I don't know .... their system seems to be a work in progress. If you look at the first and second paragraphs from the RECYCLER.pdf link they seem to contradict one another.
A small timer might be able to get a variance as long as they limited themselves to dismantling and shipped their boards to a R2 certified buyer. That ... and file yearly reports on the amount & type of material they are processing.
It wouldn't do any harm to contact the regulating state agency and ask for more information.
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