contains a list of company names, primary or physical addresses, email

addresses and phone numbers of each producer, renovator and retailer that have

registered with the Program as of May 31, 2024 (30 days before the revised Plan

submittal). This list will continue to grow as important Program milestones are reached,

including DEQ’s approval of the Plan, announcement of the assessment and the

Program start date.

e) Identify each of the proposed transporters and recyclers that the stewardship

organization will contract with to transport and process program mattresses.

In an appendix, please include the business’ name, physical address, contact

name, email address and phone number.

Section 4(1)(e)(A) of the Act requires that the Plan include “[i]dentification of the

proposed transporters and recyclers that the stewardship organization will

contract with to transport and process program mattresses and the recycling

methods that the recyclers will use.”

Given that MRC has not yet entered into contracts with these transporters or

recyclers, it would be premature for MRC to require now that they obtain any

required licenses or meet other requirements to transport or recycle program

mattresses in accordance with relevant laws and regulations at some point in the

future. Nevertheless, MRC’s request for proposals, to which each of these

businesses responded to with interest in participating in the Program, clearly

notified each business that MRC would contractually require compliance with

such licensing, environmentally sound management and other requirements.

Once DEQ approves this Plan, MRC will seek to formally contract with these

businesses and to formalize these requirements in the contract at that time.

TABLE 1. Proposed Transporters

Company Address

Contact

Name

Phone Email

Ally Global

Logistics

DBA The AGL

Group

317 Libbey Industrial

Pkwy.,

Ste B-200

Weymouth, MA 02189

Jessica

Allen

(781) 544-3970

jallen@allygloballogistics.com

Ron Lawrence

And Son

Transport, Inc.

532 Beard Ave.

Modesto, CA 95354

Kelly

Snyder

(209) 321-4122

kelly@ronlawrenceandson.com

Ryder

Transportation

Solutions

11690 NW 105th St.

Miami FL 33178-1103

Derek

Peterson

(305) 633-7497

Derek_w_peterson@ryder.com

Titan Concepts

International LLC

DBA TCI Global

Logistics

710 S 67th Ave.

Phoenix, AZ 85043

Dave

Mosely

(773) 218-6852

MoseleyD@TCILogistics.com

Total Quality

Logistics, LLC

4289 Ivy Pointe Blvd.

Cincinnati, OH 45245

Aaron

Nodal

(912) 441-8265

[email protected]om

TABLE 2. Proposed Recyclers

Company Address

Contact

Name

Phone E-mail

Environmentally

Conscious

Recycling

12409 NE San Rafael

Portland OR 97230

Vince

Gilbert

(503) 253-0867

Vince@ecrrecycling.com

Klamath Works,

Inc.

2350 Maywood Dr.

Klamath Falls, OR

97603

Joy

McInnis

(541) 887-8495

joy@klamathworks.com

St. Vincent de

Paul Society of

Lane County, Inc.

135 N Cleveland St.

Eugene, OR 97402

Bethany

Cartledge

(541) 687-5820

bethany.cartledge@svdp.us

f) Describe how the stewardship organization will provide for the environmentally

sound management of program mattresses, regardless of the producer, with no

charge at the point of collection of discarded mattresses.

MRC will provide for the environmentally sound management of program mattresses (see

Part 4(b), above) at no charge to the consumer at the point of collection, regardless of

which company manufactured that unit (provided, however, that MRC may permit a

person that provides a “premium service" to charge for that service) as described below.

MRC contracts with third parties and will expressly require that they use environmentally

sound management practices as defined in Section 2(4) of the Act to collect, transport and

recycle discarded units. They will be contractually obligated to comply with all federal, state

and local laws and regulations that apply to their businesses and operations. These laws

will include air and water pollution laws, other environmental laws, workplace health and

safety requirements, fair labor standards rules and other laws and regulations that can

affect the work and natural environment.

The services to be provided by the entities with which MRC will contract will divert

thousands of discarded units from Oregon’s solid waste system and landfills annually,

which will generate significant environmental benefits, prolong the life of existing landfills

and reduce the cost, fuel and other resources that the state’s solid waste system and

landfills must expend to handle discarded mattresses. The recyclers will generate recycled

steel, foam, fiber, fabric, wood and other mattress materials that can be reused or

manufactured into new products. The environmental costs of manufacturing equivalent

materials from virgin sources that the recycled materials will displace will be avoided, once

again generating significant net environmental benefits.

As the Program is implemented, MRC will work closely with its collection and recycling

network to make the process more environmentally and financially efficient and cost-

effective, with our overarching goals being to continually improve the Program’s

operations, conserve resources and increase the net environmental benefits that the

Program provides. For example, MRC will continually seek to reduce the per unit cost to

transport units from collection sites to the recyclers. These cost savings will come primarily

from developing routes, loading/off-loading practices and equipment that will reduce the

amount of fuel required to transport each unit (which in turn will generate environmental

benefits in the form of reduced greenhouse gas generation).

The collection network will consist of a variety of drop-off locations (solid waste facilities,

mattress reuse and renovators, recycling centers, retailers, etc.) and collection events for

underserved or rural communities that MRC will provide at no charge to the Oregon

consumer. MRC will also provide transportation and recycling services for large volume

generators of discarded mattresses, referred to as bulk pickup service (such as hotels,

healthcare facilities, universities, military facilities and retailers), again at no charge to the

participant. MRC will also accept at no charge units collected by entities that provide

premium mattress collection services (like curbside bulky item collection or small

commercial haulers). Curbside collection haulers may generate enough mattresses to

have an MRC trailer in their yard. Small commercial haulers may be able to deliver direct

to a collection site or a mattress recycler.

MRC will contract with mattress recyclers that can establish that they have the ability to

use environmentally sound management practices to provide the required mattress

recycling services, and that will agree to comply with recordkeeping requirements,

documenting the final disposition of discarded mattresses, contractual performance

metrics and relevant federal, state and local legal requirements including the Act. To

identify recyclers that can meet these criteria, MRC issued a request for proposals (RFP)

to recyclers interested in processing discarded mattresses under the Program. Potential

recyclers’ responses included the processing fee that they propose to charge MRC to

recycle units and other important aspects of the recycling contract.

In the RFP, MRC also requests that each respondent list all downstream purchasers to

which the respondent intends to sell used mattress materials obtained from the recycling

process. This information is useful in confirming that the materials removed from

mattresses are recycled when possible, as opposed to being landfilled or incinerated.

MRC evaluates all proposals based on a combination of factors, including price,

experience, geographic location and completeness of RFP response.

The recyclers with which MRC will contract will be required by contract to comply with

Recycling Standards (see Appendix C). For these reasons, MRC and its contracted

service providers will use environmentally sound management practices at every step in

the mattress collection, transport and recycling process. To address noncompliance with

the contract or Recycling Standards, each of MRC’s contracts with recyclers will contain

a contract compliance/dispute resolution process, as well as contract termination

criteria. The goals of these provisions are to encourage regular and positive

communications between the contracting parties regarding the fulfillment of their legal

obligations, to identify instances when contract compliance problems arise and to

gradually escalate the discussions until the problems can be remedied in a constructive

manner that avoids rupturing the contractual relationship and resulting in termination.

Compliance with the Recycling Standards will be one of the contractual obligations that

are subject to these provisions.

We anticipate that the vast majority, if not all, of the contractual compliance issues that

MRC and its recyclers will encounter under the Program can and will be resolved

through this process. In the event, however, that a material violation of the contract

cannot be cured and contract termination becomes necessary, MRC will notify DEQ of

that action, as part of its monthly reports to DEQ identifying which recyclers are

participating in the Program.

g) Describe how the stewardship organization will prioritize renovation, reuse or

recycling over disposal in providing for the environmentally sound

management and final disposition of program mattresses under the mattress

stewardship program.

MRC will use environmentally sound management practices to divert discarded

mattresses from the solid waste stream and disposal through landfills and other means.

MRC’s primary focus will be on dismantling discarded mattresses and making the

recycled materials available to use in making new products. The recyclers with which

MRC will contract will be required by contract to achieve a recycling rate, thereby

disincentivizing disposal. Whole mattresses and mattress materials sent for reuse,

renovation or recycling all contribute to and are factored into the recycling rate. The

recycling rate is calculated using data reported by mattress recyclers. It is determined

by dividing the weight of whole mattresses and materials that are renovated, reused and

recycled by the weight of whole mattresses and materials recycled, renovated, reused

and disposed. Some recyclers separate and supply cleaner uncontaminated used

mattresses or their component materials to reuse organizations, used mattress sellers,

and renovators of used mattresses. MRC will provide recyclers with a list of renovators

in Oregon that comply with applicable federal and state laws governing the sale of used

and renovated mattresses.

Based on the experience of other mattress recycling programs, most mattresses can be

dismantled and the materials recycled. Nevertheless, in some cases, a mattress is so

soiled with bodily fluids, contaminated with putrescible solid waste (for example, from

exposure to residential food waste during trash collection), infested with bedbugs or

mold, or becomes so mangled (from being loaded into a trash compactor truck), wet or

frozen (from being exposed to weather) that attempting to dismantle such a unit may

expose a recycler’s workforce to unacceptable health and safety risks or make the unit

unrecyclable from an environmental or financial perspective. In order to minimize the

number of units that cannot be recycled for these reasons, MRC provides collection

sites with resources to implement best practices that will reduce the number of units that

are ruined because of mishandling or other causes. These will include the Collection

Site Requirements and video tutorials on acceptable and unacceptable mattresses,

effective site operations, collection site signage, safe mattress loading and stacking and

bedbug identification and training. MRC will also provide information to collection sites,

transporters and recyclers that will help them protect their workforce from these health

and safety risks.

In addition to recycling and diverting discarded mattresses from waste disposal, the

reuse prong of Oregon’s waste management hierarchy includes mattresses handed

down to friends or family, mattresses donated to charitable organizations, sold in used

furniture stores and mattress renovation. As a result, reuse organizations, used

mattress sellers and renovators of used mattresses who comply with relevant federal

and state laws may also participate in the Program as collection sites. MRC is (and will

continue) to communicate with renovators and reuse organizations in Oregon regarding

the Program and how they can participate in an environmentally sound manner. As a

participating collection site, these entities may receive units that they may cull for reuse,

resale, or renovation and may recycle remaining unwanted units through the Program,

whether they function as a collection site or not. At present, MRC is only aware of two

active renovators in Oregon.

See Part 4(f) for additional information about the collection network, including

renovation, reuse and recycling.

h) Describe the recycling methods that the recyclers will use for the processing of

mattresses.

After discarded mattresses arrive at a recycling facility, the recycler will unload the

container and (at its discretion) may landfill units heavily contaminated with bedbugs,

mold or putrescible solid waste, or that are otherwise in nonrecyclable condition. This

may be necessary to minimize facility contamination and worker exposure to health and

safety risks. Alternatively, units that are deemed suitable for reuse or resale may be

separated at this time. Recyclers will report to MRC the number and weight of

mattresses and weight of mattress materials directed to reuse, renovation, and landfill

as a result of this triage process. MRC will report this data in the annual report as

required in section 9(2) of the Act.

The recycler will then dismantle the non-contaminated mattresses that are not reused or

resold. The outer ticking layer is removed first so that each internal component material

layer (typically foam, fiber and steel springs) can then be separated. The dismantling

process varies from one recycler to the next, but most use a combination of manual and

mechanical processes. Each recyclable material type (e.g., steel, foam, fiber, etc.) is

separated and sometimes compressed into bales for shipment to buyers.

Part 5 – Collection

The Mattress Stewardship Act requires a stewardship organization to operate at least one collection

sites in every county with a population of 10,000 or more, plus an additional 25 sites to be

distributed throughout the state to extend convenient service to all persons in the state. A

stewardship organization must establish and maintain collection sites at permitted solid waste

facilities or other suitable site for the collection of discarded mattresses, such as organizations that

recycle or renovate mattresses, reuse stores or locations on tribal land. In counties that have a

population of less than 10,000 people and that do not have a permanent collection site, at least one

collection event per year must be held in that county.

It is preferred that a stewardship organization use Portland State University population data when

planning for the convenience standard. https://www.pdx.edu/population-research/population-

estimate-reports

a) In an appendix, list all proposed collection sites and events, including

location name, physical address, a contact name and phone number.

MRC consulted with Portland State University (PSU) data when developing the

convenience standard. Of Oregon’s 36 counties, PSU’s Certified Population

Estimates identify 29 with a population of 10,000 or more and seven with a

population of less than 10,000.

See Appendix D for a list of the facilities that responded favorably to MRC’s

survey or subsequent outreach in serving as a permanent collection site, as

further described in subsection (c) below. MRC has not yet entered into contracts

with any collection sites, pending DEQ’s approval of this Plan. Once approved,

MRC will accelerate our contract review process. See the Implementation

Timeline for when we expect these arrangements will begin to be formalized.

Once DEQ approves the Plan, MRC will provide DEQ monthly updates that will

reflect finalized collection site contracts and which collection sites can be

operational both in time for Program launch and afterwards.

b) If proposing alternative methods to providing convenient service, describe

and provide any geographic information systems analysis or additional

information sufficient to support how the alternative methods will result in

providing service to residents throughout this state at an equivalent level of

convenient service compared with the number of collection sites and events

required under the Act.

A stewardship organization could measure effectiveness of the alternative

methods compared to collection by a collection site or event on an annual

basis, with a commitment to increasing the level of alternative methods or

awareness of the alternative methods if data does not suggest the alternative

methods are providing an equivalent level of convenient service.

Examples of additional information as mentioned above could include:

i) Concurrence by local governments with the proposed alternative

method in the areas where residents are underserved by collection

sites or events.

ii) The determination of any enhanced services needed, to improve

equitable access, including historically underserved populations.

Although MRC will streamline the contracting process as much as possible and will

promptly respond to all potential collection sites, the amount of time that a municipal

collection site will need to fully execute a collection contract is out of MRC’s control.

For this reason, it is unlikely that MRC can fully meet the convenience service metrics

prescribed in Section 5(1)(a) within seven months of plan approval

Several sections of the law contemplate that MRC will require time to fully develop a

collection network that provides convenient service. For example, the legislature

recognized that MRC will need time to identify operational challenges, explore

solutions and test the Program’s potential during the Program implementation process

to understand which performance metrics are appropriate and practical. For this

reason, Section 4(1)(f) of the law specifically allows MRC up to two years following

Program launch to propose Program performance goals to DEQ. Likewise, the

legislature understood that MRC would need a reasonable amount of time before it

should be graded as meeting the statutory Program requirements. Section 9(5)(B)

authorizes DEQ to conduct periodic performance audits of the Program, but

specifically provides that DEQ may not request the first such audit “until the third year

that a stewardship organization has implemented a mattress stewardship program.”

Consistent with both of these provisions, allowing MRC two years to negotiate needed

relationships and formal contracts, to confirm what works and what does not and to

take action needed to adjust to new information and conditions is fully within the

legislature’s intent in enacting these provisions.

For these reasons, MRC is therefore proposing alternative methods.

Permanent Collection Sites:

Beginning in May 2023, MRC surveyed and contacted all known Oregon SWFs and

other potential collection sites to assess their interest in becoming a public collection

site for the Program. To date, we have interest from at least one permanent site in 28

of the 29 Oregon counties with populations over 10,000 people. In addition, another 37

locations around the state have expressed interest in becoming MRC collection sites,

for a total of 65 interested sites, exceeding the 54-site minimum required by statute.

Upon Plan approval, MRC will notify the interested SWFs, determine whether they

remain interested in becoming MRC collection sites and initiate the contracting

process. Before and following Program launch, MRC will share resources and conduct

virtual and in person visits to recruit additional permanent collection sites.

Although many factors beyond MRC’s control influence how and when entities will sign

contracts, we estimate that within 12 months of Program implementation that 24 of 29

counties with over 10,000 people will have at least one permanent collection site

participating in the Program. Within 24 months of Program launch, MRC anticipates

that all 29 counties with over 10,000 people will have a permanent collection site.

If MRC is unable to site a permanent location in a county with over 10,000 people,

MRC’s alternative convenience method will be to host a collection event within 12

months of Program implementation. MRC will work in good faith with local SWFs and

solid waste officials to coordinate these events.

Once a permanent collection site contract has been finalized, MRC will offer to assist

the site with outreach to publicize the site to residents of the intended service area.

Within five days of MRC receiving a completed site contract, MRC will provide the site

a publicity toolkit (described in Part 11) and conduct outreach in coordination with the

site. If the site is nonresponsive to MRC’s offer, MRC will conduct outreach after a

container has been delivered to the site. At minimum MRC will send site details to

local officials to share with constituents, publish the details of the no-cost collection

site in its locator listings, and announce the site on the Oregon page of

ByeByeMattress.com and ByeByeMattress social media. MRC will provide DEQ with

site details as part of its monthly report to DEQ.

25 Additional Collection Sites:

Although many factors beyond MRC’s control influence how and when entities will sign

contracts, we estimate that within 12 months of Program implementation, MRC will

have executed collection contracts with 21 of the additional 25 collection sites

distributed throughout the state in a manner to extend convenient service to residents.

Within 24 months of Program launch, MRC anticipates that all 25 additional sites will

be under contract.

If MRC is unable to contract with all 25 additional locations within 12 months of the

Program launch, MRC’s alternative convenience approach will be to add collection

events within the first 18 months of the Program so that the total of permanent

additional sites plus events equals 25.

Collection Events:

In counties with fewer than 10,000 people that lack a permanent collection site, MRC

will demonstrate a good faith effort to coordinate with the appropriate local

government, collection service franchise holder or person who provides collection

services. We estimate that within 12 months of Program implementation that all

counties with under 10,000 people will have had at least one collection event or have

a contracted permanent collection site.

If MRC is unable to host a collection event with the appropriate local government,

collection service franchise holder or person who provides collection services, MRC

will seek alternate community organizations and entities with whom it may

coordinate, host and promote a collection event. If MRC determines that holding a

collection event in a given geographic area will not be practicable or effective, that

will be noted in MRC’s monthly collection network update to DEQ.

Once collection event details have been finalized (date, time and location confirmed

with service providers and the host has signed the necessary contract or event

registration), MRC will post the event on the ByeByeMattress.com recycling locator

(not sooner than 30 days before and not less than 1 day before the event), announce

the event on social media (not sooner than 30 days before and not less than 1 day

before the event). Within five days of an event’s details becoming finalized, MRC will

provide the event host and local officials with a publicity toolkit (described in Part 11)

and offer to assist with outreach to publicize the event to residents of the intended

service area. MRC will conduct outreach in coordination with the host. If the host is

nonresponsive and at least one week remains prior to the event, MRC at minimum

will send event details to local officials to share with constituents, announce the

details of the no-cost event in its locator listings, Oregon page of

ByeByeMattress.com and Bye Bye Mattress social media.

Convenience Network Gaps:

MRC may be unable to contract with some permanent locations or host collection

events during the first two years of the Program. Those challenges and MRC’s

approach to provide access to those communities through events or other means will

be noted in MRC’s monthly collection network updates to DEQ as required by

Section 7(3)(a).

MRC will include a statewide GIS analysis of the permanent collection site and

collection event network in the third year of the Program to determine if any service

gaps exist in this alternative convenience approach. That analysis will determine the

percentage of the population within 15 miles of MRC’s collection network after two

years of operations. The study will be included in the Program’s annual report.

c) Describe how the stewardship organization will establish and maintain

collection sites at permitted solid waste facilities and other suitable sites for the

collection of discarded mattresses, provided that the stewardship organization

ensures the sites do not impose a fee for making space available for storage

containers.

As stated in the Implementation Timeline, establishing the collection network is a

multiyear process. In an effort to implement the Program promptly and efficiently, MRC

in May 2023 preliminarily contacted 130 Oregon solid waste facilities in both urban and

rural areas included on DEQ’s online “Active Permitted Facilities” list that were likely to

accept discarded mattresses to gauge their potential interest in collecting discarded

mattresses for recycling through the Program. To extend convenient service to

residents, MRC additionally identified and surveyed 95 other suitable sites, including

existing mattress recycling and renovation organizations, solid waste service providers,

reuse organizations and other alternative drop-off options in both urban and rural areas.

These additional locations increased the survey pool to 225 locations in all 36 Oregon

counties.

See Appendix D for a list of the 62 facilities that responded positively to MRC’s survey

or otherwise indicated interest to serve as a collection site. The facilities that responded

favorably to MRC’s contacts are located in 29 of Oregon’s 36 counties, including 28 of

the 29 counties where a permanent collection site is required.

Once DEQ approves the Plan, MRC will seek to quickly formalize collection site

contracts with these entities in an effort to have them operational as collection sites

once the Program launches. MRC’s revised budget reflects an accelerated timeframe

for contracting and providing recycling service to these entities. Realistically, some of

these entities may decline to contract with MRC despite indicating previously an interest

to serve as a collection site.

As part of maintaining and retaining collection sites, MRC will visit established collection

sites biennially. During site visits, MRC will answer questions, provide supplemental

training and resources and confirm whether the site is following environmentally sound

management practices and collection site requirements that MRC will require each

participating site to comply with. See Appendix B for examples of collection site

resources. MRC will provide information about best practices for improving operational

efficiency and stacking and loading units efficiently and safely, as well as offer

suggestions to improve the quality and condition of collected mattresses. Based on

MRC’s assessment of individual collection site improvement needs, MRC may consider

offering limited site improvement funding on a case-by-case basis. MRC also provides

signage that identifies the mattress collection area and specifies what can and cannot

be collected. MRC will also provide information and support to assist collection locations

with invoicing and generating public awareness of their participation.

d) Describe the process for identifying and engaging with permanent collection

sites and event sites, including organizations that recycle, reuse or renovate

discarded mattresses.

i) Include contacts made and information provided to prospective sites.

As described in the Part 4(g) and subsections of Part 5 above, MRC will make a

good faith effort to identify an appropriate local government, collection service

franchise holder, person who provides collection service, reuse organization,

used mattress seller, and renovators of used mattresses, in the geographic area

to coordinate with to establish a permanent collection site. Appendix E contains

examples of information MRC will provide prospective and active collection sites.

ii) Describe the process for engagement with tribal governments.

Mattress recycling programs in other states have worked with tribal governments

and solid waste facilities operated on tribal lands. MRC will invite such facilities in

Oregon to participate in the Program as part of our ongoing efforts to develop and

expand the collection network. In cases where establishing a permanent collection

location on tribal lands is not feasible or practical, MRC may organize collection

events in these areas to extend service to their residents.

e) Describe how collection sites will collect, separate, manage and get rid of

program and non- program mattresses.

MRC’s Collection Site Requirements, included in all collection site and event contracts,

define which program mattresses are eligible for recycling and explain how they can

efficiently collect, separate and load mattresses into trailers. The contracts and

requirements also require collection sites to provide for the environmentally sound

management of mattresses as defined in the Act and to comply with all applicable

federal, state and local laws and regulations. MRC will supplement the requirements

with a video series (available on MRC’s Resources Library in Spanish and English) that

addresses efficient mattress stacking and loading, effective collection site operations,

Program and non-program product identification and collection event promotion.

The requirements also describe non-recyclable mattresses (e.g., those that are mixed

with putrescible solid waste, or excessively soiled, etc.). To further assist collection sites

in identifying and managing instances of excessive bedbug contamination, MRC offers

an informational brochure, identification poster and online training video about bedbugs

that collection site staff can access on demand in MRC’s Resources Library.

MRC will inform collection sites that they will not be compensated for collecting or

handling non-program mattresses and that those units are not eligible for no-cost

recycling through the Program. Collectors will be responsible for the cost of recycling or

disposing of such non-program mattresses.

Collection sites will be responsible for disposing of non-recyclable program mattresses

and will be compensated as part of the per-unit handling rate as described in Part 5(g).

f) Describe how the stewardship organization will provide for storage containers

at no charge at, and transportation and recycling of program mattresses from,

collection sites. Describe how the stewardship organization will determine

storage container options based on the size of site, volumes collected and

different weather considerations throughout the state.

The Program will provide at its cost storage containers that are appropriate for the size

and location of each facility. These include 53-, 48- and 28-foot trailers, as well as sea

containers and roll-off bins for sites with limited space or other logistical constraints. The

53-foot trailer is preferred because it can hold the most mattress units, resulting in a

lower per unit transport cost (and fuel consumption). Roll-off containers, which are the

smallest storage option, are the least efficient alternative, but may be the only option for

collection sites with small or restricted loading areas. All such containers are covered to

reduce contamination of the mattresses and eliminate damage from weather.

To provide mattress transportation in Oregon, MRC will contract with third-party logistics

companies, transportation companies and solid waste facilities to pick up and transport

units from collection sites that have properly source separated program mattresses at

one time for recycling under the Program.

If packed efficiently, approximately 120-150 units can be loaded into a 53-foot trailer.

MRC instructs sites to make a request that a transporter provided by MRC pick up the

trailer on site and swap it for an empty one in advance of the on-site trailer reaching

capacity. For sites located in urban areas (where discarded units generally are collected

more quickly), MRC transporters will have 48 hours to swap a trailer after receiving a

request, and up to five days to do so for sites in rural areas (where units are generally

collected more slowly). The collection sites’ advance notice paired with the required

response time for transporters safeguards against the collection site exceeding the

capacity of the trailer while waiting for the pickup/swap process to occur.

MRC may assign high-volume locations a regular pickup schedule so that transporters

can keep up with the volume. MRC will seek to resolve scheduling and other issues that

may arise regarding transportation. Mattresses are bulky and light cargo, and as a

result, efficient transportation helps control both financial and environmental costs.

MRC will assign mattress loads to individual recyclers to achieve efficiency throughout

the collection network.

g) Describe how the stewardship organization will calculate and provide

financial compensation to collection sites for their reasonable actual costs to

collect and manage mattresses.

MRC will negotiate an agreement to pay reasonable compensation with each

collection site that agrees to accept discarded mattresses dropped off free of

charge. Compensation will be based on the site’s actual costs to collect and

manage units. The amount of the compensation varies from site to site since it is

based on a number of factors, including the hourly wage rates for general mattress

handling labor, forklift operators, as well as the forklift type. It generally takes about

three minutes per unit to load a unit on a trailer. The compensation MRC pays also

includes the costs a collection site will incur to dispose of non-recyclable units that

it receives. Based on the experience of other state mattress recycling programs,

such units typically account for 10% or less of the total units received. If a collection

site requests separate compensation for the reasonable, actual cost to manage

non-recyclable units received from consumers, MRC will negotiate compensation

provided the collection site provides photographic evidence to verify the disposal of

non-recyclable units and the reason they are not recyclable.

MRC will compensate collection sites for all program mattresses dropped off by all

persons as defined in the Act, including individuals, businesses (including mattress

retailers) or other entities for which the collection site has not collected a fee and that

the collection site loads in a collection container. A collection site’s monthly invoices to

MRC will quantify the number of units handled and be accompanied by either a bill of

lading or report from MRC’s designated electronic reporting system. As a check on this

information, the recycler that receives a load from a collection site will count the number

of units received during the off-loading process. The recycler’s count determines the

number of units for which MRC will compensate the collection site. MRC will pay

properly documented and reconciled invoices within thirty (30) days of receipt by

electronic funds transfer or check. MRC staff will verify that the unit counts on each

collection site invoice matches the invoice’s supporting documentation during the

invoice review and approval process.

h) Describe how the stewardship organization will provide for bulk pickup

service at no cost to collect a minimum of 100 properly source separated

program mattresses at one time.

MRC will provide bulk pickup service at no cost to collect a minimum of 100

properly source separated program mattresses at one time from persons including,

but not limited to:

(A) Public bodies as defined in ORS 174.109

(B) Retailers

facilities

(D) Health care, educational or military facilities

(E) Hotels, motels, inns and other establishments that provide transient lodging

For the eligible entities with at least 100 discarded units, MRC will provide pick up,

transport and recycling at no cost to the participating entity. For bulk pickup entities

located in urban areas, MRC transporters will have 48 hours to swap a trailer after

receiving a request, and up to five days for sites in rural areas. Bulk pickup service is an

important component of the Program and is promoted using direct marketing tactics,

advertising, industry events and conferences, media coverage and social media.

Transportation service will be provided by proposed third-party transportation

companies listed in Part 4(e) of this Plan. Our other state programs coordinate the

logistics and hauling of over 12,000 loads of discarded mattress annually and we will

bring this expertise to Oregon.

i) Describe how the public will access available collection opportunities as

part of the mattress program, including how the stewardship organization’s

website will meet the requirements of Section 3(4) of the Mattress

Stewardship Act and OAR 340-098-0480.

MRC created ByeByeMattress.com to communicate where consumers

(households) and commercial sources (businesses) can drop off discarded

mattresses. The website also includes a directory of cities that provide at least

one free bulky item collection opportunity each year and those that participate in

the Program are noted. Commercial sources can also learn how to work with

MRC to have their large volumes of mattresses picked up and transported for

recycling.

Per Section 3(4) of the Act, the Oregon collection site and event listings will

provide the physical address, phone number, hours of operation and any physical

or language accessibility considerations. MRC will use an already established

process to implement changes to this information within three business days.

Consumers will learn ByeByeMattress.com exists through a multichannel,

multilingual outreach campaign that includes retailers distributing point-of-sale

materials, local media airing public service announcements and including

information about the Program in their news coverage and local leaders and

community influencers sharing collection opportunity information with residents.

Commercial sources will learn that ByeByeMattress.com exists through

advertisements and media coverage in industry news sources. MRC also

maintains a consumer and industry hotline and mailbox to provide assistance to

residents seeking information. See Part 11 of this Plan for outreach and

education strategy details.

Part 6 – Performance Goals

Following the schedule described in statute, explain when the stewardship organization will submit

proposed performance goals to DEQ for approval, as part of the initial program plan.

Section 8(2) of the Act requires that MRC submit proposed performance goals to DEQ no

later than two years after the Program implementation date. The date on which the Program

actually launches will depend in part on when DEQ approves this Plan. MRC will comply with

this statutory requirement as well as Oregon Administrative Rules promulgated pursuant to

that statutory authority to implement the Act, and will use data collected in the Program’s initial

years to determine baselines that will inform our proposed performance goals.

Part 7 – Program Administration

Describe how the program’s overall daily management will be handled through management of

contracts, record keeping, reporting, and compliance oversight of service providers.

a) Identify and provide the contact information for key personnel responsible

for running various aspects of the program, including the authorized

representative.

MRC will provide the requested contact information for key Program personnel to

DEQ separately from the Plan submission.

b) Provide a statement that the stewardship organization retains legal

responsibility for all plan commitments and any violations of the Mattress

Stewardship Act, as well as all federal and state laws applicable to the

operation of the mattress stewardship program.

As the stewardship organization, MRC’s legal responsibilities are set forth in the

Act, federal statutes and other state statutes. MRC will comply with and fulfill these

statutory responsibilities.

c) State that all obligations of vendors, collection sites, and other participating

entities described in the plan, unless noted specifically, are set forth in

contracts enforceable by the stewardship organization.

Following approval of the Plan, MRC will enter into contracts with collection sites,

transporters and recyclers that will set forth their obligations. The obligations of each

vendor will vary, depending on the services they provide to the Program. Each

contract will contain a breach clause, including both an escalation and cure process,

as well as a termination clause, in the unlikely event that a vendor does not comply

with its contractual obligations.

d) Describe how the program will be consistent with the policies for materials

management set forth in ORS 459.015(2) including responding within three

business days to requests by DEQ, unless the timeline specifies otherwise in

the Act.

To clarify, neither ORS 459.015 nor the Act contains a requirement that a party must

respond to DEQ requests within three business days. Nevertheless, to the extent that

MRC has access to relevant information and has the requisite legal authority to

respond, MRC intends to be responsive to DEQ requests regarding its obligations

under the Act.

Regarding ORS 459.015(2), that provision contains broad general statements to

guide Oregon’s recycling policy. For example, subparagraph ORS 459.015(2)(a)

provides that Oregon’s materials management policy should:

Minimize the net negative impacts of materials, across their life cycle, on human

well-being and environmental health, including the quality of land, air, water and

ecosystems, with consideration of technical and economic feasibility.

Consistent with this policy goal, MRC will prepare “a life cycle assessment report of

mattresses sold in this state” in Year 3 of the Program, pursuant to Section 9(4)(b)(B)

of the Act.

Pending completion of that report, subparagraph ORS 459.015(2)(c) provides that

Oregon’s policy is to manage materials with priority given to waste reduction, reuse,

recycling, composting, energy recovery and proper disposal. Once again, MRC will

implement the Act consistent with this policy goal. Specifically, MRC will focus on

reducing waste by recycling discarded mattresses and offering organizations that

recycle, reuse or renovate discarded mattresses the opportunity to participate as

collection sites in the Program. MRC will also work with mattress manufacturers and

component suppliers to identify materials, product designs and manufacturing

methods that can mitigate current challenges to the reuse and recycling of

mattresses discarded today.

MRC will work with its collection sites, transporters and recyclers to improve the

efficiency of their operations, reduce their environmental footprint and reduce the

amount of waste generated by the dismantling process. As part of this effort, MRC

will regularly analyze which materials cannot be recycled and why, and how to

address those challenges, either through market development research, changes in

mattress materials, designs or manufacturing methods, better disassembly methods

or other tactics.

Likewise, the Act and MRC’s intended implementation of those requirements is

consistent with other policies set forth in ORS 459.015(2). For example:

• Subparagraph (f) states that Oregon policy should:

Promote, encourage and develop markets first for reusable material and

then for recyclable material.

• Similarly, subparagraph (g) provides that Oregon policy should:

Promote research, surveys and demonstration projects to encourage

material or energy recovery.

• Subparagraph (h) provides that Oregon policy should:

Promote research, surveys and demonstration projects to aid in developing

more sanitary, efficient and economical methods of solid waste

management.

MRC will work with solid waste facilities and other collection sites to minimize

the improper handling of discarded mattresses (crushing in compactor trucks),

contamination (exposure to food and similar wastes) and storage (exposure to

weather) prior to recycling. In doing so, MRC can increase the amount of

recycling (and reduce the amount of waste) possible from mattress recycling.

• Subparagraph (k) provides that Oregon policy should:

Provide for the adoption and enforcement of recycling rates and standards

as well as performance standards necessary for safe, economic and proper

solid waste management.

Consistent with this policy, Section 8(2) of the Act provides that MRC will

propose recycling goals no later than two years after the Program’s launch,

and MRC will contractually require its recyclers to follow practices that comply

with state and federal environmental requirements and reduce the

environmental impact of each recycler’s facility.

• Subparagraph (p) provides that Oregon policy should:

Provide for recycling collection and recycling processing systems that have

adequate capacity and are operated for the purpose of achieving the policy

set forth in this section and providing clean, usable materials to industry.

MRC’s goal in establishing a used mattress collection and recycling network

will be to further this policy. MRC will seek to help its contracted recyclers to

be more financially and environmentally sustainable and to develop adequate

capacity to efficiently handle the needs of Oregon residents.

• Subsection (q) encourages Oregon to:

Ensure that all materials collected for waste disposal or recovery shall be

managed responsibly through to their final disposition, minimizing impacts

that create pollution or harm the quality of air, land, water and ecosystems,

or harm human health and welfare.

As the mattress stewardship organization, MRC will implement these policies. For

each of these reasons, MRC will administer the Program consistent with Oregon’s

material management policies.

e) Describe the auditing, inspection and other procedures that will be used by

the stewardship organization and the frequency at which the procedures will

be implemented to ensure that all entities the stewardship organization

contracts with to implement the mattress stewardship program engage in

environmentally sound management practices.

MRC will follow the process outlined below in Part 7(f).

f) Describe the stewardship organization’s processes for ensuring that the

recyclers contracted with by the stewardship organization to process

program mattresses and entities handling discarded mattresses through their

final disposition will comply with environmentally sound management

practices.

See Part 4(f) for a general explanation of how the stewardship organization will provide

for the environmentally sound management of program mattresses.

In MRC’s recycling contracts, recyclers will be required to achieve minimum recycling

targets of at least 70%, provided that there is sufficient market demand for recycled

mattress materials and that extenuating circumstances (such as floods, fires or other

unforeseen events) do not prevent a recycler from achieving this performance metric. In

addition, MRC will employ a variety of inspection and accounting procedures to confirm

that collection sites, transporters and recyclers are complying with their contractual

obligations, including environmentally sound management practices defined in the Act.

The obligations of each vendor will vary depending on the services they provide to

the Program. Each contract will contain dispute resolution and termination clauses in

the event that a vendor does not comply with its contractual obligations.

This begins with transporters documenting mattress deliveries to recyclers with bills of

lading (electronic or paper) that identify the source, quantity and destination of the units.

These bills of lading are then used to validate monthly transportation invoices. The

number of units recorded on the bill of lading is also important for validating the number

of units received from collection sites that invoice MRC for their actual costs to collect

and manage those units.

Upon receipt at a recycling facility, recyclers enter data from each bill of lading into an

electronic data reporting platform. This database is used for a variety of reporting

functions including calculating the number of units received by the Program, the source

of those units and the number of pounds of each commodity type recycled by each

recycler. Furthermore, recyclers are also contractually bound to adhere to Recycling

Standards, which detail material receiving, processing, tracking and downstream due

diligence requirements for purchasers of mattress materials used for recycling or

renovation. These Standards are attached in Appendix C.

MRC will perform monthly desk audits to monitor the compliance of recyclers with data

tracking and reporting requirements, inventory verification, recycling rate (monitor

progress) and the final disposition of deconstructed mattress materials and disposal of

non-recyclable waste. Additionally, MRC will conduct quarterly site inspections of all

recyclers to verify compliance with environmentally sound management practices.

Annually, MRC contracts with third-parties to observe and document each recycler’s

compliance with environmental health and safety requirements, fire safety protocols,

recycling standards and contractual obligations. As required under Section 9(2)(m),

MRC’s annual report to DEQ will include a report on the outcome of these inspections in

summary form. MRC will provide specific reports, including their procedures and

findings, to DEQ upon request.

g) Describe the stewardship organization’s record keeping, and how such

record-keeping will be adequate to ensure environmentally sound

management of program mattresses, as required in Section 11 of the Act.

Section 11(2) of the Act provides:

A stewardship organization shall retain all records related to implementation of

a mattress stewardship program for not less than three years and make the

records available for inspection by the department upon request.

Pursuant to this requirement, MRC will retain documents related to implementation

of the Program as required by Section 11 of the Act, most if not all of which are

generated and/or maintained electronically. Upon request, copies of the relevant

records can be provided to DEQ for review in DEQ’s offices.

MRC’s enterprise customer relationship management (CRM) system aggregates

information from collectors, collection sites, transporters and recyclers to track and

monitor the performance of individual contractors and the Program as a whole.

Data and reports extracted from that system provides metrics relevant for annual

reporting and internal performance tracking, including units collected, tracking of

transportation requests, recyclers’ receipt of loads from collection sites, recycling

rates for each recycler, etc.

h) Describe how the stewardship organization will ensure that all required

program participants are participating, the actions that will be taken to bring

required participants into compliance and the process for referring non-

compliant entities to DEQ for potential enforcement actions.

MRC has compiled a database of potential retailers, producers and renovators from

various information sources, including ReferenceUSA, Dun & Bradstreet, industry

publication subscriber lists, industry event attendee lists, Yellow Pages, Chambers of

Commerce, the Better Business Bureau and online searches. MRC will continue to

monitor these sources for new entrants into the mattress segment, as well as identifying

non-compliant parties.

If MRC identifies a party that should register and participate in the Program, MRC will

notify the party via certified mail of its potential obligations and follow up with a phone

call or email. If the party does not respond within 30 days, MRC will mail a second

certified letter and give the party 30 more days to respond. If the party remains

unresponsive after 60 days, MRC’s monthly reports to DEQ will identify the party and

request that DEQ take action (if appropriate).

MRC will also monitor whether retailers and other mattress sellers are submitting

monthly reports and are remitting collected recycling charges on time. MRC will use the

following protocol to alert parties that have missed deadlines for reports and payments.

Those more than 90 days delinquent will be notified that they owe MRC late fees and

associated interest. MRC assesses late fees and interest to encourage prompt payment

from all obligated parties and help compensate MRC for administrative expenses

related to non-compliance. Each month, MRC will notify DEQ of all delinquent parties

whom MRC has notified that they owe late fees and interest (defined as a Level 7

Delinquency Stage in the chart below).

A registered party may deregister only if it informs MRC that it no longer sells

mattresses in Oregon or has registered with another organization that has a plan

approved by DEQ under Section 6 of the Act.

TABLE 3: Notification Protocol for Late Reporters and Charge Remitters

Delinquency

Stage

Late Reporter Late Remitter

Timeline (Days since

due date missed)

Level 1

Late notice email generated

by MRCreporting.org

Late notice email generated by

MRCreporting.org

Reporter – After 7 days

Remitter – After 10

days

Level 2

Phone call made to verify

continued Program

participation and provide a

verbal reporting reminder

Phone call made and late notice

issued regarding outstanding

payment and warning of potential

interest charges

Reporter – After 15

days

Remitter – After 20

days

Level 3

Written notice mailed

Written notice mailed and interest

invoice issued

Reporter and Remitter

– After 30 days

Level 4

Second phone call made to

provide verbal warning of

potential penalties

Second written notice sent by

certified mail and interest invoice

issued

Reporter and Remitter-

After 60 days

Level 5

Written notice sent by

certified mail and late fee

invoice issued

Second phone call made warning

of accruing interest

Reporter and Remitter -

After 90 days

Level 6

Second written notice sent

by certified mail and late

fee invoice issued

Third call made warning of referral

to collections agency and interest

invoice issued

Reporter and Remitter -

After 120 days

Level 7

Late fee invoice issued;

DEQ notified of delinquent

account

Delinquent account sent to

collections agency and interest

invoice issued

Reporter and Remitter -

After 150 days

Level 8

Continued action begins

Interest invoice issued; DEQ

notified of delinquent account and

continued action begins

Reporter and Remitter

– After 180 days

Continued

action

Late fee invoices issued

monthly until account no

longer delinquent

Interest invoices issued monthly

until account is no longer

delinquent

Every 30 day reporting

period

i) Describe the stewardship organization’s methods for the following:

i) Management of discarded mattresses.

See Part 4(f) of the Plan for detail on discarded mattress management.

ii) Tracking and documenting the fate of discarded mattresses from

collection through final disposal within and outside the state.

See Part 7(f) for detail related to tracking and documentation.

iii) Conducting performance audits and inspections of recyclers,

haulers and other parties, including the frequency of such

performance audits and inspections.

See Part 7(f) for detail related to audits and inspections.

iv) Ensuring compliance with work health and safety requirements.

See Part 7(f) for recycler EHS compliance and schedule.

v) Describe how the stewardship organization will keep detailed

documentation for these methods.

As required by Section 11(2) of the Act, MRC will maintain records related to

implementation of the Program for not less than three years with some

documentation related to compliance efforts, licenses, contracts and other

relevant documents as required by law having longer retention periods. MRC’s

enterprise customer relationship management (CRM) system aggregates

information from collection sites, transporters, and recyclers to track and monitor

the performance of individual contractors and the Program as a whole. Data

related to management of discarded mattresses, material tracking, audits and

inspection, compliance with health and safety is kept in that CRM.

Part 8 – Budget

a) Describe the financial health of the stewardship organization.

The International Sleep Products Association, the trade association for the mattress

industry, formed the Mattress Recycling Council, Inc. (MRC Inc.) in 2013. MRC Inc. in

turn has formed individual limited liability companies (LLCs) as affiliates to serve as the

representative stewardship organization for mattress recycling in each state that has

enacted a mattress recycling law. MRC Inc. formed Mattress Recycling Council Oregon

LLC (MRC) in 2022. To fund MRC’s start-up costs prior to Program launch, MRC has

borrowed money pursuant to a loan from its parent, MRC Inc. MRC’s proposed budget

includes revenue from projected assessment collections, paying back the loan to MRC

Inc. and funding a financial reserve sufficient to operate the Program over a multiyear

period in a prudent and responsible manner. Additional detail is provided in MRC’s

budget in Appendix F.

b) Describe the stewardship organization’s process for establishing the proposed

operating budget and why the proposed operating budget will ensure an

effective mattress stewardship program that complies with the Act.

To develop the Oregon budget, MRC relied on the budgeting experience of mattress

stewardship programs in other states. Unit sales and revenue forecasts are based on

both industry-forecasted sales, as well as historical trends in other states with similar

programs. Estimates of units recycled are based on experience of other mattress

recycling programs.

TABLE 4: Forecasted Units Sold and Units Recycled

Calendar Year

Units Sold

Units Recycled

2025

410,012

164,097

2026

418,212

210,305

MRC evaluates actual expenses compared to budget monthly.

To control costs, MRC will periodically conduct an RFP process for several expense

areas, including its transportation and processing. Once finalized by management, the

budget is approved by MRC Inc.’s Board of Directors. Additional detail is provided in

MRC’s budget in Appendix F.

c) Include an anticipated annual operating budget for the mattress stewardship

program for two years of program operations, beginning with the year in which

the plan is submitted to the department. Line items should include but are not

limited to:

i) The collection, transportation and processing of program mattresses.

ii) The administrative costs of the mattress stewardship program to the

stewardship organization.

iii) The costs of compensating collection sites for their reasonable

actual costs to collect and manage discarded mattresses.

iv) The anticipated amount of moneys that the stewardship organization

will hold in unallocated reserve funds for the mattress stewardship

program.

v) The annual fee to be paid to the department pursuant to section 9(3) of the

2022 Act.

See Appendix F for the budget MRC has prepared that includes line items for expenses

noted in Part 8(c)(i – v) above.

Part 9 – Assessment Fee

a) Describe the methodology and data used to arrive at the proposed assessment

amount.

As noted in Part 8(b), MRC calculated an assessment fee based on anticipated annual

sales in Oregon, the Plan’s budgeted costs, and funding a reserve of no more than 75%

of annual expenses that would be sufficient to operate the Program over a multiyear

period in a prudent and responsible manner.

b) Describe a proposed method for collecting the mattress stewardship assessment

from retailers.

Part 9(c) of this Plan describes the proposed method and mechanism for collecting the

mattress stewardship assessment from retailers and an example of wording that retailers

should use to describe the assessment on the receipt provided to the customer. Parts

7(h) and 11(b) describe how MRC will inform retailers of their obligation to collect the

assessment from customers and remit that money to MRC. Completed and upcoming

activities to inform the industry of Oregon’s Program and the obligation to collect the

mattress stewardship assessment are included in the Implementation Timeline.

c) Describe the method for ensuring the assessment is remitted to the stewardship

organization.

The following responds to Part 9(b) – (c).

The Program is funded by a visible mattress stewardship assessment collected on all

mattresses sold for use in Oregon. MRC is proposing, subject to DEQ’s approval, an

assessment of $22.50 per unit, based on its anticipated administrative and operational

costs. Retailers and other parties selling mattresses will collect the assessment and

remit it directly to MRC, as required by the Act.

As required by Section 3(5) of the Act, the assessment must be stated as a separate

line item on the receipt for a mattress provided to a consumer at the point of sale. The

assessment may not be described on the receipt as an “Oregon recycling fee.” Retailers

employ a variety of transactional point-of-sale systems which may have limitations on

the number of characters that can be used to describe the assessment. MRC will

emphasize that the assessment may not be referred to as an “Oregon recycling fee”,

but retailers may use a combination of words and abbreviations such as “recycling fee”

to convey the purpose of the assessment. Other words that retailers may use include

mattress, recycling, stewardship, assessment, or fee and may abbreviate those words

as necessary to accommodate their point-of-sale system limitations.

The assessment is collected on the following types of sales:

• Brick-and-mortar retailers must collect the assessment on all sales of mattresses.

• Online retailers must collect the assessment on all mattresses sold for delivery in

Oregon, regardless of where the online retailer is located.

• Mattress manufacturers who sell to any consumer in Oregon must collect the

assessment on such sales and remit it to MRC.

Parties that collect the assessment must remit those amounts monthly and process their

remittances using MRC’s online remittance portal, MRCreporting.org. When making

their monthly remittances, parties must provide the following information: mattress units

sold and returned, foundation units sold and returned, renovated mattress units sold

and returned and renovated foundation units sold and returned. Records must be

maintained to provide verification of reporting data upon request.

In addition to facilitating remittances, the portal includes important information about

MRC, program definitions, FAQ’s, fee policy, examples of program and non-program

mattresses, participant agreements and registration instructions. MRC’s fee policy on

the portal also includes details about verifying remitted fees. All of this information is

publicly available and not behind a pay or subscription wall.

Part 10 – Illegal Dumping

Describe the mechanism to mitigate the costs associated with collection and management of

discarded mattresses that are illegally dumped and why the proposed mechanism will be effective.

The proposed mechanism must take into account the cost of one or more incentives to encourage

collectors to properly dispose of discarded mattresses and discourage illegal dumping, and may

include but need not be limited to proposals for funding of cleanup activities, for education and

outreach or for studies to evaluate the causes of illegal dumping. In describing the mechanism, the

plan may address efforts to ensure equitable outcomes such as:

• Understanding barriers

• Geographic differences in the state

• Different housing types

To mitigate the costs associated with illegally dumped mattresses found in any condition,

entities may discard these mattresses at no cost at collection events and collection sites

that participate in the Program. Additionally, MRC’s public outreach as described in Part 11

of this plan will reinforce that mattresses in any condition are eligible for drop-off at

collection events and collection sites. Based on the experience of other mattress recycling

programs, areas that lack proper mattress disposal alternatives tend to experience more

illegal dumping. Residents’ access to no-cost collection sites and events across the state

will provide such opportunities to address this problem. But MRC recognizes that each

state’s illegal dumping problem is different. For that reason, MRC’s first priority in Oregon

will be to understand the scope of this state’s problem, where the illegal mattress dumping

is occurring, tactics that Oregon communities have or are using to address the problem, the

effectiveness of those tactics and where additional work is needed. Once we have a

baseline understanding of the problem, then MRC will work with state and local officials,

community leaders and others to develop a fact-based consensus on how to proceed.

In preparation for submitting this Plan, MRC has had preliminary meetings with Portland

Metro (Metro) staff who have sought to address this issue for years. Metro has developed

and maintains a robust database that captures and analyzes information collected across

its jurisdiction about illegally dumped products including mattresses. Metro also deploys

well balanced dumping mitigation strategies. Leveraging this valuable experience, MRC will

pursue the following three-stage process:

Stage 1: Approximately six months after the operational aspects of the Program (that is,

mattress collection, transport and recycling) have commenced, MRC will hold in depth

discussions with Metro staff and other select urban and rural communities to learn more

about how they collect and analyze illegal dumping data, limitations in their approach

and areas where they think that additional resources or tactics might be helpful. This will

accomplish two purposes. First, MRC will gain a baseline understanding of the illegal

mattress dumping problem in Portland and other regions in Oregon. Second, MRC will

learn whether some, or all of the approaches can be replicated in other urban, and

possibly rural, areas of Oregon.

Stage 2: Understanding how illegal mattress dumping affects the full state will enable

MRC to prioritize possible actions and measure whether those actions were effective in

mitigating the effects of illegal dumping. To obtain such information, MRC will survey

other communities regarding data that they currently collect about illegal dumping and

encourage those that do not currently collect that information to do so in the future.

MRC’s budget will allow it to offer some funding to help share the costs that these

communities may incur to gather such information. MRC’s goal will be to collect

statewide data to the best of our ability in a manner that is consistent with the long-term

data sets that Metro has already developed. This will allow the statewide data to be

compiled and analyzed in a consistent “apples to apples” manner. MRC’s goal is to

gather county or municipal illegal dumping data through an annual survey and for the

first statewide illegal mattress dumping census to be completed and shared with DEQ

by December 2026.

Stage 3: In parallel with the effort in Stage 1 and 2 to design and collect consistent

statewide data on illegal mattress dumping, MRC will also meet with Metro officials and

other urban and rural communities to learn in depth how their existing dumping

mitigation strategies work and the effectiveness of those strategies. MRC will also draw

on several approaches related to illegal dumping eradication, education and

enforcement that various California communities have developed in coordination with

the mattress recycling program in that state to determine if they can be replicated in

Oregon. Reports summarizing the results of completed California projects may be

accessed at https://mattressrecyclingcouncil.org/illegal-dumping/. During this stage,

MRC will also develop and publicize criteria for communities or private entities to

propose, and for MRC to fund, pilot projects to implement ideas that have the potential

to mitigate illegal dumping and associated costs.

With this background information in hand, MRC will then implement its pilot programs

annually for the remainder of the Plan term. MRC will encourage Oregon communities to try

new ideas for addressing this persistent problem of illegal mattress dumping and to make

the results of those efforts available publicly to help de-risk the process for other

communities in the state to try new and tested concepts.

In short, MRC wants to:

• Understand how Metro and other urban and rural communities collect illegal

dumping data.

• Develop a statewide database that will help define the scope of the illegal mattress

dumping problem in Oregon.

• Use that information to establish fact-based priorities.

• Fund pilot projects proposed by Oregon communities and other entities that are

designed to discourage illegal dumping in the future and mitigate the costs

associated with illegal dumping.

MRC will include updates on progress and findings regarding the three-stage illegal

dumping plan, pilot studies and final reports or case studies in the annual report. By

following this multistep process, MRC will be in a position to be able to make fact-based

decisions designed to further the statutory objective of mitigating the fiscal, health and

social costs of illegal dumping.

Part 11 – Public Education, Advertising and Promotion

a) Describe how the stewardship organization will provide public

education, advertising and promotion of discarded mattress collection

opportunities statewide and on a regular basis.

i) Explain how education will be enhanced in the first years of the program

to grow awareness of the new program.

ii) For each type of outreach, include details such as frequency, reach,

languages that will be used and what areas of the state are being

targeted.

iii) Ensuring equity in the program is of particular importance to DEQ,

including methods that make for equitable outcomes, measuring for

equity and making changes as needed.

MRC’s education and outreach efforts will target consumers, the mattress industry, the

collection network, state regulators and other stakeholders. To reach these audiences,

MRC will use existing industry- and consumer-facing brands.

The primary brand, Mattress Recycling Council, will be used to:

• Educate the mattress industry about program mechanics, Oregon’s mattress

recycling law and their legal obligations under that law.

• Inform regulators about the Program’s performance.

• Encourage mattress collectors and collection sites throughout Oregon to work

with MRC to divert mattresses from landfills and combat illegal mattress

dumping.

• Inform the collection network and recyclers about MRC’s expectations for proper

screening, stacking, loading and environmentally sound management of

mattresses.

• Share expertise, resources, the results of research projects and outcomes.

MRC will use its consumer-facing sub-brand, Bye Bye Mattress, to inform those looking

to discard a mattress about their options. Specifically:

• Residents will learn about their nearest drop-off location, as well as available

bulky item curbside waste collectors that offer at least one free pickup each year.

• Businesses will learn how to work with MRC to have old mattresses transported

and recycled at no-cost.

• The public will learn about the Program, the assessment, eligible and ineligible

items, how a mattress is recycled and why recycling is beneficial.

• The Bye Bye Mattress website (ByeByeMattress.com) will include an interactive

locator to find important details about the no-cost collection opportunities.

To meet these outreach objectives, MRC will use a comprehensive mix of methods

including, but not limited to advertising, public relations, social and digital media, direct

marketing and event sponsorships. MRC is committed to educating Oregon residents by

following multichannel (print, TV, radio, digital, social media, word of mouth, grassroots,

etc.) and multilingual industry best practices. Not only will this approach create multiple

opportunities for one person to hear about the Program, but it will allow MRC to inform

different people in different types of communities about the Program.

MRC will monitor the effectiveness of this communications strategy through an annual

survey (described in more detail in Measuring Impact of Outreach) to collect

demographic information that will allow MRC to monitor resident awareness across the

state and also among specific segments.

Growing Awareness of the New Program (Years 1-3)

In the initial years of the Oregon Program, MRC will implement tactics that have already

proven successful at promoting collection opportunities in other mattress recycling

programs. These include:

• Providing retailers with point-of-sale materials in the five most common

spoken languages. These materials include an information card, poster, digital

badge (an image for use on a website or other digital material) and a question-

and-answer sheet to help retailers explain the assessment to customers and how

to find recycling opportunities. According to the Oregon Secretary of State’s

office (which is required to publish the five most common languages spoken in

the state other than English), Spanish, Vietnamese, Chinese, Korean and

Russian are the current most spoken additional languages. MRC will provide the

information card and poster in each of these languages.

• Offering local media a public service announcement (PSA). Each spring and

fall, MRC will distribute a 30-second PSA to television and radio outlets in three

languages – English, Spanish and Chinese (Mandarin). MRC will distribute the

PSA in these seasons because behaviors leading to mattress discards –

(mattress sales peaks, seasonal cleaning, more home sales and increased

moving activity) are higher at those times of year.

• Seeking media coverage opportunities. After the Program launches, MRC will

issue a press release statewide and encourage media interviews that may

include collection sites and a recycler tour. On an ongoing basis, MRC will work

with a media consultant to pitch content ideas to influential community news

sources and build relationships with journalists in order to be established as the

expert source for mattress recycling information and content.

• Distributing a publicity toolkit to participating collection sites, recyclers

and local officials. MRC’s toolkit will allow stakeholders to self-promote the

Program in their community using customizable flyers, social media posts and

website/newsletter content with specific site details. This toolkit will be made

available to all collection sites and recyclers and applicable local officials three

weeks before the Program launches. As toolkits are being developed and

distributed, MRC will coordinate with those individuals and entities who have

expressed interest in using the toolkit.

Once the Program begins, toolkits will be distributed as a site or recycler joins the

collection network. MRC will encourage use of the toolkits seasonally (Earth Day

and America Recycles Day). As MRC builds relationships, other promotional

opportunities may arise as MRC learns more about a site, recycler or local

government’s needs. In other states with mattress recycling programs, collection

sites, recyclers and local officials have taken their own initiative to incorporate

MRC’s messaging into their communications as they find most appropriate.

• Engaging and collaborating with community-based groups. MRC will seek

out groups that value community beautification or recycling education, and that

assist minority, low-income or other historically underrepresented people. MRC

will ask these groups to help promote the Program to these audiences (e.g,

publishing our information in their printed materials, on their websites, mentioning

us or allowing us to speak during their meetings or events, etc.). MRC will offer

community-based groups a set of materials similar to those provided to local

officials, and will translate those materials if necessary. MRC is also open to

collaborating with a group to create and conduct outreach in a culturally

appropriate manner for their audience.

• Participating in community events focused on environmental and recycling

education. During Earth Day (April 22) and America Recycles Day (Nov.15),

many communities host festivals or environmental- or recycling-themed events.

MRC may either participate as a vendor or provide Program information for

distribution to attendees about mattress recycling opportunities in their

communities. MRC considers event sponsorship/vendor proposals from all

communities, and would support appropriate proposals, based on available

resources.

If MRC exhibits at a community event, it will use an informative booth similar to

what other state mattress recycling programs have used, consisting of a tabletop

display with pull up banners (or a tent wrap) that provides an activity to educate

the visitor and encourages interaction with MRC. Ultimately the visitor should

walk away knowing a mattress can be recycled and how to recycle it in their

immediate area and that they (as well as friends and family) may access

ByeByeMattress.com to obtain more information about the Program.

Booth banners (or tent wrap) and materials promote Bye Bye Mattress and messaging that

encourages recycling, a QR code flyer or other printed items (info cards or posters) help

booth visitors immediately learn about the local options, show-and-tell clear acrylic boxes of

various mattress materials create opportunities for engagement and pique curiosity, a

stacking tower game reinforces why mattress recycling is important and how to do it, as

well as remembering ByeByeMattress.com.

This experience is versatile, allowing MRC to fit spaces as small as a 6-foot table

or as large as 10-foot by 10-foot space. It does not require electricity and all of

the booth elements can be easily transported, making it suitable for indoor or

outdoor environments.

MRC would also take advantage of any other advertising or marketing benefits

provided as a result of the selected exhibitor/sponsorship level. Based on

previous experience this provides MRC extra visibility of the Bye Bye Mattress

website URL and logo on event materials, other banners or signage on the event

grounds, social media exposure, dedicated email blasts to registered

participants, remarks at the event or a short news interview or segment by the

event’s media sponsor.

If MRC is unable to exhibit or sponsor, we would attempt to use relationships with

collection site operators, recyclers, solid waste haulers, etc. who may have a

presence at the event as an exhibitor or sponsor in order to distribute information

to consumers.

• Working with other industry associations and industry media to encourage

mattress recycling. Large volume generators of discarded mattresses including

mattress retailers, hotels, schools, healthcare facilities and military installations are

typically networked in the mattress industry and will have access to no-cost

recycling. MRC and ISPA have long-standing relationships with industry

associations and media covering the home furnishings, lodging and educational

sectors. MRC promotes how different businesses can work with MRC to recycle

throughout the year via advertisements or editorial opportunities in these

associations’ member communications and the trade media. MRC will expand the

existing industry-facing advertising plan to reach Oregon professionals in these

industries and update the ads to include Oregon.

Measuring Impact of Outreach

MRC will collect and analyze metrics to determine the effectiveness of Program launch

communications.

On a regular basis, we monitor the number of ByeByeMattress.com visitors accessing

the website, the number of impressions and airings of the PSA and the collective

impressions of MRC’s media outreach and the coverage generated by publicity toolkits.

Each social media platform also provides analytics which MRC uses to monitor

performance of content and audience growth and engagement.

On an annual basis, MRC will issue a consumer survey to measure the percentage of

Oregon consumers aware of mattress recycling being available and free; and whether

they know how to access the Program in their area. Like MRC’s other state programs,

the survey will be conducted online and collect demographic, behavioral and attitudinal

data. The sample will be large enough to reach a 90% confidence level with a 5%

margin of error (approximately 500-1,000 responses) and reflect Oregon’s population in

terms of age, gender, race, ethnicity and household income based on current census

data. Collecting this demographic information, along with zip code and county of

residence, will allow us to analyze different segments of responses to understand if

there is a bias or inequality in Program knowledge (i.e. zip code analysis can identify

how knowledge of the Program compares in urban and rural areas). MRC will use the

mattress purchasing and disposal behavior questions to guide messaging, hone target

audience profiles, adjust timing of outreach, and identify the information sources or life

experiences that likely lead to the respondent’s knowledge of the Program or need for

the Program. This also allows MRC to understand how behaviors and lifestyle choices

are affecting knowledge and leading to intended action (i.e., Are those exhibiting certain

behaviors learning about the Program? Are changes in disposal behavior occurring?).

MRC will use questions about recycling attitudes and intentions to further understand

what Oregon residents believe and value so that messaging remains appealing and

relevant. MRC will repeat the survey each year to identify trends and changes. MRC’s

annual reports will include the questionnaire and results.

Maintaining/Expanding Awareness of Existing Program (Beyond Year 3)

In future years, based on awareness levels measured in the annual survey and the

Program’s financial performance, the following may be implemented to increase

awareness in a specific region, to a specific demographic or to a statewide audience:

• Targeted advertising such as online search and display ads, direct mail

campaigns, digital geofencing campaigns or social media advertisements.

• Advertising campaigns to a broader general audience. These campaigns would

use cable or broadcast TV, broadcast radio and other types of media capable of

wider reach.

• Sponsoring large community events that have statewide or regional significance.

b) Describe how the stewardship organization will identify and notify retailers

about the mattress stewardship program, and what information will be

provided.

i) If there are different sets of information for online and physical store

fronts, please describe them.

ii) This should include information necessary to comply with the program and

should be directed to all retailers selling or offering for sale mattresses in

Oregon.

As explained in Part 7(h), MRC will use a variety of sources to identify retailers selling

or offering for sale mattresses in Oregon. MRC will also leverage long-standing

relationships that we and ISPA have with other home furnishings associations to

notify their members.

Both online and brick-and-mortar mattress retailers will receive direct mail notices and

emails about the Program when the Plan is approved and will continue to receive

follow up communication as the Program is implemented. Furthermore, MRC will

encourage the home furnishings media to report on the Program’s development and

announce important information necessary to comply with the law. MRC will also

advertise the Program in industry news sources and distribute Program information at

industry events. MRC will also publish important details on our social media, in our

newsletters and on our website (MattressRecyclingCouncil.org).

Once registered with MRC, retailers will receive Program notices through the

registration portal (MRCreporting.org) and can sign-up to receive additional

information through our quarterly retailer newsletter and MRC’s monthly Highlights

newsletter.

c) Describe education efforts to participating collection sites and events,

including types of information provided and how often.

MRC will establish an ongoing relationship with participating collection sites and events.

A regional program coordinator will be the point of contact to educate these participating

locations about available resources including training videos, signage and marketing

assistance.

The program coordinator will visit each collection site biennially (at a minimum) to meet

with a site’s staff and leadership, evaluate adherence to the Collection Site

Requirements, conduct any needed training and collect feedback to help improve the

Program’s performance.

Participating collection sites and events will receive a quarterly newsletter from the

program coordinator and can opt-in to receive MRC’s monthly Highlights newsletter.

MRC uses these email publications to announce important Program details, milestones

and achievements, as well as to continually promote available resources. As Collection

sites and events are established, they receive the publicity toolkit described in 11(a).

MRC will also be involved in the regional solid waste community by attending

conferences and events, serving on task forces and seeking presentation

opportunities to stakeholder groups.

Part 12 – Closure Plan

Following the schedule described in statute, explain when the stewardship organization will submit a

proposed closure plan to DEQ for approval, as part of the initial program plan.

MRC will submit a closure plan to DEQ no later than two years after implementation, as

required by Section 8(2).

Part 13 – Coordination

Describe methods that will be used by the stewardship organization to identify, engage and

coordinate activities with existing recycling programs, including existing nonprofit organizations that

are mattress recyclers, to further the environmentally sound management of discarded mattresses.

In April 2023, MRC requested proposals from parties interested in providing recycling

services to implement MRC’s Program in Oregon. In requesting these proposals, MRC

directly contacted all existing mattress recyclers in Oregon (including non-profit recyclers),

posted the request on MRC’s website and visited all active mattress recyclers in Oregon to

assess capabilities, interest in participating in the Program, and future plans. See Part 4(e)

for a list of recyclers that MRC intends to contract with to implement its Program in Oregon.

MRC also included existing mattress recyclers in its collection site survey.

Additionally, MRC will explore collaborating with other state and local recycling programs to

pool resources on collection events and education strategies to improve Program

participation. MRC will draw from its prior experience in California joining multi-material

collection events and seeking joint-marketing opportunities with other recycling programs.

Part 14 – Program Changes

a) Describe procedures, including how the stewardship organization will consult

with DEQ, regarding changes to the system for collecting discarded

mattresses that may require a plan amendment.

As required by Section 7 of the Act, a Plan amendment is required if there is a

material change to the collection system, if MRC proposes a change to the

assessment, or if DEQ requests an amendment based on budget-related findings.

As required by Section 7(3) and OAR 340-098-0460, MRC will report monthly to

DEQ changes in the location or number of permanent collection sites, a change in

the producers, retailers or renovators registered with MRC, or a change in the

recyclers, renovators or reuse facilities managing discarded mattresses under the

Program. MRC anticipates these changes will be frequent during the initial years of

the Program and will not substantially or materially change the Program’s

functionality.

b) Include a description of how the stewardship organization will submit a plan

amendment or notification on a timely basis as required by Section 7 of the

Mattress Stewardship Act and OAR 340-098-0460.

Sections 6 and 7 of the Act clearly describe circumstances, timelines and

mechanisms that the stewardship organization shall follow to submit Plan

amendments. MRC will follow those provisions.

Part 15 – Contact and Certifying Information

A stewardship organization should provide a primary contact for the organization

managing the mattress stewardship program in Oregon. This should include the

contact’s name, address, phone number and email address. Please specify when

the stewardship organization will notify DEQ if this contact changes (for instance,

within two business days of the change).

Justine Fallon

501 Wythe Street

Alexandria, VA 22314

(860) 397-4847

jfallon@mrc-us.org

MRC will notify DEQ within three business days if there is a change to the primary

contact.

The following certifying statement should be included with the signature of the

program’s authorized representative: I, [name of authorized representative], hereby

declare under penalty of false swearing (Oregon Revised Statute 162.075 and ORS

162.085) that the above information and all of the statements, documents and

attachments submitted with this plan are true and correct.

I, Ryan Trainer, hereby declare under penalty of false swearing (Oregon Revised Statute

162.075 and ORS 162.085) that the above information and all of the statements,

documents and attachments submitted with this plan are true and correct.

Ryan Trainer, President ISPA and MRC

As part of the plan submittal, a stewardship organization should also provide:

a) Documentation of the stewardship organization’s non-profit status, including:

i) 501(c)(3) status in Oregon

MRC is a wholly owned tax-exempt subsidiary of MRC, Inc., a Delaware

nonprofit, nonstock corporation recognized as tax-exempt pursuant to Section

501(c)(3) of the Internal Revenue Code and classified as a public charity. MRC is

recognized as an organization exempt from federal income tax under Section

501(c)(3) by virtue of its status as a disregarded entity of MRC, a sole exempt

organization owner, pursuant to Treasury Regulation Section 301.7701-2(c)(2)(i)

and Announcement 99-102, 1999-43 I.R.B.545. A copy of the IRS determination

letter of MRC Inc. has been e-mailed to DEQ per Plan Guidelines.

ii) Articles of incorporation

A copy of the Certificate of Formation and Operating Agreement of MRC has

been e-mailed to DEQ per Plan Guidelines. The Certificate of Formation and

Operating Agreement respectively serve the same functions as the Articles of

Incorporation.

iii) Proof of registration as a charity with the Oregon Department of Justice

MRC’s Registration for Charitable Organizations was filed with the Oregon

Department of Justice on September 14, 2023. A copy has been e-mailed to

DEQ per Plan Guidelines.

iv) If incorporated outside of Oregon, proof of registration as a foreign

corporation with the Oregon Secretary of State

MRC’s 2023 Amended Annual Report to the Oregon Secretary of State has been

e-mailed to DEQ per Plan Guidelines.

b) Proof of adequate liability insurance for a stewardship organization and

contractors working for the stewardship organization

MRC Inc. and MRC carries insurance with the following minimum limits:

• Commercial General Liability – minimum of $1 million per incident/$1 million

aggregate

• Commercial Automobile Liability – minimum of $1 million combined single limit

Supplemental Information

MRC’s Evidence of Commercial General Liability and Commercial Automobile

Insurance listing MRC as a covered entity has been e-mailed to DEQ per Plan

Guidelines. However, MRC intends to rely on its contractors’ insurance for activities

undertaken by contractors whenever possible as most contracts will require that

contractors’ insurance coverage be primary to MRC’s policies.

Contractors Insurance

MRC will require, by contract, that all contractors (collection sites, transporters,

recyclers, etc.) carry insurance appropriate to the level of services that they provide

for the Program. While the specific amount and terms may vary from contractor to

contractor, all contractors will be required to have coverage that the MRC considers

to be adequate to address the risk and liability for the activities undertaken by the

applicable contractor. MRC will typically require the following minimum insurance

coverage in service contracts:

Commercial General Liability Insurance

• Collection Sites: require limits of at least $1 million per occurrence.

• Transportation and/or Recycling Contractors: limits not less than $1-2 million per

occurrence and $2 million in the aggregate.

Commercial Automobile Liability Insurance

• Collection Sites: For sites that will engage in the transportation of program

mattresses under the Program, MRC will require that they carry commercial

automobile liability insurance (owned, non-owned or hired) written on an

occurrence basis with limits not less than $1 million for each occurrence.

• Transport and/or Recycling Contractors: All Transporters and any Recyclers

that will engage in the transportation of program mattresses under the

Program, MRC will require that these contractors carry commercial automobile

liability insurance (owned, non-owned or hired) written on an occurrence basis

with limits not less than $1 million for each occurrence.

In addition, MRC will typically require the policies of any contractor involved in the

transport or recycling of program Mattresses under the Program to contain

endorsements to name MRC as an additional insured on both of these required

insurance policies, as well as a waiver of subrogation in favor of MRC.

Because contractors have widely different insurance policies (e.g., commercial

insurance vs. self-insurance, etc.), MRC will evaluate the insurance terms in each

contract on a case-by-case basis to confirm that the contractor maintains insurance of

the types and in amounts adequate to address both risk and liability to both MRC and

the contractor. In Oregon, this may include alternative self-insurance requirements for

municipalities and municipal insurance or retention pools. MRC may seek the opinions

of outside counsel and MRC insurance brokers in the evaluation of the adequacy of

various insurance policies.

At time of Plan submittal, MRC has not executed any service contracts and therefore

cannot provide proof of insurance for those contractors.

Appendix A: Registered Producers, Renovators and Retailers

Per Section 4(1)(d), these tables identify each producer, renovator and retailer that has registered with MRC as of May 31, 2024 (30

days before the plan submittal). MRC submitted a separate version containing contact names to DEQ and requested confidentiality.

TABLE 5: Registered Producers

Section 2(15): “Producer” means any person, irrespective of the selling technique used, including that of remote sale, that:

(a) Manufactures a mattress that is sold, offered for sale or distributed in this state;

(b) Is the owner of a trademark or brand under which a mattress is sold, offered for sale or distributed in this state, whether or

not such trademark or brand is registered in this state; or

Company

DBA Name

Address City State Zip Country Phone

12 Park, LLC

Evaya Organics,

Serenia Sleep

12 Park St.

Webster

01570

USA

(508) 943-0440

815 Healthy &

Beautiful Co. Ltd

King’s Castle HK

Import and

Export Co.

Limited

78-27, Seodunmul-Gel,

Poseungeup

Pyeongtaek-Si

17814

KOR

(086) 177-5062

Aaron's, LLC

400 Galleria Pkwy SE

Atlanta

30339

USA

(678) 402-3325

American

Bedding Mfg. Inc.

American

Bedding Mfg. Inc.

2110 Redfern Dr.

Athens

37303

USA

(423) 745-1512

Ascion, LLC

Reverie

750 Denison Ct.

Bloomfield Hills

48302

USA

(248) 409-5656

Ashley Furniture

Industries, LLC

Ashley Furniture

Industries, LLC

One Ashley Way

Arcadia

54612

USA

(608) 323-6789

Appendices

Company

DBA Name

Address

City

State

Zip

Country

Phone

Bedgear, LLC

Bedgear

1953 Langston St.

Rock Hill

29730

USA

(631) 414-7758

Bestar Inc.

4220 Villeneuve

Lac-Mégantic

G6B 2C3

CAN

(819) 583-1017

Bob Barker

Company Inc.

Bob Barker

Company Inc.

134 N Main St.

Fuquay-Varina

27526

USA

1-800-334-9880

Boyd Flotation

Inc.

Boyd Specialty

Sleep

2440 Adie Rd.

Maryland Heights

63043

USA

(314) 997-5222

Brentwood

Home, LLC

Simply Modern

Mattress

570 A N Gilbert St.

Fullerton

92833

USA

(562) 949-3759

Brooklyn

Bedding, LLC

Dreamfoam

Bedding,

Brooklyn

Bedding, Helix

Sleep, Bear

Mattress, Nolah

Sleep, Leesa

Sleep

5301 W Bethany Home Rd.

Glendale

85301

USA

(888) 213-8967

Bryte Inc.

Bryte Labs

221 Main St. 570

Los Altos

94022

USA

(844) 440-9462

Carpenter Co.

5016 Monument Ave.

Richmond

23230

USA

(804) 359-0800

Casper Sleep

Inc.

Casper

175 Greenwich St.

New York

10007

USA

(646) 361-2458

Children's

Products, LLC

Simmons

Juvenile

Furniture

114 W 26th St.

New York

10001

USA

(212) 736-7000

Colchones

Wendy SA De

Colchones

Wendy

Calle 3, 1401

Guadalajara

JAL

44940

MEX

(333) 884-2000

Comfort DTC Inc.

Molecule

360 N Pacific Coast Hwy Ste.

2000

El Segundo

90245

USA

(833) 365-7378

Comfort

Revolution, LLC

Comfort

Revolution, LLC

One Office Parkway

Trinity

27370

USA

(662) 454-7526

Consolidated

Hospitality

Supplies, LLC

Consolidated

Hospitality

Supplies, LLC

544 Lakeview Pkwy

Vernon Hills

60061

USA

(800) 323-5686

Correctional

Technologies Inc.

Cortech USA

7530 Plaza Ct

Willowbrook

60527

USA

(630) 455-0811

Company

DBA Name

Address

City

State

Zip

Country

Phone

Corsicana

Acquisition, LLC

Corsicana

Mattress

Company

3001 S US Hwy 287

Corsicana

75109

USA

(800) 323-4349

Costco

Wholesale

Corporation

Costco

Wholesale

Corporation

Attn Tax Dept

Seattle

98134-

2389

USA

(425) 313-8100

Custom Comfort

Mattress

Company Inc.

Custom Comfort

Mattress

579 N. Batavia St.

Orange

92868

USA

(714) 693-6169

Custom Mattress

Makers Inc.

Custom Mattress

Makers Inc.

13101 56th Ct

Clearwater

33760

USA

(413) 537-8307

CVB Inc.

LUCID®

MATTRESS,

WELLSVILLE®,

LINENSPA®

1525 W 2960 S

Logan

84321

USA

(435) 232-5369

Denver Mattress

Company, LLC

Denver Mattress

Company

5651 Broadway

Denver

80216

USA

(303) 566-8700

Direct Supply Inc.

Direct Supply;

Direct Supply

Equipment &

Furnishings;

Direct Supply of

Wisconsin

6767 N Industrial Rd.

Milwaukee

53216

USA

(414) 760-5895

Dishuo Furniture

PTE. Ltd

Dishuo Furniture

PTE. Ltd

8 Tuas South Ln #01-51

Factory 2

Singapore

637302

SGP

(006) 569-7074

Elements

International

Kyvno, LLC

PO Box 851601

Mesquite

75185

USA

(877) 575-3888

Ergomotion Inc.

6790 Navigator Dr.

Goleta

93117

USA

(805) 979-3931

Feng Ben

International (HK)

Limited

Feng Ben

International (HK)

Limited

No.15 Xinkang Rd., Xinyang

Industrial Area, Haicang,

Xiamen, Fujian, China

Xiamen

361000

CHN

(861) 895-0057

Future Foam Inc.

1610 Ave. N

Council Bluffs

51501

USA

(712) 323-9122

FXI Inc.

FXI

100 Matsonford Rd.

Radnor

19087

USA

(908) 675-3925

Gateway

Mattress Co. Inc.

Gateway

Mattress Co. Inc.

624 S Vail Ave.

Montebello

90640

USA

(323) 725-1923

Company

DBA Name

Address

City

State

Zip

Country

Phone

GF Health

Products Inc.

GF Health

Products Inc.

One Graham-Field Way

Atlanta

30340

USA

(678) 291-3261

Golden Well

International (HK)

Ltd

Golden Well

International (HK)

Ltd

Room 2,2/F Tower1, Harbour

Centre, 1 Hok Cheung St.,

Hunghom, HK

Hongkong

999077

CHN

(189) 600-1376

Grand Life Inc.

14647 Northam St.

La Mirada

90638

USA

(213) 255-1234

Heartland

Mattress, LLC

Heartland

Mattress

1770 N 500 W

Shipshewana

46565

USA

(260) 768-7875

Hong Kong Gesin

Technology

Company Ltd

Hong Kong Gesin

Technology

Company Ltd

27885 Irma Lee Cir.

Lake Forest

60045

USA

(847) 910-1133

Honor Global

Industry PTE. Ltd

Glory

No. 555 W Kangxing Rd.

Jiaxing

314113

CHN

(086) 057-3846

Honor Home

(Laos) Sole Co.

Ltd

Honor Home

(Laos) Sole Co.

Ltd

Vientiane Saysettha

Development Zone,

YouyiRd.ano Village, Saysettha

District

Vientiane

01000

LAO

(086) 157-5737

IKEA Supply AG

IKEA

Gruessenweg 15

Pratteln

4133

CHE

(004) 179-7437

InnoMax

Corporation

InnoMax

Corporation

530 W Elk Pl.

Denver

80216

USA

(303) 296-9530

Invacare

Corporation

Invacare

Corporation

One Invacare Way

Elyria

44035

USA

(440) 329-6000

Joerns

Healthcare, LLC

Joerns

Healthcare

2430 Whitehall Park Dr.

Charlotte

28273

USA

(704) 499-6000

Keeson

Technology

Corporation LTD

Keeson

Technology

Corporation LTD

No 195 Yuanfeng Rd.,

Wangjiangjing

Zhejiang

314016

CHN

(805) 979-3931

King’s Castle HK

Import and

Export Co.

Limited

Deluxe Home of

USA Inc.

Flat C 23/F Lucky Plaza, 315-

321 Lucky Rd.

Hong Kong

999077

HKG

(086) 595-2772

Kingsdown Inc.

126 W Holt St.

Mebane

27302

USA

(919) 563-3531

Kuka Sleep Inc.

3584 Mountain Creek Pkwy

Dallas

75236

USA

(911) 448-1743

Lakewood

Candies, LLC

Milliard Bedding

1980 Swarthmore Ave.

Lakewood

08701

USA

(866) 686-4891

Company

DBA Name

Address

City

State

Zip

Country

Phone

Legends Home

10300 W. Buckeye Rd.

Tolleson

85353

USA

(801) 837-4826

Leggett & Platt

Automotive

Group de Mexico,

S. de R.L. de

C.V.

Leggett & Platt

Automotive

Group de Mexico,

S. de R.L. de

C.V.

Hermanos Escobar #6640

Juarez

CHH

32410

MEX

(417) 358-8131

Lippert

Components Inc.

Lippert

Components Inc.

3501 County Rd. 6

Elkhart

46514

USA

(574) 891-3243

Lull Ventures,

LLC

Lull

3905 State St.

Santa Barbara

93105

USA

(800) 301-5845

Mattress Firm

Inc.

Mattress Firm

Inc.

3250 Briarpark, Ste. 400

Houston

77042

USA

(346) 718-5490

MTJ American,

LLC

MTJ American

4276 Helena St.

Hudson

28638

USA

(828) 396-1537

Noble House

Home

Furnishings, LLC

Noble House

Home

Furnishings

21325 Superior St.

Chatsworth

91311

USA

(845) 558-1730

Norix Group Inc.

1 Innovation Dr.

West Chicago

60185

USA

(630) 231-1331

Oregon

Corrections

Enterprises

Oregon

Corrections

Enterprises

PO Box 12849

Salem

97309

USA

(541) 922-6156

Organic

Mattresses Inc.

Organic

Mattresses Inc.

1335 Harter Pkwy

Yuba City

95993

USA

(530) 790-6723

Peace Lily Sleep

Peace Lily

58 - 60 Levanswell Rd.

Moorabbin

VIC

3189

AUS

(888) 420-1467

Pleasant

Mattress Inc.

Pleasant

Mattress Inc.

375 S West Ave.

Fresno

93706

USA

(559) 268-6446

Poliuretanos SA

De CV

Poliuretanos SA

De CV

Noble House s/n, Zona

Industrial Toluca,

Toluca

MEX

50071

MEX

(722) 214-9900

Purple

Innovation, LLC

Purple

4100 N Chapel Ridge Rd.

Lehi

84043

USA

(801) 756-2600

Quality Sleep

Shop

My Green

Mattress

1519 W 55th St.

La Grange Highlands

60525

USA

(877) 737-8237

Resident Home,

LLC

Resident

100 Logistics Ave.

Jeffersonville

47130

USA

(908) 752-1388

Company

DBA Name

Address

City

State

Zip

Country

Phone

Restwell Mattress

Co.

Restwell Mattress

Factory

9901 W 74th St. #120

Eden Prairie

55344

USA

(952) 920-7860

Safe For Home

Products, LLC

Naturepedic

16925 Park Circle Dr.

Chagrin Falls

44023

USA

(440) 543-1483

SBL, LLC

SBl, LLC

5645 W 31st St.

Cicero

60804

USA

(800) 777-5282

Sealy Mattress

Manufacturing

Company, LLC

Sealy Mattress

Manufacturing

Company

1000 Tempur Way

Lexington

40511

USA

(614) 629-8056

Serta Simmons

Bedding, LLC

Serta and

Simmons

2451 Industry Ave.

Doraville

30360

USA

(404) 534-5000

Sferra Fine

Linens, LLC

Sferra

15 Mayfield Ave.

Edison

08837

USA

(646) 822-0473

Sherwood West,

LLC

Sherwood West,

LLC

2830 NE 29th St.

Ft. Lauderdale

33306

USA

(954) 566-9115

Solstice Sleep

Products Inc.

Solstice Sleep

Products Inc.

3720 W Broad St.

Columbus

43228

USA

(614) 670-4655

Somnium Inc.

PO Box 1804

Venice

90294

USA

(323) 655-6700

South Bay

International Inc.

South Bay

International Inc.

8570 Hickory Ave. Ste. 150

Rancho Cucamonga

91739

USA

(909) 718-5000

Southerland Inc.

6050 Dana Way

Antioch

37013

USA

(615) 226-9650

Stylus Sofas Inc.

Stylus, Made to

Order Sofas

7885 Riverfront Gate

Burnaby

V5J5L6

CAN

(604) 436-4100

Tempur

Production USA,

LLC

Mountain Top

Foam

25 Elmwood Rd.

Mountain Top

18707

USA

(570) 715-7200

The Furniture

Bank

Houston

Furniture Bank

8220 Mosley Rd.

Houston

77075

USA

(713) 842-9771

The Original

Mattress Factory

Inc.

The Original

Mattress Factory

4930 State Rd.

Cleveland

44134

USA

(216) 661-8388

Transcosmos

America Inc.

Transcosmos

America Inc.

879 W. 190

St., #410

Gardena

90248

USA

(310) 630-0072

University Loft

Company

University Loft

Company

2588 Jannetides Blvd.

Greenfield

46140

USA

(317) 866-5697

TABLE 6: Registered Renovators

Section 2(18): "Renovator" means a person that renovates discarded mattresses.

Company

DBA Name

Address

City

State

Zip

Phone

American Mattress Manufacturing

4075 W 11th

Eugene

97402

(541) 343-2690

Gateway Mattress Co. Inc.

624 S Vail Ave.

Montebello

90640

(323) 725-1923

St Vincent De Paul of Lane Co.

Inc.

St Vinnies

2890 Chad Dr.

Eugene

97408

(541) 687-5820

Company

DBA Name

Address

City

State

Zip

Country

Phone

Ureblock S.A. DE

C.V.

Ureblock

Calle 4 Num 300

Zapopan

Jalisco

45134

MEX

52333-836-4000

Victory Supply,

LLC

Victory Supply,

LLC

7025 Industrial Park Rd.

Mount Pleasant

38474

USA

(888) 376-1205

Vien Lam Co. Ltd

Hanh Loc Quarter, Khanh Binh

Ward

Tan Uyen

75412

VNM

(008) 427-4380

Vispring Limited

Ernesettle Ln.

Plymouth

Devon

GBR

(855) 511-1199

VPC Group Inc.

VPC Group

150 Toro Rd.

Toronto

M3J2A9

CAN

(905) 577-3898

Werner Media

Partners, LLC

Ghostbed

7143 W Broward Blvd.

Plantation

33317

USA

(855) 855-4499

Xiamen

Moreshire Import

and Export Co.

LTD

Xiamen

Moreshire Import

and Export Co.

LTD

Elevator 304, Block C,

Yincheng, Zhigu Building A6,

Tong 'an District, Xiamen,

Fujian

Xiamen

361000

CHN

(861) 380-6062

Zinus Inc.

5731 Promontory Pkwy

Tracy

95377

USA

(925) 417-2100

Zoma Sleep, LLC

Zoma Sleep

7167 E Rancho Vista Dr.

Scottsdale

85251

USA

(888) 400-8856

TABLE 7: Registered Retailers

Section 2(19): “Retailer” means a person that offers new, used or renovated mattresses for retail sale.

Company

DBA Name

Address

City

State

Zip

Phone

12 Park, LLC

Evaya Organics, Serenia Sleep

12 Park St.

Webster

01570

(508) 943-0440

A Lava Son, LLC

Naturally Nestled

4800 S Kilbourn Ave.

Chicago

60632

(773) 254-2800

Aaron's, LLC

400 Galleria Pkwy SE

Atlanta

30339

(678) 402-3325

AFM Mattress Company, LLC

American Mattress

1300 Pratt Blvd.

Elk Grove

Village

60007

(630) 279-0222

AgilityBed Inc.

ShopTherapedic

103 College Rd. E,

2nd Fl.

Princeton

08540

(877) 848-5753

Amazon.com Services, LLC

PO Box 81207

Seattle

98108

(206) 266-8365

American Bedding Mfg. Inc.

2110 Redfern Dr.

Athens

37303

(423) 745-1512

American Mattress Manufacturing

4075 W 11th

Eugene

97402

(541) 343-2690

Anchortex Corporation

420 Commerce Ln.

West Berlin

08091

(856) 768-5240

Arhaus, LLC

Arhaus Furniture

51 E Hines Hill Rd.

Boston

Heights

44236

(440) 439-7700

Ascion, LLC

Reverie

750 Denison Ct.

Bloomfield

Hills

48302

(248) 409-5656

Ashley Global Retail, LLC

Ashley Furniture Home Store

1 Ashley Way

Arcadia

54612

(608) 323-6337

Avocado Mattress, LLC

Avocado Green Mattress

12 Hudson Pl. Ste.

100-105

Hoboken

07030

(562) 949-3759

Barron's Home Furnishings

Barron's Home Furnishings &

Sleep Center

410 Oak St.

Brookings

97415

(541) 412-0250

Beach Trading Co. Inc.

www.buydig.com

80 Carter Dr.

Edison

08817

(732) 424-1100

Bedgear, LLC

Bedgear

1953 Langston St.

Rock Hill

29730

(631) 414-7758

Beds For Less Inc.

Ashley/Beds For Less

579 Rossanley Dr.

Medford

97501

(541) 858-5500

Belnick Retail, LLC

BizChair

4350 Ball Ground Hwy

Canton

30114

(800) 924-2472

Best Buy Stores L.P.

Best Buy

7601 Penn Ave. S

Richfield

55423

(612) 291-5337

BF Sleep, LLC

Big Fig Mattress

3201 Harvard Ave.

Newburgh

Heights

44105

(888) 344-6547

Big Lots Stores Inc.

Big Lots

4900 E Dublin

Granville Rd.

Columbus

43081

(614) 278-6300

Black Buggy Furniture, LLC

Black Buggy Furniture

74447 Larson Rd.

Rainier

97048

(360) 775-0325

Company

DBA Name

Address

City

State

Zip

Phone

Blackledge Furniture Company

Blackledge Furniture

233 SW Second St.

Corvallis

97339

(541) 753-4851

BLST Sales Marketing and

Servicing, LLC

Fingerhut

13300 Pioneer Trail

Eden Prairie

55347

(952) 656-3700

Bob Barker Company Inc.

134 N Main St.

Fuquay-

Varina

27526

1-800-334-9880

Boll & Branch, LLC

1 Prospect St.

Summit

07901

(908) 473-9920

Boring Mattress Company, LLC

Boring Mattress Co.

315 W Elliot Rd. #107-

430

Tempe

85284

(602) 753-0256

Boyd Flotation Inc.

Boyd Specialty Sleep

2440 Adie Rd.

Maryland

Heights

63043

(314) 997-5222

Brenner's Furniture Inc.

151 W 8th Ave.

Eugene

97401

(541) 345-4451

Brentwood Home, LLC

Simply Modern Mattress

570 A N Gilbert St.

Fullerton

92833

(562) 949-3759

Brooklyn Bedding, LLC

Dreamfoam Bedding, Brooklyn

Bedding, Helix Sleep, Bear

Mattress, Nolah Sleep, Leesa

Sleep

5301 W Bethany

Home Rd.

Glendale

85301

(888) 213-8967

Bryte Inc.

Bryte Labs

221 Main St. 570

Los Altos

94022

(844) 440-9462

Carpenter Co.

5016 Monument Ave.

Richmond

23230

(804) 359-0800

Casper Sleep Inc.

Casper

175 Greenwich St.

New York

10007

(646) 361-2458

Central Rent 2 Own

490 E Ln.

Ontario

97914

(541) 889-2786

City Liquidators Inc.

823 SE 3rd Ave.

Portland

97214

(503) 238-1367

Cocoon International Sales, LLC

1000 Tempur Way

Lexington

40511

(859) 455-1729

Comfort DTC Inc.

Molecule

360 N Pacific Coast

Hwy Ste. 2000

El Segundo

90245

(833) 365-7378

Comfort Revolution, LLC

One Office Parkway

Trinity

27370

(662) 454-7526

Consolidated Hospitality Supplies,

LLC

Consolidated Hospitality

Supplies, LLC

544 Lakeview Pkwy.

Vernon Hills

60061

2247861308

Correctional Technologies Inc.

Cortech USA

7530 Plaza Ct.

Willowbrook

60527

(630) 455-0811

Corsicana Acquisition, LLC

Corsicana Mattress Company

3001 S US Hwy 287

Corsicana

75109

(800) 323-4349

Costco Wholesale Corporation

Attn Tax Dept

Seattle

98134

(425) 313-8100

Courtesy Home Furnishings

Self Service Furniture

1313 Bridge St.

Clarkston

99403

(541) 523-7701

CTR Associates

Kelly's Furniture, Paul Schatz

Furniture

3850 Hagers Grove

Rd.

Salem

97317

(503) 378-1794

Company

DBA Name

Address

City

State

Zip

Phone

Custom Comfort Mattress

Company Inc.

Custom Comfort Mattress

579 N Batavia St.

Orange

92868

(714) 693-6169

Custom Mattress Makers Inc.

13101 56th Ct

Clearwater

33760

(413) 537-8307

CVB Inc.

LUCID® MATTRESS,

WELLSVILLE®, LINENSPA®

1525 W 2960 S

Logan

84321

(435) 232-5369

Dania Inc.

Scandinavian Designs; Dania

Furniture

390 E Parkcenter Blvd.

Boise

83706

(208) 423-8869

Dennis M Rose

Plank and Coil

2259 NW Raleigh St.

Portland

97210

(503) 224-0551

Denver Mattress Company, LLC

Denver Mattress Company

5651 Broadway

Denver

80216

(303) 566-8700

Direct Mattress and Furniture

2701 E Wilshire Dr.

Eugene

97405

(541) 521-1942

Direct Supply Inc.

Direct Supply; Direct Supply

Equipment & Furnishings; Direct

Supply of Wisconsin

6767 N Industrial Rd.

Milwaukee

53216

(920) 207-0032

DirectBuy Operations, LLC

1221 Arrowhead Ct

Crown Point

46307

(219) 224-6986

Downey Sleep Center, LLC

Downey Sleep Center

600 E 2nd St.

The Dalles

97058

(154) 129-8876

E. Gregg Clemmer Inc.

Clemmer's Furniture

10070 SE Orient Dr.

Boring

97009

(503) 663-4950

East West Bedding, LLC

EasyRest

1401 S Edgewood St.

Baltimore

21227

(443) 573-1400

Elements International

Kyvno, LLC

PO Box 851601

Mesquite

75185

(877) 575-3888

Emerald City Organic Sleep

Solutions Inc.

ECO Sleep Solutions

25 E 8th Ave.

Eugeen

97401

(541) 343-1022

Emma Mattress Inc.

Emma Mattress

1209 Orange St.

Wilmington

19801

(310) 736-2504

Encore Home Furnishings, LLC

Encore Home Furnishings

2730 NE Bunn Rd.

McMinnville

97128

(503) 474-1937

Engles Furniture Inc.

2079 Sherman Ave.

North Bend

97459

(541) 756-1123

Ergomotion Inc.

6790 Navigator Dr.

Goleta

93117

(805) 979-3931

Ergopedic, LLC

Ergopedicsleep.com

PO Box 2787

Indio

92202

(602) 373-0002

Euromarket Designs Inc.

Crate & Barrel

1250 Techny Rd.

Northbrook

60062

847-272-2888

Express Furniture Services, LLC

Express Furniture Rental

2448 Foundry Park

Ave.

Fresno

93706

(559) 268-3074

Furniture City

550 NW Burnside Rd.

Gresham

97030

(503) 667-8927

Future Foam Inc.

1610 Ave. N

Council

Bluffs

51501

(712) 323-9122

x223

Company

DBA Name

Address

City

State

Zip

Phone

Gates Furniture of Grants Pass

Inc.

Gates Home Furnishings

700 SW 6th St.

Grants Pass

97526

(541) 476-4627

Gateway Mattress Co. Inc.

624 S Vail Ave.

Montebello

90640

(323) 725-1923

GF Health Products Inc.

One Graham-Field

Way

Atlanta

30340

(678) 291-3261

Gilbert Investments Inc.

Edgewater Home Furnishings

155 Division Ave.

Eugene

97404

(541) 484-1962

Greg's Sleep Center

1725 N 1st St. Ste. D

Hermiston

97838

(541) 567-1099

Harvest Green Mattress, LLC

Harvest Green Mattress

3535 W 47th St.

Chicago

60632

(630) 204-5136

Haven Sleep Products Ltd

Haven Sleep Co.

1451 Richter St.

Kelowna

V1Y 2M1

(844) 694-2836

Hennick's Home Center Inc.

Hennick's Furniture & Sleep

Center

88296 Hwy 42 S

Bandon

97411

(541) 329-1233

Home Depot U.S.A. Inc.

Home Depot

2455 Paces Ferry Rd.

Atlanta

30339

(770) 384-4555

Homelife Furniture Inc.

Homelife Furniture

301 Main Ave.

Tillamook

97141

(503) 842-2005

HSNi, LLC

Home Shopping Network

1 HSN Dr.

St.

Petersburg

33729

(727) 872-1000

InnoMax Corporation

530 W Elk Pl.

Denver

80216

(303) 296-9530

Invacare Corporation

One Invacare Way

Elyria

44035

(440) 329-6787

Joerns Healthcare, LLC

Joerns Healthcare

2430 Whitehall Park

Dr.

Charlotte

28273

(704) 499-6000

Kohl's Department Stores Inc.

N56W17000

Ridgewood Dr.

Menomonee

Falls

53051

(262) 703-7000

Kuebler's Furniture Inc.

1894 Churn Creek Rd.

Redding

96002

(530) 221-9898

L&M Arnold Enterprises, LLC

Mattress Land

830 Biddle Rd.

Medford

97501

(541) 474-2337

Lakewood Candies, LLC

Milliard Bedding

1980 Swarthmore Ave.

Lakewood

08701

(866) 686-4891

Lavin Industries

European Sleep Works

2966 Adeline St.

Berkeley

94703

(510) 841-5340

Layla Sleep Inc.

Layla

157 Church St.

New Haven

06510

(203) 606-0526

LeafScore Inc.

970 W Broadway

Jackson

83001

(646) 640-7141

Lewis Home Source Inc.

Roby's Furniture and Appliance

1901 Main Ave. N

Tillamook

97141

(503) 842-7111

Lifekind Inc.

333 Crown Point Cir.

Grass Valley

95945

(530) 477-5395

Lippert Components Inc.

3501 County Rd. 6

Elkhart

46514

(574) 584-7330

Company

DBA Name

Address

City

State

Zip

Phone

Lucas & Howard Furniture Inc.

Ultimate Mattress & Bedroom

Company

2727 S 6th St.

Klamath Falls

97603

(541) 892-6191

Lull Ventures, LLC

Lull

3905 State St.

Santa

Barbara

93105

(800) 301-5845

Macy's Retail Holdings, LLC

Macy's

145 Progress Place

Springdale

45246

(513) 579-7322

Marpac, LLC

Yogabed

3870 US Hwy 421 N

Wilmington

28401

(800) 602-1421

Mattress Firm Inc.

3250 Briarpark, Ste.

400

Houston

77042

(346) 718-5490

Mattress MegaStore, LLC

Mattress MegaStore

175 Baseline St.

Hillsboro

97123

(503) 747-0808

MGOFF, LLC

Bedrooms West

590 NE Burnside Rd.

Gresham

97030

(503) 666-2376

Morgan’s Mattresses

18200 NE Halsey St.

Portland

97230

(503) 913-4364

MTJ American, LLC

MTJ American

4276 Helena St.

Hudson

28638

(828) 396-1537

Murray's Auction Center Inc.

Murray's Furniture, and Ashley

Homestore

4270 Belmont Dr.

Hood River

97031

(541) 386-3915

My Livingway, LLC

The American Furniture

320 Lancaster Dr. NE

Salem

97301

(971) 915-2266

Nest Bedding Inc.

Nest Bedding

1811 Concord Ave.

Ste. 110

Chico

95928

(530) 762-1630

Newton Baby Inc.

382 NE 191st St.

Miami

33179

(646) 383-4597

Noble House Home Furnishings,

LLC

Noble House Home Furnishings

21325 Superior St.

Chatsworth

91311

(845) 558-1730

Norix Group Inc.

1 Innovation Dr.

West

Chicago

60185

(630) 231-1331

Northwest Beds Inc.

Northwest Home Furnishings

86203 Franklin Blvd.

Eugene

97405

(541) 741-2109

Northwest Furniture and Mattress,

LLC

Northwest Furniture and

Mattress, LLC

215 Elm St.

La Grande

97850

(541) 963-5440

Northwest Furniture Outlet Inc.

Northwest Furniture Outlet

23300 S Hwy 99E

Canby

97013

(503) 266-8800

Northwest RTB9, LLC

Relax The Back

2750 SW Cedar Hills

Blvd.

Beaverton

97005

(503) 643-1088

Oregon Corrections Enterprises

PO Box 12849

Salem

97309

(541) 922-6156

Organic Exchange Inc.

200 NE 2nd St.

Boca Raton

33432

(561) 571-9800

x223

Organic Grace

11904 E. Alsea Hwy.

Tidewater

97390

(541) 528-2655

Company

DBA Name

Address

City

State

Zip

Phone

Organic Mattresses Inc.

1335 Harter Pkwy

Yuba City

95993

(530) 790-6723

Patriot Mattress & More, LLC

11119 Los Olivos Dr.

Moreno

Valley

92557

(951) 318-9469

Peace Lily Sleep

Peace Lily

58 - 60 Levanswell Rd.

Moorabbin

VIC

3189

(888) 420-1467

Penney OpCo, LLC

JCPenney

PO Box 10001

Dallas

75301

(801) 350-2535

Pleasant Mattress Inc.

375 S West Ave.

Fresno

93706

(559) 264-6446

Purple Innovation, LLC

Purple

4100 N Chapel Ridge

Rd.

Lehi

84043

(801) 756-2600

Quality Sleep Shop

My Green Mattress

1519 W 55th St.

La Grange

Highlands

60525

(877) 737-8237

QVC Inc.

1200 Wilson Dr.

West Chester

19380

(484) 701-1000

R.C. Willey Home Furnishings Inc.

R.C. Willey

2301 S 300 W.

Salt Lake

City

84115

(801) 461-3900

Relief Products, LLC

3500 20th St. E

Fife

98424

(253) 312-0653

Rent-A-Center Inc.

Rent-A-Center

5501 Headquarters Dr.

Plano

75024

(972) 801-1100

Resident Home, LLC

Resident

100 Logistics Ave.

Jeffersonville

47130

(908) 752-1388

Rested Development Inc.

America's Mattress

112 SE Douglas St.

Newport

97365

(541) 270-1546

Richardson's Furniture

Richardson's Furniture &

Mattress Gallery

2015 Columbia Blvd.

St Helens

97051

(503) 397-1329

Room & Board Inc.

Room & Board

4600 Olson Memorial

Hwy

Golden

Valley

55422

(763) 588-7525

Ruth Murphy Ltd

Murphy's Furniture

2962 Baseline St.

Cornelius

97113

(503) 640-1124

Safe For Home Products, LLC

Naturepedic

16925 Park Circle Dr.

Chagrin Falls

44023

(440) 543-1483

Salem Building Specialties

Kelly's Home Center

3850 Hagers Grove

Rd.

Salem

97317

(503) 378-1793

Scenic Dreams, LLC

Mattress Depot USA

32907 Ash Ave. SE

Black

Diamond

98010

(509) 344-9878

Sealy Mattress Manufacturing

Company, LLC

Sealy Mattress Manufacturing

Company

1000 Tempur Way

Lexington

40511

(614) 629-8056

Serta Simmons Bedding, LLC

Serta and Simmons

2451 Industry Ave.

Doraville

30360

(470) 509-1643

Sferra Fine Linens, LLC

Sferra

15 Mayfield Ave.

Edison

08837

(646) 822-0473

Shepherd Inc.

Roseburg Mattress

635 SE Stephens St.

Roseburg

97470

(541) 957-8866

Company

DBA Name

Address

City

State

Zip

Phone

Snowhite Hospitality, LLC

Boston Interior Solutions

476 Brighton Dr.

Bloomingdale

60108

(978) 562-9988

Solstice Sleep Products Inc.

3720 W Broad St.

Columbus

43228

(614) 279-8850

Sonu Sleep Corporation

Sonu Sleep

7321 Rindge Ave.

Playa Del

Rey

90293

(844) 444-7668

South Bay International Inc.

8570 Hickory Ave.,

Ste. 150

Rancho

Cucamonga

91739

(909) 718-5000

St Vincent De Paul of Lane Co.

Inc.

St Vinnies

2890 Chad Dr.

Eugene

97408

(541) 687-5820

Sterling Furniture Company

M.Jacobs Furniture

3194 Gateway Loop

Springfield

97477

(541) 726-6221

Stumptown Sleep, LLC

The Mattress Lot, Stumptown

Mattress

2406 NE Sandy Blvd.

Portland

97232

(503) 896-1072

Tempur Retail Stores, LLC

1000 Tempur Way

Lexington

40511

(859) 455-1729

Tempur-Pedic North America, LLC

Tempur-Pedic North America,

LLC

1000 Tempur Way

Lexington

40511

(859) 455-1000

Thanepohn Corp.

Mattress Mill

8383 Huffine Ln.

Bozeman

59718

(406) 586-4525

The Furniture Connexion

1800 NW Fairview Dr.

Gresham

97030

(503) 674-4488

The Furniture Superstore Inc.

Rife's Home Furniture

PO Box 25739

Eugene

97402

(458) 205-8923

The Original Mattress Factory Inc.

The Original Mattress Factory

4930 State Rd.

Cleveland

44134

(216) 661-8388

Thuma Inc.

1169 Gorgas Ave.

San

Francisco

94129

(415) 990-6492

TO & Sons Corp.

Michaels Fine Furniture

2011 NE 181st Ave.

Portland

97230

(503) 674-0414

Tom Busch Home Furnishings Inc.

Tom Busch Home Furnishings

Inc.

804 Main St.

Oregon City

97045

(503) 656-2621

TradeMango Solutions Inc.

Article

1010 Raymur Ave.

Vancouver

V6A 3T2

(604) 679-3107

Trailhead Ventures Inc.

Medley

3519 NE 15th Ave.

#590

Portland

97212

(323) 801-6892

Tru Furniture, LLC

222 S Broadway

Coos Bay

97420

(541) 294-3041

University Loft Company

2588 Jannetides Blvd.

Greenfield

46140

(317) 866-5657

Victory Supply, LLC

7025 Industrial Park

Rd.

Mount

Pleasant

38474

(888) 376-1205

Walker's Furniture Inc.

Walker's Furniture & Mattress

3808 N Sullivan Rd.

Spokane

Valley

99216

(509) 535-1995

Company

DBA Name

Address

City

State

Zip

Phone

Wallbeds By Wilding, LLC

Wilding Wallbeds

3988 S 1540 E Cir.

St. George

84790

(909) 680-4141

Werner Media Partners, LLC

Ghostbed

7143 W Broward Blvd.

Plantation

33317

(855) 855-4499

Williams-Sonoma Inc.

3250 Van Ness Ave.

San

Francisco

940109

(415) 421-7900

Wilson's of Redmond

2071 S Hwy 97

Redmond

97756

(541) 548-2066

Zinus Inc.

5731 Promontory

Pkwy

Tracy

95377

(925) 417-2100

Ziwi, LLC

Ziwi

801 S 1230 E

Alpine

84004

(801) 234-0038

Zoma Sleep, LLC

Zoma Sleep

7167 E Rancho Vista

Dr.

Scottsdale

85251

(888) 400-8856

Appendix B: Collection Site Requirements

Collection Site Requirements

Video Series

To complement the written requirements and assist facilities with training staff, MRC

develops short videos on specific topics. The examples here accompany the Northeast

Guidelines and MRC will develop similar videos for Oregon once the Plan is approved.

Included & Excluded

Products

English

Spanish

Effective Collection Site

Operations

English

Spanish

Stacking and Loading

Properly

English

Spanish

There are additional videos in the series. View more here: Northeast Guidelines Playlist

Appendix C: Recycling Standards

Oregon Mattress Recycling Standards

The Mattress Recycling Standards (Standards) define the minimum requirements to be an

approved Recycler for the Mattress Recycling Council Oregon, LLC (MRC). Under these

Standards, Mattresses must be managed and recycled in a manner that adequately

safeguards the environment, industry employees and consumers. The Standards also

includes data tracking and reporting requirements.

For purposes of these Standards, the term “Mattress” or “unit” means the same thing as

Mattresses and Foundations (or box springs) as defined in Section 2 of the Act and Section

1 of this Plan.

Background

MRC was formed to administer Oregon’s Mattress Recycling Program.

Recyclers must comply with Environmentally Sound Management practices and have

transparent operations, clear and documented recycling procedures and accurate tracking

of all Mattresses and components (including non-recyclable waste). All Recyclers will be

audited under these Standards and in accordance with Environmentally Sound

Management practices as defined in Section 2 of the Act.

Disclaimer

MRC does not intend for these Standards to constitute or provide legal guidance of any

kind. The Recycler must be aware of and abide by all local, state, or federal laws and

regulations applicable to the management of post-consumer Mattresses or the business

operation of the Recycler. In the event that these Standards violate any such laws or

regulations, the laws or regulations take precedence, and the Recycler must inform MRC of

such inconsistency.

1. General Requirements

Each Recycler shall:

1.1. Possess current and valid business licenses, insurance and meet all

applicable local, state and federal requirements for providing the type of

recycling services required by the MRC including but not limited to:

• Occupational Safety and Health Administration (OSHA) and applicable

local and state health and safety regulations

• Local and state fire department regulations, fire and building codes and

other applicable building and occupancy safety requirements

1.2. Maintain all records for a minimum of 4 years, including but not limited to

shipping documents (both for goods received and shipped), processing,

material disposal and sales records.

1.3. Develop and keep current a written plan that assures that:

1.3.1. inventory of unprocessed Mattresses (including both Program and

Non-Program Materials), stored either at Recycler’s premises

(including storage containers and truck trailers on its premises) or at

off-premises locations under Recycler’s control, will not exceed

[number to be determined] Units at any time;

1.3.2. Recycler’s facility or site will be properly closed in the event of sale,

closure, abandonment, bankruptcy, any form of dissolution of the

Recycler, or for any other reason, in compliance with all applicable

local, state and federal laws and regulations;

1.3.3. any Mattresses, Mattress materials, or other products or materials

processed by the Recycler will not be abandoned in the event of

closure;

1.3.4. any contamination to the Recycler’s facility or site will be properly

remediated in accordance with all applicable local, state and federal

laws and regulations;

1.3.5. Recycler will provide written notice of closure to MRC with a minimum

of 90-days advance notice; and

1.3.6. Recycler will maintain adequate funds or other resources that will be

used to fulfill these assurances should the need for such funds arise.

1.4. Maintain a consistent operating schedule and provide MRC with a written

notice of its holiday closures on an annual basis.

1.5. Provide written notice to MRC of any incidents that required the assistance of

first responders (fire, ambulance, police) within 12 hours of the occurrence.

1.6. Provide written notice to MRC of any regulatory orders, fines or other

governmental or administrative actions taken within 2 business days of

receiving such orders or fines.

1.7. Maintain a documented health and safety plan to record and track accidents,

injuries or violations and any corresponding corrective and/or preventive

actions taken.

1.8. Maintain a documented process to identify and communicate physical,

mechanical, biological or pathogenic hazards and severity of such hazard to

employees, and any corresponding corrective and/or preventive actions

taken.

1.9. Maintain a documented process to identify and communicate potential fire

hazards and severity of such hazards to employees, and any corresponding

corrective and/or preventive actions taken.

2. Material Processing

Each Recycler shall implement and maintain a documented plan for deconstructing

Mattresses, which shall at a minimum require the Recycler to:

2.1. Fully disassemble each unit.

2.2. Recycle at least 70% by weight of the Mattresses it processes by selling such

material through end markets that use the commodities in making new

materials or products.

2.3. Minimize the quantity of material disposed of through landfills, incineration,

waste to energy facilities or other non-recycling avenues.

2.4. Maintain a written policy describing how each Mattress type and material

(including pocket coils) will be processed.

2.5. Process all Mattresses within 30 days of receipt at deconstruction facilities.

2.6. List criteria applied in determining when a given Mattress cannot be

processed.

3. Material Tracking

Each Recycler shall implement and maintain a documented plan to track and control

Mattresses entering its processing facilities and the flow of recyclable and non-recyclable

materials generated through the Mattress deconstruction process. Under the plan, the

Recycler shall at minimum:

3.1. For all in-bound shipments, track and document each shipment using bills of

lading or other equivalent shipping documents.

3.2. Maintain in-house or third-party annually calibrated and certified scales to

weigh all in-bound loads.

3.3. For all out-bound shipments, track and document the fate of recyclable

mattress materials and solid waste shipments using bills of lading or other

equivalent shipping documents through final disposition within Oregon and

outside of Oregon.

3.4. Outbound shipment loads must be weighed using in-house or third-party

annually calibrated and certified scales.

3.5. Separately track Non-Program Mattresses received, processed and discarded

or recycled by the facility through final disposition within Oregon and outside

of Oregon.

3.6. Maintain a list of all purchasers of recycled materials and notify MRC of any

changes to that list at least 10 business days in advance (the MRC will treat

this information as confidential). Recycler must obtain written approval from

MRC for new purchasers of recycled materials.

3.7. Train employees on how to prepare and maintain all necessary records and

other documentation related to the receipt, processing, inventory and

disposition of Mattresses and Mattress materials.

3.8. Complete the provided Certificate of Recycling, Employment and Inventory on

a monthly basis.

4. Downstream Due Diligence

Each Recycler shall have processes in place to identify, audit and approve all purchasers

of recycled materials in accordance with Environmentally Sound Management practices as

defined in Section 2 of the Act. The processes shall at a minimum require:

4.1. Annual desk audits to verify each purchaser’s compliance with all applicable

local, state and federal environmental and other requirements, and review of

each purchaser’s operating permits, environmental compliance permits,

business licenses, insurance and certifications.

4.2. A summary of the audit results must be provided to MRC upon request and

DEQ may view the results at their offices upon request.

5. Bed Bug Management

Each Recycler shall implement and maintain a documented plan to identify and mitigate

bed bug infestation in the facility. Components of the plan shall, at minimum, address the

following provisions:

5.1. Document that all employees attended bed-bug identification and mitigation

training.

5.2. Post bed bug identification posters in prominent workplace locations to

encourage proactive identification and isolation of contaminated Mattresses.

5.3. Clearly identify how infested Mattresses will be isolated and either

decontaminated or disposed.

5.4. Track the number and if possible, source of contaminated Units.

Certificate of Recycling, Employment and Inventory

To: Mattress Recycling Council Oregon, LLC

From: [Name of Recycler]

Date: _____________________

Month Covered by This Certificate (the Month): _____________________

Number of Unprocessed Units in Inventory at the Close of the Month: __________________

I, [name of person signing the certificate], serving as [insert individual’s company title] of [Name

of Recycler] (Recycler), being duly authorized to provide this certificate on behalf of Recycler,

hereby certify to the Mattress Recycling Council Oregon, LLC under penalties of perjury that the

following statements are truthful and accurate:

1. The quantities and weights of Mattresses reported by Recycler in the electronic reporting

platform specified by MRC were recycled in strict compliance with the requirements of

Recycler’s contract with MRC and all applicable federal, State and local laws and

regulations,

2. The data reported by Recycler in the electronic reporting platform specified by MRC are

based on this company’s internal books and records and are to the best of my knowledge

accurate, and

3. Recycler’s inventory of unprocessed Mattresses (including both Program and Non-Program

Materials) as of the date of this certification, stored either at Recycler’s premises (including

Storage Containers and truck trailers on its premises) or with previously granted permission

by MRC, at off-premises locations under Recycler’s control, did not exceed a combined __

Units, and

4. At the close of the Month, Recycler employed _____ full-time workers (that is, working 30 or

more hours/week) and _____ part-time workers (that is, working fewer than 30 hours /week).

_________________________________________________________________

Authorized Signature

_________________________________________________________________

Print Name

_________________________________________________________________

Title

_________________________________________________________________

Date

Appendix D: Interested Collection Site Participants

In preparation for this Plan, MRC surveyed 225 collection opportunity locations across the

state. The following facilities responded to MRC as indicating interest and have not

entered into any contract with MRC. Upon Plan approval, MRC will take steps to secure

each facility’s participation as a site and issue a formal contract. No facility listed here is

obligated/guaranteed to become a site. MRC will keep DEQ informed as the collection

network is established.

TABLE 8: Interested Collection Site Participants

County

City

Facility Name

Baker

Baker City

Baker Sanitary Landfill

Benton

Corvallis

Coffin Butte Landfills

Clackamas

KB Recycling

Clackamas

Oregon City

Metro South Transfer Station

Clackamas

Sandy

Sandy Transfer Station

Clatsop

Astoria

Astoria Transfer Station

Columbia

St. Helens

Columbia County HHW & Transfer Station

Coos

Coos Bay

Beaver Hill Solid Waste Facility

Crook

Prineville

Crook County Landfill

Crook

Prineville

Prineville Disposal Reload Station

Deschutes

Bend

Deschutes County Transfer Station & Household Hazardous Waste Facility

Deschutes

Bend

Furnish Hope

Deschutes

La Pine

Southwest Transfer Station

Deschutes

Redmond

Negus Transfer Station

Deschutes

Sisters

Northwest (Fryrear) Transfer Station

Douglas

Camas Valley

Camas Valley Transfer Station

Hood River

Cascade Locks

Emerald Systems

Hood River

Hood River Recycling & Transfer Station + Tri-County HHW Collection

Facility

Jackson

Ashland

Valley View Transfer Station

Jackson

Medford

Rogue Transfer Station & MRF

Jackson

Medford

Southern Oregon Goodwill Industries

Jefferson

Madras

Box Canyon Transfer Station

Josephine

Grants Pass

Redwood Transfer Station

Klamath

Klamath Falls

Klamath Works, Inc.

Lane

Cottage Grove

Cottage Grove Transfer Station

Lane

Cottage Grove

St. Vincent de Paul Society of Lane County - Cottage Grove Store

Lane

Eugene

Glenwood Central Receiving Station

Lane

Eugene

St. Vincent de Paul Society of Lane County - Garfield Store

Lane

Florence

Florence Transfer Station

Lane

Junction City

St. Vincent de Paul Society of Lane County - Junction City Thrift Store

Lane

Oakridge

St. Vincent de Paul Society of Lane County - Oakridge Thrift Store

Lane

Springfield

St. Vincent de Paul Society of Lane County - Main Street Thrift Store

County

City

Facility Name

Lincoln

Lincoln City

Schooner Creek Private Transfer Station

Lincoln

Newport

Thompson's Transfer And Disposal Inc.

Lincoln

Toledo

Toledo Transfer Station

Lincoln

Waldport

South Lincoln Recycle & Transfer Station

Linn

Albany

St. Vincent de Paul Society of Lane County - Albany Thrift Store

Malheur

Ontario

Ontario Sanitary Service Transfer Station

Marion

Salem

St. Vincent de Paul Society of Lane County - Salem Thrift Store

Marion

Woodburn

Woodburn Recycle Center & Transfer Station - Republic Services

Morrow

Boardman

North Morrow County Transfer Station

Morrow

Lexington

South Morrow Transfer Station

Multnomah

Portland

Community Warehouse

Multnomah

Portland

Environmentally Conscious Recycling

Multnomah

Portland

Far West Recycling

Multnomah

Portland

Metro Central Transfer Station

Multnomah

Portland

Suttle Road Material Recovery Facility - Recology

Polk

Monmouth

Brandt's Sanitary Service

Tillamook

Manzanita

Manzanita Transfer Station

Tillamook

Pacific City

Pacific City Transfer Station

Tillamook

Tillamook Transfer Station

Umatilla

Milton-

Freewater

Milton-Freewater Recycling Center

Union

La Grande

Waste Pro Recovery Transfer Station

Wasco

The Dalles

The Dalles Transfer Station + Tri-County HHW Collection Facility

Washington

Forest Grove

Forest Grove Transfer Station

Washington

Hillsboro

Far West Recycling

Washington

Hillsboro

Tualatin Valley Waste Recovery

Washington

Sherwood

Pride Disposal

Washington

Tualatin

Community Warehouse

Washington

Wilsonville

Republic Services Wilsonville

Wheeler

Fossil

Fossil Solid Waste Transfer Station And Recycling Station

Yamhill

Newberg

Newberg Transfer And Recycling Center

Appendix E: Prospective Site Information Examples

MRC’s Resources Library contains additional items. The most relevant to the Program

were selected for this appendix.

Information Sheet: How to Become a Collection Site

Available online: https://mattressrecyclingcouncil.org/wp-content/uploads/2022/10/MRC-OR-Collection-Sites-Info-Sheet-

FINAL.pdf

Publicity Toolkits for Collection Sites and Collection Events

MRC’s publicity toolkits help a collector promote their site or event. The toolkits:

• Describe the on-site signage MRC offers and how to reorder.

• Explain how to request an update to locator and directory listings.

• Provide ready to use information for a collector to implement in a variety of

communications or marketing materials such as their website, social media,

newsletters or presentations.

• Include customizable templates for a press release and flyer.

• Describe how to work with MRC on a custom project such as a direct mail

campaign or local advertising.

• Include details about MRC’s outreach booth and where to send event sponsorship

proposals.

Per the Implementation Timeline, an Oregon version of the publicity toolkits will be

created in the months following Plan approval.

View or download these documents: MRC’s Publicity Toolkits

Appendix F: Budget

The Act requires that on or before October 1, 2023, and on or before July 1 annually

thereafter, MRC prepare and submit to DEQ a proposed mattress stewardship Program

operating budget that includes:

a) Anticipated revenues from the assessment collected on mattress sales

b) Costs of implementing the Program, including:

1. Collection, transportation and processing of program mattresses

2. Collection site compensation for reasonable actual costs to collect and

manage discarded mattresses

3. Administrative costs of the mattress stewardship Program

4. Annual fee to be paid to the Oregon DEQ pursuant to Section 9(3) of the

2022 Act

5. Anticipated unallocated reserve funds

The Act also provides that MRC will budget and report on a calendar year basis.

Pursuant to these provisions, MRC has calculated an assessment sufficient to cover the

Plan’s budgeted costs and to accumulate a reserve sufficient to operate the Program over

a multiyear period in a prudent and responsible manner.

MRC will review the budget monthly, comparing actuals to budget. Should the assessment

be insufficient or excessive to fund the Program, MRC will submit a Plan amendment

pursuant to Section 7 of the Act proposing a change to the mattress stewardship

assessment.

The Act requires that the budget cover revenue and costs for the first two years of Program

operations. The exact date on which the Program will launch and operations commence,

however, will depend in part on when the Plan is approved. For purposes of preparing the

budget, MRC has assumed a January 1, 2025 launch date. This budget covers (A) start-up

costs through 2024 and (B) full operations for calendar years 2025 and 2026.

Revenue

Funding for Program implementation and ongoing operations comes from a mattress

stewardship assessment collected at the point of sale (retail or otherwise). Retailers must

report the number of units sold each month and submit all assessments collected to MRC

by the end of the following month in which the sale occurred.

MRC is budgeting Program assessment revenue $9,225,270 for 2025 and $9,409,770 for

2026. In calculating revenue, MRC has used (A) a per unit assessment of $22.50, which

MRC has budgeted as the per unit amount needed to fund the Program over a multiyear

period in a prudent and responsible manner, and (B) an estimate of the number of units

that Oregon consumers will buy during the relevant calendar year. In estimating the number

of units that Oregon consumers will buy, MRC considered 2023 and Q1 2024 actuals in

other state mattress recycling programs and the ISPA Industry Forecast for 2025, and then

adjusted for Oregon’s population. The 2025 budgeted sales are expected to be 2.5% above

2024 projected levels and 2026 is expected to be 2% above 2025. Based on this

information, MRC estimates that revenue will be collected on 410,012 and 418,212 units for

2025 and 2026, respectively.

Based on these assumptions, MRC’s budgeted assessment revenue for 2025 to 2026 is

based on the following units sold in Oregon and a per unit assessment of $22.50:

TABLE 9: Revenue Calculation

Category

2025 Budget

2026 Budget

Total

Assessment Revenue

$9,225,270

$9,409,770

$18,635,040

Units Sold

410,012

418,212

828,224

Expenses

Operational Costs

Based on our experience operating other statewide mattress recycling programs and

factoring in Oregon’s population, MRC has estimated the number of units that recyclers will

process in 2025 and 2026 to be 374,402.

TABLE 10: Units Sold and Units Recycled

Units

2025 Budget

2026 Budget

Total

Number of Units Sold

410,012

418,212

828,224

Number of Units Recycled

164,097

210,305

374,402

Operational costs to recycle program mattresses include collection, transportation,

processing, efforts to mitigate illegal mattress dumping, various program studies (including

life cycle analysis, convenience, etc.), compliance audits, and field visits to collection sites,

recyclers, and transporters. Note that there will always be a differential between units sold

and units recycled. This is due to several factors including a significant time differential

between when a unit is purchased and discarded. During the usable life of a mattress, it is

common for consumers to pass a used mattress along to a friend or relative or sell them on

local marketplace sites like Craigslist, Facebook Marketplace or OfferUp. In 2022, MRC

conducted a study to estimate the average time between when units are manufactured and

then discarded through the program. That study concluded the average age for all

discarded units was 13.9 years.

TABLE 11: Operational Costs

Category

Start-Up Costs

2022-2024

2025 Budget

2026 Budget

Total

Collection

$ 0

$ 829,725

$ 1,033,214

$ 1,862,939

Transportation

$ 0

$ 1,255,342

$ 1,657,206

$ 2,912,548

Processing

$ 0

$ 2,591,355

$ 3,434,504

$ 6,025,859

Illegal Dump Mitigation

$ 0

$ 150,000

$ 300,000

Program Studies (Life Cycle,

Convenience, etc.)

$ 3,400

$ 130,000

$ 128,000

$ 261,400

Program Compliance Audits

$ 0

$ 10,000

$ 30,000

$ 40,000

Field Visits

$ 20,000

$ 13,700

$ 18,800

$ 52,500

Total Operational Costs

$ 23,400

$ 4,980,122

$ 6,451,724

$ 11,455,246

Collection

Collection costs are comprised of handling fees, container rental, mattress recycling

signage and collection site improvement funding. For the purposes of preparing this

budget, MRC estimates that approximately 75% of the units collected will be subject to a

handling fee paid to collection sites. MRC anticipates the costs of compensating collection

sites for their reasonable actual costs to manage discarded mattresses will $377,300 and

$456,515 in 2025 and 2026 respectively. The remaining 25% of the units are expected to

come directly from retailers, commercial volume sources and special community collection

events that will not incur handling fees.

Container rental costs are based on the estimated number and type of storage containers

needed to handle units from a variety of collectors. This budget includes an accelerated

timeline to contract with collection sites in the first year of the program. Subsequent years

will see more collection sites and growth from commercial volume sources. Therefore,

container costs increase each year. The collection facility improvement funding is

discussed further in Part 5 of this Plan.

TABLE 12: Collection Costs

Collection

2025 Budget

2026 Budget

Total

Collection Site Handling

Fees

$ 377,300

$ 456,515 $ 833,815

Collection Container and

Storage

$ 402,425

$ 526,699 $ 929,124

Mattress Collection Facility

Improvement Funding

$ 50,000

$ 50,000 $ 100,000

Total Collection Costs

$ 829,725

$ 1,033,214

$ 1,862,939

Transportation and Recycling

MRC uses third parties to transport mattresses from collection sites to recyclers for

processing units. Transport costs vary considerably depending on the transport distance,

geographic location of the collection site and the container type used to hold the discarded

mattresses. Transportation costs are affected by the number of units the container can

hold, the distance the transporter travels to the recycling facility and fuel costs.

Recycling costs, paid to third party contracted recyclers on a per unit basis, are for the

dismantling and processing of program mattresses. These costs are directly related to the

number of program mattresses collected.

Illegal Dump Mitigation

MRC has allocated funds to mitigate the costs of illegal dumping as discussed in Part 10 of

this Plan. This includes costs associated with meetings, community surveys, data collection

and pilot projects.

Program Studies

In future years, MRC is also required to conduct a life cycle analysis, report on the scope of

discarded mattresses that are not being collected as part of the Program and study

effective methods for providing discarded mattress collection services to low-income

individuals and multifamily housing structures. Costs for these studies will be incurred in

2025 and 2026. The budget also includes a convenience analysis study in 2025.

Program Compliance

Recycler performance audits and inspections for environmentally sound management

practices will be conducted annually for contracted recyclers as discussed in Part 7 of this

Plan. In 2026, the budget also includes $20,000 for a third party to perform a program

audit.

Field Visits

This budget includes staff travel expenses associated with regular meetings and

inspections of recyclers and collection sites.

Public Education, Advertising and Promotion

MRC’s comprehensive education and communication efforts targeting retailers, producers,

renovators and consumers is described in detail in Part 11 of this Plan. Oregon shares

costs for hosting and maintaining the consumer- and industry-facing websites

(ByeByeMattress.com, MattressRecyclingCouncil.org and MRCreporting.org) with our other

state recycling programs. Shared costs are based on each state’s population. In order to

achieve its objectives with the state, MRC’s marketing team will also prepare an annual

report in compliance with the Act. All of these activities through year-end 2026 are included

in the $640,771 budget listed below.

TABLE 13: Public Education, Advertising and Promotion Costs

Category

Start-Up Costs

2022-2024

2025

Budget

2026

Budget

Total

Advertising and

Consumer Education

$ 119,513

$ 142,260

$ 94,345

$ 356,118

Party PR Agencies

$ 2,965

$ 82,750

$ 168,465

Industry and

Stakeholder Outreach

$ 26,403

$ 16,990

$ 14,065

$ 57,458

Conferences and

Events

$ 4,650 $ 18,500

$ 20,580

$ 43,730

Annual Report

$ -

$ 15,000

Total Costs

$ 153,531

$ 260,500

$ 226,740

$ 640,771

DEQ Oversight Fees

The Act requires that MRC pay DEQ an annual fee that is reasonably calculated to cover

the costs to the department to administer, implement and enforce the Act. The budget

reflects the annual fee that MRC understands DEQ will charge MRC.

Program Administration Costs

MRC administration costs include management and administrative expenses, professional

services (e.g., financial audit), government relations, legal and other administrative

expenses required to manage the Program. Administration costs also include corporate

expenses incurred by MRC Inc. which are shared among other state mattress recycling

programs to provide general administrative support. At present, similar mattress recycling

programs operate in California, Connecticut, and Rhode Island. These expenses are

allocated to each state program based on its relative population. At the time of Plan

submission, Oregon represents 8.8% of the total population of the four states. That means

that for purposes of this budget, 8.8% of shared expenses have been allocated to the

Oregon Program. Total administration costs for the Program for the period 2025-2026 plus

start-up costs from 2022-2024 represent 15% of total Program costs.

Start-Up Costs

From 2022 to 2024, MRC incurred various start up expenses. These include legal

expenses incurred to form MRC, staff administrative costs and professional services

required to prepare this Plan and contact mattress sellers in Oregon (as well as to prepare

and review RFP’s for recycling and transportation services), travel and other necessary

expenses incurred to prepare to launch the Program. MRC funded these start-up expenses

by borrowing money from MRC Inc. MRC will incur additional start-up costs in 2024 until

the Program launches in 2025. In total, MRC anticipates borrowing $1.8 million. MRC has

budgeted $205,591 in interest expense on its loan and anticipates that the loan can be

repaid by the end of 2025.

TABLE 14: DEQ Oversight and MRC Administration Costs

Category

Start-Up Costs

2022-2024

2025

Budget

2026

Budget

Total

DEQ Government

Oversight Fees

$ 205,000

$ 200,000

$ 605,000

Program

Administration

Management and

Administrative

$ 426,290

$ 569,019

$ 631,456

$ 1,626,765

Annual Audit/Tax

Filings

$ -

$ 2,000

$ 25,000

$ 27,000

Industry and

Government

Relations

$ 150,000

$ 60,000

$ 270,000

Legal Expenses

$ 49,131

$ 51,000

$ 16,000

$ 116,131

Program Travel

$ 31,743

$ 7,000

$ 9,000

$ 47,743

Interest Expense

$ 104,364

$ 101,227

$ -

$ 205,591

Total

Administration

$ 761,528

$ 790,246

$ 741,456

$ 2,293,230

All costs for this Program, including the start-up costs, are shown in the following table:

TABLE 15: 2022-2026 Expenses

Category

Start-Up Costs

2022-2024

2025

Budget

2026

Budget

Total

Operational Costs

$ 23,400

$ 4,980,122

$ 6,451,724

$ 11,455,246

Public Education,

Advertising and Promotion

$ 153,531

$ 260,500

$ 226,740

$ 640,771

DEQ Oversight

$ 205,000

$ 200,000

$ 605,000

Program Administration

$ 761,528

$ 790,246

$ 741,456

$ 2,293,230

Total Program Costs

$ 1,143,459

$ 6,230,868

$ 7,619,920

$ 14,994,247

In 2025, the $22.50 assessment collected on each mattress or boxspring sold will include:

• $12.15 for Program operational costs

• $2.79 for start-up costs incurred prior to Program launch

• $1.93 for Program administration

$12.15

$15.43

$0.64

$0.54

$0.49

$0.48

$1.93

$1.77

$2.79

$4.51

$4.28

$0.00

$5.00

$10.00

$15.00

$20.00

$25.00

2025 Budget 2026 Budget

Allocation of $22.50 Assessment Fee

Operational Costs Public Education, Advertising and Promotion

Oregon Government Oversight Program Administration

Start-Up Costs Working Capital and Reserves

• $0.49 for DEQ Oversight

• $0.64 for public education and advertising

• $4.51 allocated to build MRC’s reserves and working capital

Once MRC repays the money it has borrowed to fund Program start-up costs, a larger

percentage of the collected assessment ($15.43) will cover Program operations in 2026

and MRC will continue to allocate funds to build reserves.

Calculating the Per Unit Assessment

Total budgeted expenses through 2026 (including start-up costs) are $14,994,247. We add

targeted reserve funding through December 31, 2026 of $1,755,019, as well as three

months working capital of $1,904,980 to cover short term cash flow requirements. From

this, we deduct budgeted investment revenue earned during the period of $19,206. That

leaves a total of $18,635,040 that must be funded by the per unit assessment. MRC

anticipates that during the period from January 1, 2025 through December 31, 2026,

Oregon consumers will buy 828,224 mattresses and foundations. Based on this

information, MRC calculates the per unit assessment of $22.50 by dividing the sum of total

costs, unallocated reserves and working capital (less investment revenue

) by total units

sold ($18,635,040 / 828,224 = $22.50). Any delay in the Program launch beyond January 1,

2025, will change expenses and the assessment calculation illustrated below:

TABLE 16: Per Unit Assessment Calculation

Stewardship Assessment

Total Expenses (A)

$ 14,994,247

Working Capital + Target Unallocated Reserve (B)

$ 3,659,999

Less Investment Income (C)

$ (19,206)

Amount to Cover (D = A + B - C)

$ 18,635,040

Projected Unit Sales 2025-2026 (E)

828,224

Per Unit Assessment (F = D/E)

$ 22.50

Unallocated Reserve Funds

As with the other states, the MRC Board has established a reserve policy that directs MRC

management to have sufficient operating cash to fund operations (e.g., cash on hand equal

to approximately three months of expenses), and a prudent level of unallocated reserves

(Board Designated Financial Reserve) that allows MRC to be prepared in case its

operational expenses increase or planned revenues decrease as a result of external

factors. The amount that MRC sets aside in this reserve is influenced by several factors.

First, the Program must be able to adjust to unforeseen circumstances that can have a

substantial impact on MRC’s expenses. These circumstances could include accidents and

natural disasters, or operational or financial disruptions. Significant or sudden changes in

market dynamics that affect costs (e.g., fuel) or failure of secondary markets for recycled

components, political uncertainties, or any combination of the above could also significantly

affect the Program and its budget. As an example, the COVID-19 pandemic and

subsequent inflation significantly disrupted budgets, eventually resulting in unpredicted cost

increases beyond MRC’s control.

MRC anticipates earning investment revenue on its unallocated reserves beginning 1st quarter of 2026.

Second, the reserve protects the long-term viability of the Program by setting aside money

that can fund budget deficits without necessitating frequent adjustments in the assessment.

Third, MRC’s ability to operate prudently over a multiyear period depends in part on MRC’s

forecasted operating and administrative expenses for several years into the future. For the

next few years, MRC expects to increase its expenditure as it continues to develop the

Program’s collection network and increase the number of units collected and recycled. This

growth will result in MRC’s annual expenses increasing in the future.

Finally, MRC must be prepared in case its revenue stream (that is, assessment collected

on the sale of mattresses) is significantly or suddenly disrupted. This could include a

downturn in the U.S. economy or mattress sales (as experienced recently) or other events

that are external to the Program itself, like legislative or regulatory initiatives that disrupt

sales.

For these reasons, MRC has budgeted to build a reasonable unallocated reserve of

$1,755,019 by December 2026. The unallocated reserves at the end of 2026 represents

23% (2.8 months) of annual Program expenses. MRC is committed to maintaining financial

stability and sustainability. To ensure this, MRC will continue to allocate funds to its

reserves annually. However, the total reserve amount will not exceed 75% of MRC's annual

expenses.

The details of the anticipated budget are as follows on the next page:

TABLE 17: Proposed Budget

Asse ssm e n t Fe e 22.50$

Start-Up Costs

2022-2024

2025 Budget 2026 Budget Total

Expense

Allocation

REVENUE:

Assessment Revenue -$ 9,225,270$ 9,409,770$ 18,635,040$

Total Revenue -$ 9,225,270$ 9,409,770$ 18,635,040$

EXPENSES:

Operational Costs

Collection

Collection Site Handling Fees -$ 377,300$ 456,515$ 833,815$

Collection Container and Storage Costs -$ 402,425$ 526,699$ 929,124$

Mattress Collection Facility Improvement Funding -$ 50,000$ 50,000$ 100,000$

Total Collection Costs -$ 829,725$ 1,033,214$ 1,862,939$

Transportation -$ 1,255,342$ 1,657,206$ 2,912,548$

Processing -$ 2,591,355$ 3,434,504$ 6,025,859$

Illegal Dump Mitigation -$ 150,000$ 150,000$ 300,000$

Program Studies (Life Cycle, Convenience, etc.) 3,400$ 130,000$ 128,000$ 261,400$

Program Compliance Audits -$ 10,000$ 30,000$ 40,000$

Field Visits 20,000$ 13,700$ 18,800$ 52,500$

Total Operational Costs 23,400$ 4,980,122$ 6,451,724$ 11,455,246$ 76.4%

Public Education, Advertising, and Promotion

Public Education and Advertising 148,881$ 242,000$ 191,160$ 582,041$

Conferences and Events 4,650$ 18,500$ 20,580$ 43,730$

Annual Report -$ -$ 15,000$ 15,000$

Total Public Education, Advertising, and Promotion 153,531$ 260,500$ 226,740$ 640,771$ 4.3%

Oregon Government Oversight Fees 205,000$ 200,000$ 200,000$ 605,000$ 4.0%

Program Administration

Management and Administrative Expenses 426,290$ 569,019$ 631,456$ 1,626,765$

Annual Financial Audit and Tax Filings -$ 2,000$ 25,000$ 27,000$

Industry and Government Relations 150,000$ 60,000$ 60,000$ 270,000$

Legal Expenses 49,131$ 51,000$ 16,000$ 116,131$

Field Visits and Program Travel 31,743$ 7,000$ 9,000$ 47,743$

Interest Expense 104,364$ 101,227$ -$ 205,591$

Total Administration 761,528$ 790,246$ 741,456$ 2,293,230$ 15.3%

Total Expenses 1,143,459$ 6,230,868$ 7,619,920$ 14,994,247$ 100.0%

Net Operating Assets (1,143,459)$ 2,994,402$ 1,789,850$ 3,640,793$

Net Investment Return -$ -$ 19,206$ 19,206$

Ne t Asse ts (1,143,459)$ 2,994,402$ 1,809,056$ 3,659,999$

Cumulative Net Assets (1,143,459)$ 1,850,943$ 3,659,999$

Reserve Funds

Board Designated Financial Reserve (Unallocated Reserves)

293,226$ 1,755,019$

Reserves as a % of Annual Operating Budget 0.0% 4.7% 23.0%

Undesignated Net Assets (Working Capital) -$ 1,557,717$ 1,904,980$

25% (3 months) of Annual Operating Budget 0.0% 25.0% 25.0%

Mattress Recycling Council Oregon LLC