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Report to Congressional Requesters: 

November 2005: 

Electronic Waste: 

Strengthening the Role of the Federal Government in Encouraging 
Recycling and Reuse: 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-47] 

GAO Highlights: 

Highlights of GAO-06-47, a report to congressional requesters: 

Why GAO Did This Study: 

Advances in technology have led to rapidly increasing sales of new 
electronic devices. With this increase comes the dilemma of managing 
these products at the end of their useful lives. Some research suggests 
that the disposal of used electronics could cause a number of 
environmental problems. Research also suggests that such problems are 
often exacerbated by the export of used electronics to countries 
without protective environmental regulations. 

Given that millions of used electronics become obsolete each year with 
only a fraction of them being recycled, GAO was asked to (1) summarize 
information on the volumes of, and problems associated with, used 
electronics; (2) examine the factors affecting their recycling and 
reuse; and (3) examine federal efforts to encourage recycling and reuse 
of these products. 

What GAO Found: 

Available estimates suggest that over 100 million computers, monitors, 
and televisions become obsolete each year, and this number is growing. 
If improperly managed, these used electronics can harm the environment 
and human health. Available data suggest that most used electronics are 
probably stored in garages, attics, or warehouses, with the potential 
to be recycled, reused, or disposed of in landfills, either in the 
United States or overseas. If disposed of in landfills, valuable 
resources, such as copper, gold, and aluminum, are lost for future use. 
Additionally, some research shows that toxic substances with known 
adverse health effects, such as lead, have the potential to leach from 
discarded electronics in landfills. Although one study suggests that 
this leaching does not occur in modern U.S. landfills, it appears that 
many used electronics are exported to countries without modern 
landfills or with regulations less protective of human health and the 
environment. 

Economic factors inhibit the recycling and reuse of used electronics. 
Consumers generally have to pay fees and drop off their used 
electronics at often inconvenient locations to have them recycled or 
refurbished for reuse. Recyclers and refurbishers charge these fees 
because their costs exceed the revenue they receive from selling 
recycled commodities or refurbishing units. In addition to these 
economic factors, federal regulatory requirements provide little 
incentive for environmentally preferable management of used 
electronics. First, the governing statute, the Resource Conservation 
and Recovery Act, allows individuals and households to dispose of 
hazardous waste, including many used electronics, in landfills. Second, 
federal regulations do not provide a financing system to overcome the 
economic factors deterring recycling and reuse. Third, federal 
regulations do not prevent the exportation of used electronics to 
countries where disassembly takes place at far lower cost, but where 
disassembly practices may threaten human health and the environment. In 
the absence of federal actions to address these concerns, an emerging 
patchwork of state requirements to encourage recycling and reuse may 
place a substantial burden on manufacturers, retailers, and recyclers, 
who incur additional costs and face an uncertain regulatory landscape 
as a result. 

In response to these challenges, EPA has spent about $2 million on 
several promising programs to encourage recycling and reuse of used 
electronics. Participation in one program—the Federal Electronics 
Challenge—has already led the Bonneville Power Administration to 
substantial cost savings through the procurement of environmentally 
friendly and energy efficient electronic products. To date, however, 
federal participation in this and other EPA electronics recycling 
programs has been minimal because—unlike other successful federal 
procurement programs (such as EPA’s and the Department of Energy’s 
Energy Star program)—participation is not required. 

What GAO Recommends: 

GAO recommends that EPA strengthen the federal role in encouraging 
recycling and reuse of used electronics by (1) proposing options to the 
Congress for overcoming the factors deterring recycling and reuse, (2) 
promoting wider federal agency participation in promising EPA programs, 
and (3) taking steps to ensure safe handling of these products if 
exported. EPA agreed with most of GAO’s findings, but disagreed with 
the first and second recommendations. 

www.gao.gov/cgi-bin/getrpt?GAO-06-47.

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact John Stephenson at (202) 
512-3841 or Stephensonj@gao.gov.

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Growing Volume of Used Electronics May Pose Environmental and Health 
Problems If Not Managed Properly: 

Cost and Regulatory Factors Deter Recycling and Reuse of Used 
Electronics: 

Federal Efforts to Increase Recycling and Reuse of Used Electronics Can 
Be Strengthened: 

Conclusions: 

Recommendations: 

Agency Comments and Our Evaluation: 

Appendixes: 

Appendix I: Scope and Methodology: 

Appendix II: Survey of Selected Stakeholders on Recycling Used 
Electronics: 

Appendix III: Comments from the Environmental Protection Agency: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Figure: 

Figure 1: A Woman in Guiyu, China, Disassembling a CRT Monitor: 

Abbreviations: 

ARF: advanced recycling fee: 

BPA: Bonneville Power Administration: 

CRT: cathode ray tube: 

DOE: Department of Energy: 

EPA: Environmental Protection Agency: 

EPEAT: Electronic Product Environmental Assessment Tool: 

EPR: extended producer responsibility: 

EU: European Union: 

FEC: Federal Electronics Challenge: 

NEPSI: National Electronic Product Stewardship Initiative: 

RCRA: Resource Conservation and Recovery Act: 

Letter November 10, 2005: 

The Honorable James M. Jeffords: 
Ranking Minority Member: 
Committee on Environment and Public Works: 
United States Senate: 

The Honorable John Thune: 
Chairman: 
Subcommittee on Superfund and Waste Management: 
Committee on Environment and Public Works: 
United States Senate: 

The Honorable Barbara Boxer: 
Ranking Minority Member: 
Subcommittee on Superfund and Waste Management: 
Committee on Environment and Public Works: 
United States Senate: 

The Honorable Lincoln Chafee: 
The Honorable Olympia Snowe: 
The Honorable James Talent: 
The Honorable Ron Wyden: 
United States Senate: 

Rapid advances in technology have led to increasing sales of new 
electronic devices, particularly televisions, computers, and computer 
monitors. Approximately 62 percent of U.S. households had computers in 
2003, compared with only 37 percent just 6 years earlier. With this 
increase comes the dilemma of how to manage these products when they 
reach the end of their useful lives. The National Safety Council 
forecast that in 2003 alone, about 70 million existing computers became 
obsolete, but it also forecast that only 7 million were recycled. 

Disposal of used electronics poses a number of potential environmental 
problems.[Footnote 1] For example, concerns have been raised because 
toxic substances such as lead, which have well-documented adverse 
health effects, can potentially leach from these products, especially 
if disposed improperly. Concerns have also been raised over used 
electronics that are exported from the United States to countries with 
less stringent environmental regulations because disposal in these 
countries can more easily have adverse environmental and human health 
effects. In addition to toxic substances, computers contain precious 
metals, such as gold, silver, and platinum, which require substantial 
amounts of energy and land to extract. These metals can often be 
extracted with less environmental impact from used electronics than 
from the environment. The U.S. Geological Survey, for instance, reports 
that 1 metric ton of computer scrap contains more gold than 17 tons of 
ore and much lower levels of harmful elements common to ores, such as 
arsenic, mercury, and sulfur. 

Under the Resource Conservation and Recovery Act (RCRA), the 
Environmental Protection Agency's (EPA) Office of Solid Waste provides 
regulatory oversight of the disposal of certain hazardous used 
electronic products. The office tightly regulates hazardous waste from 
generation to disposal; but also under RCRA, for other solid wastes, it 
promotes waste reduction, recycling, and responsible disposal through 
national voluntary and educational programs. Individual states must 
meet minimum national standards for the management of municipal solid 
waste in landfills, but they operate their own waste management 
programs, develop their own recycling and reuse programs, and are free 
to implement more stringent waste management policies. 

Given the growing number of computers and other electronic products 
becoming obsolete, you asked that we (1) summarize existing information 
on the volumes of, and problems associated with, used electronics; (2) 
examine the factors affecting the nation's ability to recycle and reuse 
these products; and (3) examine federal efforts to encourage recycling 
and reuse of used electronics and determine what, if anything, can be 
done to improve them. 

To address these issues, we reviewed scientific studies and reports 
conducted by government agencies, nonprofits, trade organizations, and 
academics. We also interviewed federal, state, local, nonprofit, and 
industry officials, as well as academic and research organization 
experts. For studies that we cite in this report, we reviewed their 
methodology, assumptions, limitations, and conclusions to ensure that 
we properly represented the validity and reliability of their results 
and conclusions. To examine the factors that affect the nation's 
ability to recycle and reuse used electronics, we examined current 
federal laws, regulations, and guidance regarding solid and hazardous 
waste disposal as they relate to the disposal of used electronics. We 
also reviewed pertinent state and local laws, regulations, and 
guidance. In particular, we reviewed the electronic waste legislation 
passed in California, Maine, Maryland, Massachusetts, and Minnesota. We 
visited states and localities that have implemented programs or passed 
legislation to responsibly manage used electronics, including 
California, Maine, Massachusetts, Oregon, and Washington. Further, we 
examined EPA-sponsored federal, state, and local pilot programs that 
attempt to encourage recycling of electronic products. In addition, to 
obtain the views of informed stakeholders regarding the factors that 
affect the nation's ability to recycle and reuse used electronics, we 
conducted a survey of participants in the National Electronics Product 
Stewardship Initiative (NEPSI) and other key stakeholders. We received 
42 responses from our survey population of 49. For additional 
information on our scope and methodology, see appendix I. Our work was 
conducted in accordance with generally accepted government auditing 
standards, which include an assessment of data reliability and internal 
controls. 

Results in Brief: 

Available research suggests that the volume of used electronics is 
large and growing and, if improperly managed, can harm the environment 
and human health. While data and research are limited, some data 
suggest that over 100 million computers, monitors, and televisions 
become obsolete each year and that this amount is growing. These 
obsolete products can be recycled, reused, disposed of in landfills, or 
stored by users in places such as basements, garages, and company 
warehouses. Data we reviewed suggest that most used electronics are 
probably stored, and therefore have the potential to be recycled or 
reused, disposed of in landfills, or exported overseas. If ultimately 
disposed in landfills, either in the United States or overseas, 
valuable resources, such as copper, gold, and aluminum, are lost for 
future use. In addition to concerns over losing valuable resources, 
some research shows that certain toxic substances with known adverse 
health effects, such as lead, have the potential to leach into 
landfills. Although one study suggests that leaching is not a concern 
in modern U.S. landfills, it appears that many of these products end up 
in countries without modern landfills or environmental regulations 
comparable to those in the United States. Finally, even with 
uncertainty surrounding the risks associated with toxic substances in 
used electronics, EPA has identified a number of these substances as 
priority toxic chemicals for reduction because they do not break down 
when released into the environment and can be dangerous even in small 
quantities. 

Despite the large volume of used electronics and the valuable resources 
contained within them, economic and regulatory factors discourage these 
products' recycling and reuse. Specifically: 

* Consumers generally have to pay fees and drop off their used 
electronics at often inconvenient locations to have them recycled or 
refurbished for reuse. Consumers in Snohomish County, Washington, for 
instance, may have to travel more than an hour to the nearest drop-off 
location, which then charges between $10 and $27 per unit, depending on 
the type and size of the product. Consumers in the Portland, Oregon 
area pay one local recycler 50 cents per pound to have their used 
computers recycled, which is about $28 for an average-sized desktop 
computer. Recyclers and refurbishers charge these fees because costs 
associated with recycling and refurbishing outweigh the revenue 
received from recycled commodities or refurbished units. This point was 
underscored by the International Association of Electronics Recyclers, 
which reported that the value of commodities recovered from computer 
equipment (such as shredded plastic, copper, and aluminum) is only 
between $1.50 and $2.00 per unit. It was further underscored by our 
interviews with eight electronics recyclers, who were unanimous in 
emphasizing that they could not cover costs without charging fees. 

* Federal regulatory requirements also provide little incentive for 
environmentally preferable management of used electronics. First, some 
used electronics are considered hazardous waste under RCRA, and RCRA 
bars entities that generate more than 220 pounds per month of hazardous 
waste (including some used electronics) from depositing it in 
landfills. However, RCRA does not bar households and entities that 
generate less than 220 pounds of hazardous waste per month from this 
practice. Consequently, since only four states currently ban disposal 
of used electronics in landfills, most consumers in the remaining 46 
states (and the District of Columbia) are allowed to do so--and have 
little incentive to do otherwise. Not surprisingly, data we reviewed 
suggest that states and localities without landfill bans have 
dramatically lower levels of recycling than the four states that have 
enacted landfill bans. Second, federal law does not provide a financing 
system to recycle used electronics. Absent a consistent financing 
system to make recycling less costly and more convenient for consumers, 
a patchwork of potentially conflicting state requirements is emerging 
that may ultimately place a substantial burden on recyclers, retailers, 
and manufacturers. The lack of a national financing mechanism has also 
led to an array of legislative proposals that take very different 
approaches to address the problem. Third, federal regulations do not 
provide adequate oversight of these products when exported. This is a 
particular problem in the case of some developing countries, where 
risks to the environment and human health may be more likely because 
less stringent environmental regulations often do not ensure that 
exported used electronics--supposedly destined for reuse--are not 
instead being disposed of improperly. Together, these factors hinder 
EPA's ability to reach its stated goal that within 10 years, it will be 
as convenient for consumers to take a discarded television or computer 
for recycling or reuse as it is to purchase a new product. 

EPA has spent about $2 million on several voluntary programs to help 
overcome some of the factors discouraging recycling and reuse of used 
electronics. For example, the "Plug-In To eCycling" campaign sponsors 
partnerships with industry and state and local governments to make 
recycling used electronics less expensive and more convenient for 
consumers. In 2004, Plug-In To eCycling sponsored four pilot projects 
involving collection events at retailers such as Best Buy, Good Guys, 
Office Depot, and Staples, in which over 11 million pounds of used 
electronics were collected. Another program--the Federal Electronics 
Challenge--leverages U.S. government purchasing power to promote 
environmentally preferable management of used electronics throughout 
their life cycle: procurement, operation and maintenance, and end-of-
life management. Through its participation in this program, the 
Bonneville Power Administration has already documented cost savings 
associated with longer life spans for the agency's computers and 
through purchases of computer monitors that contain less toxic 
substances and are therefore cheaper to recycle. To date, however, only 
61 out of thousands of federal facilities participate in the Federal 
Electronics Challenge. A major reason for the limited federal 
participation in this and other EPA electronics recycling programs is 
that, unlike other successful federal procurement programs (such as 
EPA's and the Department of Energy's Energy Star program), 
participation is not required. 

We are recommending that the Administrator of EPA develop a legislative 
proposal that addresses some of the economic and regulatory factors 
discouraging recycling and reuse of used electronics. In addition, we 
are recommending that the agency take several administrative steps to 
(1) increase federal agency participation in promising EPA electronics 
recycling programs and (2) help ensure that used electronics exported 
overseas are destined for reuse, as intended, and not disposed of 
improperly. 

In responding to a draft of this report, EPA generally agreed with our 
findings but disagreed with our recommendations that it develop a 
legislative proposal, and that it take additional steps to engender 
wider federal agency participation in promising EPA electronics 
recycling programs. Regarding the first of these two recommendations, 
EPA commented that it does not believe it is appropriate for the agency 
to propose options for a nationwide financing system to overcome the 
barriers to recycling and reuse because there is no consensus among 
manufacturers as to the optimal solution. We disagree that this lack of 
consensus provides a compelling reason for EPA to abstain from acting 
because there are ample precedents for EPA's involvement in addressing 
complex financing issues affecting solutions to key environmental 
problems. Furthermore, our survey results show that there is 
overwhelming agreement that legislation will be needed to deal with 
used electronics and a national financing system must be a part of it. 

In commenting on the recommendation to engender wider federal agency 
participation in its electronics recycling programs, EPA disagreed with 
our view that participation in the Federal Electronics Challenge is 
limited, noting that the 12 federal agencies participating in the 
program to date "represent over 80 percent of the Information 
Technology purchasing in the government." The figure, however, 
overstates federal agency adherence to the goals of the program. 
Participation simply means these agencies have identified their current 
practices for managing electronic products and set goals to improve 
them. However, the participating agencies and facilities are not 
required to meet their goals. As a practical matter, 61 out of 
thousands of federal facilities participate in the program, and only 5 
of these are meeting electronic product management criteria that the 
program's steering committee has asked them to attain. We continue to 
believe this track record falls short of EPA's own goal that the 
federal government "lead by example" in promoting recycling, reducing 
the use of toxic chemicals, and conserving energy and materials in its 
lifecycle management of electronic products. 

Background: 

Few people are aware of recycling options for their old televisions and 
personal computers. Because of the perceived value of used electronics, 
some pass their used equipment to family members or friends before 
eventually storing these units in their attics, basements, or garages. 
Eventually, though, consumers need to dispose of these units in some 
manner. By choosing to have these products recycled, consumers ensure 
the recovery of resources like copper, iron, aluminum, and gold, which 
would otherwise be procured through less environmentally friendly 
practices such as mining. Likewise, consumers who choose to recycle 
also reduce the amount of waste entering the nation's landfills and 
incinerators. Since used electronics typically contain toxic substances 
like lead, mercury, and cadmium, recycling or refurbishing will prevent 
or delay such toxic substances from entering landfills. 

The Congress affirmed its commitment to reducing waste and encouraging 
recycling, first through enactment of the Resource Conservation and 
Recovery Act (RCRA) of 1976, and then again with passage of the 
Pollution Prevention Act of 1990. Both RCRA and the Pollution 
Prevention Act address alternatives to waste disposal. RCRA promotes 
the use of resource recovery, either through facilities that convert 
waste to energy or through recycling. To promote recycling, RCRA 
required EPA to develop guidelines for identifying products that are or 
can be produced with recovered materials. RCRA also required federal 
agencies to procure items that are, to the maximum extent practicable, 
produced with recovered materials. 

The Pollution Prevention Act provided that pollution that cannot be 
prevented should be recycled or treated in a safe manner, and disposal 
or other releases should be used only as a last resort. The act 
specified that pollution prevention can include such practices as 
modifying equipment, technology, and processes; redesigning products; 
and substituting less-toxic raw materials. Executive Order 13101, 
issued September 14, 1998, also affirmed the federal government's 
commitment to encourage recycling by directing federal agencies to 
consider procuring products that, among other things, use recovered 
materials, can be reused, facilitate recycling, and include fewer toxic 
substances. The Federal Environmental Executive, who is appointed by 
and reports to the President, is responsible for recommending 
initiatives for government-wide procurement preference programs for 
environmentally preferable products. 

EPA's Office of Solid Waste regulates hazardous waste and nonhazardous 
waste, including discarded used electronics, under RCRA. RCRA 
established explicit hazardous waste management requirements overseen 
by the Office of Solid Waste, but for nonhazardous waste management, 
also under RCRA, the Office's policies rely heavily on national 
voluntary and education programs for waste reduction that emphasize 
materials recycling and reuse, toxic chemical reduction, and resource 
conservation.[Footnote 2] Several of these voluntary programs are 
tailored specifically for environmentally preferable management of used 
electronics. The Office of Solid Waste also collaborates with EPA's 
Office of Pollution Prevention and Toxics to conserve valuable 
resources and reduce wastes--particularly toxic wastes--before they are 
generated. These efforts are administered under the Resource 
Conservation Challenge, which is an institutional strategy combining 
the strengths of the two offices to ultimately minimize waste and toxic 
substances and conserve energy and resources. According to EPA, the 
overarching goal of the Resource Conservation Challenge is to move the 
nation from a waste-oriented to a life-cycle management way of thinking 
about resources. 

Growing Volume of Used Electronics May Pose Environmental and Health 
Problems If Not Managed Properly: 

The information we reviewed suggests strongly that the volume of used 
electronics is large and growing. For example, in a 1999 study, the 
National Safety Council forecast that almost 100 million computers and 
monitors (70 million of which would be computers) would become obsolete 
in 2003--a three-fold increase over the 33 million obsolete computers 
and monitors in 1997.[Footnote 3] Additionally, a 2003 International 
Association of Electronics Recyclers report estimated that 20 million 
televisions become obsolete each year--a number that is expected to 
increase as cathode ray tube (CRT) technology[Footnote 4] is replaced 
by new technologies such as plasma screens.[Footnote 5] 

Thus far, it appears that relatively few used electronics have found 
their way into either landfills or recycling centers. Available EPA 
data indicate that less than 4 million monitors and 8 million 
televisions are disposed of annually in U.S. landfills--only a fraction 
of the amount estimated to become obsolete annually, according to 
EPA.[Footnote 6] Additionally, the 1999 National Safety Council report 
forecast that only 19 million computers, monitors, and televisions 
would be recycled in 2005. Hence, the gap between the enormous quantity 
of used electronics that are obsolete (or becoming obsolete), and the 
quantity either in landfills or sent to recycling centers, suggests 
that most are still in storage--such as attics, basements, and garages, 
and that their ultimate fate is still uncertain--or have been exported 
for recycling and reuse overseas. 

Conventional disposal of used electronics in landfills raises two 
primary concerns, according to research we reviewed: the loss of 
natural resources and the potential release of toxic substances in the 
environment. By disposing of these products in landfills or 
incinerators, valuable resources are lost for future use. For example, 
computers typically contain precious metals, such as gold, silver, 
palladium, and platinum, as well as other useful metals like aluminum 
and copper. The U.S. Geological Survey reports that one metric ton of 
computer circuit boards contains between 40 and 800 times the 
concentration of gold contained in gold ore and 30 to 40 times the 
concentration of copper, while containing much lower levels of harmful 
elements common to ores, such as arsenic, mercury, and sulfur.[Footnote 
7] The research we reviewed also suggests that the energy saved by 
recycling and reusing used electronics is significant. The author of 
one report by the United Nations University states that perhaps as much 
as 80 percent of the energy used in the life cycle of a computer, which 
includes manufacturing, can be saved through refurbishment and reuse 
instead of producing a new unit from raw materials.[Footnote 8] 

Regarding the issue of toxicity, the research we reviewed is unclear on 
the extent to which toxic substances may leach from used electronics in 
landfills. According to a standard regulatory test RCRA requires to 
determine whether a solid waste is subject to federal hazardous waste 
regulations, lead (a substance with known adverse health affects) 
leaches from some used electronics under laboratory conditions. Some 
tests conducted at the University of Florida indicate that lead 
leachate from color computer monitors and televisions with CRTs exceeds 
the regulatory limit and, as a result could, according to EPA, be 
considered hazardous waste under RCRA.[Footnote 9] On the other hand, 
the author of this study told us that these findings are not 
necessarily predictive of what could occur in a modern landfill. A 
report by the Solid Waste Association of North America also suggests 
that while the amount of lead from used electronics appears to be 
increasing in municipal solid waste landfills, these landfills provide 
safe management of used electronics without exceeding toxicity limits 
that have been established to protect human health and the 
environment.[Footnote 10] 

Nonetheless, regardless of uncertainty surrounding the environmental 
risks associated with toxic substances commonly found in used 
electronics, EPA has identified lead, mercury, and cadmium (which are 
typically found in computers or monitors), as priority toxic chemicals 
for reduction under the agency's Resource Conservation Challenge. 
According to EPA, these toxic substances do not break down when 
released into the environment and can be dangerous, even in small 
quantities. 

Cost and Regulatory Factors Deter Recycling and Reuse of Used 
Electronics: 

The costs associated with recycling and reuse, along with limited 
regulatory requirements or incentives, discourage environmentally 
preferable management of used electronics. Generally, consumers have to 
pay fees and take their used electronics to locations that are often 
inconvenient to have them recycled or refurbished for reuse. Recyclers 
and refurbishers charge fees to cover the costs of their operations. In 
most states, consumers have an easier and cheaper alternative--they can 
take them to the local landfill. This easy and inexpensive alternative 
helps, in part, explain why so little recycling of used electronics has 
thus far taken place in the United States. Moreover, this economic 
reality, together with federal regulations that do little to preclude 
disposal of used electronics along with other wastes, have led a 
growing number of states to enact their own laws to encourage 
environmentally preferable management of these products. 

Cost and Consumer Inconvenience Discourage Recycling and Reuse of Used 
Electronics: 

Consumers who seek to recycle or donate their used electronics for 
reuse generally pay a fee and face inconvenient drop-off locations. 
Unlike their efforts for other solid waste management and recycling 
programs, most local governments do not provide curbside collection for 
recycling of used electronics because it is too expensive. Instead, 
some localities offer used electronics collection services, for a fee, 
at local waste transfer stations. These localities send consumers' used 
electronics to recyclers for processing.[Footnote 11] For example, 
transfer stations in Snohomish County, Washington, charge consumers 
between $10 and $27 per unit for collecting and transporting used 
electronics to recyclers and, ultimately, paying the recycler to 
responsibly handle the products. 

Moreover, such transfer stations are generally not conveniently 
located, and rural residents, such as those in parts of Snohomish 
County, may need to drive more than an hour to get to the nearest drop-
off station. Our survey respondents recognize this challenge for the 
recycling infrastructure--over 70 percent believe that existing 
collection options for recycling used electronics are inconvenient for 
households. However, in some localities, consumers can also take their 
used electronics directly to a recycler, where they are typically 
charged a fee. In the Portland, Oregon area, for instance, one recycler 
charges consumers 50 cents per pound to recycle computers, monitors, 
and televisions, which means it costs consumers about $28 to recycle an 
average-sized desktop computer system. 

Recyclers charge these fees to cover the costs they incur when 
disassembling used electronics, processing the components, and refining 
the commodities for resale. As noted in a 2003 report by the 
International Association of Electronics Recyclers, most recyclers and 
refurbishers in the United States cannot recoup their expenses from the 
resale of recycled commodities or refurbished units. The report, which 
compiled data from more than 60 recyclers in North America, stated that 
the costs associated with recycling are greater than the revenue 
received from reselling recycled commodities and that fees are needed 
to cover the difference. Furthermore, the report states that the value 
of commodities recovered from computer equipment, such as shredded 
plastic, copper, and aluminum, is only between $1.50 and $2.00 per 
unit. This point is further underscored by our interviews with eight 
electronics recyclers, who were unanimous in emphasizing that they 
could not cover costs without charging fees. 

The costs associated with recycling make it unprofitable (without 
charging fees) for several reasons. First, recycling used electronics 
is labor intensive--the equipment must be separated into its component 
parts, including the plastic housing, copper wires, metals (e.g., gold, 
silver, and aluminum), and circuit boards, as well as parts that can be 
easily reused or resold, like hard drives and CD-ROM drives. Officials 
with Noranda Recycling Inc., which recycles used electronics for 
Hewlett-Packard, told us that over 50 percent of their total costs for 
recycling are labor costs involved in disassembly, even though they 
operate some of the most technologically advanced equipment available. 
Labor costs are high, in part, because electronic products are not 
always designed to facilitate recycling at end of life. For instance, a 
Hewlett-Packard official told us 30 different screws must be removed to 
take out one lithium battery when disassembling a Hewlett-Packard 
computer for recycling. According to this official, if Hewlett-Packard 
spent $1 in added design costs to reduce the number of different screws 
in each computer, it would save Noranda approximately $4 in its 
disassembly costs.[Footnote 12] A substantial majority of respondents 
to our survey agreed that the complexities of taking apart used 
electronics is a major hindrance that impedes the recycling of these 
products--over 60 percent said that recycling is discouraged because of 
the difficulty of disassembly.[Footnote 13] 

Second, to obtain sellable commodities, the resulting metal and plastic 
"scrap" must be further processed to obtain shredded plastic, aluminum, 
copper, gold, and other recyclable materials. Processing in this 
fashion typically involves multimillion-dollar machinery. According to 
officials with one international electronics recycling company, 
processing costs are high, in part, because this sophisticated and 
expensive machinery is being used to process the relatively limited 
supply of used electronics being recycled in the United States. Company 
officials noted that, by contrast, in some European countries where 
manufacturers are required to take financial responsibility for 
recycling their products, the increased supply of recyclable 
electronics has decreased the company's per-unit processing costs and 
increased the net revenue associated with recycling used electronics. 

Finally, recyclers incur additional expenses when handling and 
disposing of toxic components (such as batteries) and toxic substances 
(such as lead), which are commonly found in used electronics. These 
expenses include removing the toxic components and substances from the 
product, as well as handling and processing them as hazardous 
material.[Footnote 14] Once separated from the product, these wastes 
may be regulated as hazardous wastes and, thus, subject to more 
stringent RCRA requirements governing their transportation, storage, 
and disposal. CRTs from computer monitors and televisions are 
particularly expensive to dispose of because they contain large volumes 
of leaded glass, which must be handled and disposed of as a hazardous 
waste. Some recyclers, for example, send their CRT glass to a lead 
smelter in Missouri that charges 6.5 cents per pound. A study on the 
economics of recycling personal computers found that the cost 
associated with disposing of CRT monitors substantially reduces a 
recycler's net revenue.[Footnote 15] 

Refurbishers charge similar fees to cover the costs involved in 
guaranteeing data security by "wiping" hard drives, upgrading systems, 
installing software, and testing equipment. A program manager for a 
nonprofit technology assistance provider told us that it generally 
costs about $100 to refurbish a Pentium III computer system, plus an 
additional licensing fee of about $80 for an operating system. 

To help minimize the cost and inconvenience of recycling used 
electronics, Office Depot and Hewlett-Packard partnered to provide free 
take-back of used electronics at Office Depot retail stores in 2004. 
Office Depot collected used electronics at their retail stores, and 
then sent them to Hewlett-Packard facilities for recycling. Over a 3-
month period, nearly 215,000 computers, monitors, and televisions were 
collected and recycled. EPA officials told us that the pilot program 
showed the extent to which recycling can be encouraged by making it 
inexpensive and convenient to the consumer. 

Federal Regulatory Framework Governing Used Electronics Provides Little 
Incentive for Recycling or Reuse: 

The lack of economic incentives promoting recycling and reuse of 
electronics is compounded by the absence of federal provisions that 
either encourage recycling, or preclude their disposal in landfills. 
Specifically, current federal laws and regulations (1) allow hazardous 
used electronics in municipal landfills, (2) do not provide for a 
financing system to support recycling, and (3) do not preclude 
electronic products generated in the United States from being exported 
and subsequently threatening human health and the environment overseas. 

Hazardous Used Electronics Are Allowed in Municipal Landfills: 

Regulation at the federal level of used electronics identified as 
hazardous waste and disposed in landfills falls under RCRA Subtitle C, 
which was established to ensure that hazardous waste is managed in a 
manner that is protective of human health and the environment. Many 
computer monitors and televisions are considered hazardous waste under 
RCRA, and some materials from circuit boards might be hazardous waste 
as well. Federal regulations bar entities that generate more than 220 
pounds of hazardous waste per month from sending hazardous waste to 
municipal solid waste landfills. However, households and entities that 
generate more than 220 pounds of hazardous waste per month are exempt 
from many RCRA regulations, thus allowing them to deposit their used 
electronics in municipal solid waste landfills--even though CRTs in 
computer monitors and televisions, and potentially circuit boards in 
computers, exhibit characteristics of hazardous waste. EPA's Office of 
Solid Waste regulates hazardous waste under RCRA, but its regulations 
do not require households and other entities that generate small 
quantities of hazardous waste to recycle or reuse used electronics, nor 
do its regulations require the office to establish a mandatory national 
approach, such as a disposal ban. 

In response to the RCRA regulatory exemption for household hazardous 
waste and the growing volume of obsolete electronics within their 
boundaries, four states--California, Maine, Massachusetts, and 
Minnesota--recently banned some used electronics from 
landfills.[Footnote 16] Such bans appear to have contributed to a 
higher degree of recycling than in states where disposal in solid waste 
landfills is allowed. In San Ramon, California, for instance, a 1-day 
collection event for television monitors yielded 24,000 units. In 
contrast, in Richmond, Virginia, a metropolitan area 4 times the size 
of San Ramon but without a landfill ban, a similar collection event 
(organized by the same electronics recycler as in San Ramon) only 
yielded about 6,000 monitors. This difference in yield is consistent 
with assessments of California and Massachusetts officials, who all 
said that their states have seen substantial increases in used 
electronics recycling. One international electronics recycler, for 
instance, set up recycling facilities in the San Francisco area in 2003 
because of the large volume of used electronics that was no longer 
being disposed of in landfills. In Massachusetts, an official with the 
Department of Environmental Protection said that six businesses 
dedicated to electronics recycling were created following the enactment 
of a landfill ban. Finally, over 95 percent (all but one) of survey 
respondents said that a national disposal ban should be enacted to 
overcome the factors that discourage recycling and reuse of used 
electronics. 

Recyclers we interviewed in California and Massachusetts said that a 
positive side effect of a ban is increased public awareness. In 
Massachusetts, for example, the Department of Environmental Protection 
conducted a survey in which over 60 percent of the respondents were 
aware that electronic products were banned from landfills. Of note, 
only 25 percent of survey respondents believe that the public is aware 
of recycling options for used electronics on a national scale, and over 
85 percent believe that the overall lack of awareness of recycling 
options discourages recycling of these products. 

Experts Believe a National Financing System Is Needed to Support 
Recycling: 

Given the inherent economic disincentives to recycling used electronics 
in the United States, we also found widespread agreement among our 
survey respondents and others we contacted that establishing some type 
of financing system is critical to making recycling and reuse 
sufficiently inexpensive and convenient for consumers to attract their 
participation. Of particular note, over 90 percent of survey 
respondents support one of the two major proposals being discussed--an 
advanced recovery fee (ARF) or extended producer responsibility (EPR)-
-or, a hybrid of the two.[Footnote 17] Yet despite broad agreement in 
principle, participants in the EPA-sponsored NEPSI process, 
particularly those in the computer and television industries, did not 
reach agreement on a uniform, nationwide financing system after several 
years of meetings. 

In the absence of a national system, several states have enacted their 
own financing systems through legislation to help ensure 
environmentally preferable management of used electronics. For example, 
in 2005, California implemented an ARF on all new video display 
devices, such as televisions and computer monitors, sold within the 
state. The fee is charged to consumers at the time and location of 
purchase and can range between $6 and $10. According to an official 
with the California Department of Toxic Substance Control, the revenues 
generated from the fee are intended to deal with a key concern--used 
electronics in storage, or "legacy waste." The officials explained that 
while California's recycling industry had sufficient capacity to 
recycle large volumes of used electronics, consumers and businesses had 
little incentive to take products out of their basements or warehouses 
to have them recycled. The state uses revenues from the fees to 
reimburse electronics recyclers at the rate of 48 cents per pound of 
used electronics recycled. The recyclers, in turn, pass on to 
collectors 20 cents per pound of used electronics, thereby providing an 
incentive for entities to make collection free and convenient for 
households. 

The state is still in the preliminary stages of program implementation, 
and state officials acknowledge that they face a number of challenges. 
Some of these challenges underscore the difficulty of dealing with the 
electronic waste problem on a state-by-state basis. The officials 
noted, for instance, that the ARF applies only to electronics purchased 
in California, and that the fees are intended only for used electronics 
originating in the state. Implementing the program within the state's 
boundaries, however, may prove difficult because the payout may attract 
units originating in other states. Preventing this problem, they say, 
requires substantial documentation for each unit, and may require a 
substantial enforcement effort. 

While California's ARF focuses on consumers of electronics, Maine's 
approach focuses on producers through an EPR-like system. In 2004, the 
state passed legislation requiring computer and television 
manufacturers who sell products in Maine to pay for the take back and 
recycling of their products at end of life. Under this plan, consumers 
are to take their used electronics to a consolidation point, such as a 
transfer station, where they are sorted by original manufacturer. Each 
manufacturer is physically or financially responsible for transporting 
and recycling its products, along with a share of the products whose 
original manufacturer no longer exists. According to one official with 
Maine's State Planning Office, a key challenge of its EPR system is the 
lack of a financial incentive for consumers to take their used 
electronics out of storage. Additionally, consumers will still likely 
have to pay a fee at consolidation points. 

Several other states have implemented or are considering implementing 
financing systems for used electronics. Earlier this year, Maryland 
passed legislation requiring all computer manufacturers that sell 
computers in the state to pay $5,000 into a fund to help implement 
local recycling programs.[Footnote 18] For manufacturers that implement 
a computer take-back program in the prior year, the fee is only $500. 
Other states, such as Arkansas, Colorado, Florida, and Massachusetts, 
have allocated grants to help pay for the recycling of used 
electronics, and New York, Rhode Island, and Vermont are considering 
enacting EPR-like programs. 

The differing financing systems of California and Maine, as well as 
those being considered by other states, suggest that in the absence of 
a national approach, a patchwork of potentially conflicting state 
requirements is developing. Further, this patchwork may be placing a 
substantial burden on manufacturers, retailers, and recyclers. A 
manufacturer in one state, for example, may have an advance recovery 
fee placed on its products; whereas in another state, the same 
manufacturer may have to take back its products and pay for recycling. 
Hewlett-Packard serves as one example: in Maine, officials estimate 
they will spend almost $90,000 per year paying for the take-back and 
recycling of their products under the state's EPR system. In 
California, Hewlett-Packard incurred over $3 million in start-up costs 
and will spend an additional $250,000 per year because the state's ARF 
system requires them to track their products that have been distributed 
to various retailers, who then add a fee. A Hewlett-Packard official 
said implementing one financing system on a national scale would be 
more preferable than implementing numerous financing systems on a state-
by-state basis that have different requirements and, thus, require 
additional costs. A Hewlett-Packard official also told us that these 
conflicting systems involve start-up costs, which could cost over $2 
million dollars per state if a new state system differs from those 
currently in place. 

Similarly, a Seattle area recycler told us that because of the 
differing state requirements and the lack of a national approach, 
recyclers find it difficult to invest in developing a recycling 
infrastructure. Specifically, he noted that without certainty about the 
regulatory landscape, larger recyclers will not enter the industry and 
invest in technologies that can reduce costs, such as has been done in 
some European countries where recycling used electronics is more 
profitable. He added that until this problem is addressed, recycling 
will continue to be conducted primarily by small, niche companies. 

Not surprisingly, three major computer manufacturers we contacted said 
that while they have individual preferences for one financing mechanism 
or another (usually an ARF or EPR system), their main preference is to 
operate within a uniform national system that mandates a financing 
system preempting varying state requirements. Recyclers and state and 
local government officials generally agreed, noting that having a 
system in place that covers costs and is national in scope is more 
important to them than their preferences for a particular system. Our 
survey results substantiate these views, with over 95 percent of survey 
respondents indicating that national legislation should be enacted, and 
over 90 percent of that group stating that one of the major proposals 
being discussed (or a hybrid of the two) should be included, such as an 
ARF or EPR system. 

Because of these challenges, EPA sponsored a major effort in this 
regard by providing the initial funding for the multistakeholder 
National Electronic Product Stewardship Initiative (NEPSI) process. 
NEPSI stakeholders met between 2001 and 2004, in part, to develop a 
financing system to facilitate recycling and reuse of used electronics. 
The process ultimately dissolved in 2005, however, in large part 
because EPA withdrew its participation and funding.[Footnote 19] 

Notwithstanding EPA's withdrawal of its sponsorship of the NEPSI 
process, the agency still generally advocates financing systems for 
resource conservation that involve all stakeholders--consumers, 
manufacturers, and retailers--who benefit from resource use. Under the 
Resource Conservation Challenge, EPA seeks to have products designed 
with reuse and recycling in mind, the costs of reuse and recycling 
included in the price of the product, and improved mechanisms for 
collecting products for recovery. Further, in the Resource Conservation 
Challenge's strategic plan, EPA recognizes that for some products, such 
as electronics, recycling is not economically sustainable. For these 
products, EPA supports the consideration of financing approaches that 
have been implemented in Japan and some European nations, in which the 
cost of recovering products is incorporated into the cost of buying the 
product; and in which incentives are provided for environmentally 
preferable design. 

For example, Japan enacted the Home Appliances Recycling Law in 1998, 
which requires that retailers collect--and manufacturers and importers 
recycle--four types of household appliances, in which televisions are 
included. The law's inclusion of televisions has encouraged the 
development of a television and CRT recycling industry in Japan, where 
substantial research has gone into the development of television 
dismantling and recycling technologies. Since enactment of this law, 
Sony, for example, has cooperated with other companies to establish 190 
take-back sites and 15 recycling plants in Japan. 

In Europe, the European Union (EU) enacted the Waste Electrical and 
Electronic Equipment Directive, which established comprehensive take-
back and recycling requirements for retailers, manufacturers, and 
importers of electrical and electronic products, including televisions, 
computers, and monitors. The directive requires that producers and 
importers finance the separate collection of waste electronics either 
on their own or through collective systems financed by themselves and 
other members of the industry. Ninety-three percent of our survey 
respondents believe that this directive will facilitate collection and 
recycling of used electronics in the EU. The EU also addressed the 
issue of hazardous substances in discarded used electronics by 
requiring that six hazardous substances, including substances such as 
lead, mercury, and cadmium, commonly found in used electronics, be 
replaced by other substances by July 1, 2006. 

Oversight of Exported Used Electronics Is Limited: 

The lack of oversight over some exported used electronics also appears 
to be discouraging environmentally preferable management of such 
products and inhibiting the development of a domestic recycling 
infrastructure. Companies export used electronics because the largest 
markets for reused computers and televisions are overseas. One EPA 
official told us that consumers in developing countries are more 
willing to purchase older computer and television models than consumers 
in developed countries. 

Likewise, the largest markets are also overseas for commodities 
commonly found in used electronics, such as copper, aluminum, and 
shredded plastic. In many developing countries, commodities such as 
these can be obtained more cheaply by disassembling whole units, such 
as CRT televisions and monitors, under less stringent environmental 
requirements. As a result of this demand, many businesses, schools, 
government agencies, and recyclers in the United States receive e-mails 
from foreign brokers willing to pay them for their obsolete computers 
and televisions, even if the products cannot be reused. For example, we 
observed that at one e-commerce Web site, a broker sought to purchase 
50,000 used monitors per month and did not require the monitors to be 
tested to determine whether they could be reused. Another broker in 
Pakistan sought to purchase 1 million nonworking monitors annually at a 
price of $2 to $3 per monitor. In another instance, another broker 
specifically requested nonworking monitors and wanted to fill at least 
10 containers, which amounts to anywhere from 6,000 to 11,000 units 
overall (depending on their size). 

Five electronics recyclers we interviewed, including two who export 
nonworking whole computers and televisions, agreed that brokers such as 
these are probably not handling nonworking units responsibly once the 
units reach their final overseas destination. According to these 
recyclers, it costs money to disassemble and recycle used electronics 
in such a way that protects human health and the environment from 
exposure to toxic substances. In many importing countries, they note, 
labor costs are far lower, in part because the regulatory standards 
needed to protect workers' health and the environment are far more 
lenient. One EPA official agreed, noting that it is safer and more 
protective of the environment if used electronics are disassembled (and 
their materials subsequently separated) in the United States under 
sound environmental standards before exporting recycled commodities. 
Even so, two Seattle area recyclers told us they regularly receive e-
mails requesting these types of products, and they are aware of many 
other organizations, such as school districts, that sell their obsolete 
computers and televisions to foreign brokers because it costs too much 
to have them disassembled in the United States in a manner protective 
of human health and the environment. 

As the export of nonworking whole units continues, a growing body of 
evidence suggests that it is cause for concern in developing countries. 
Instances have been documented recently to confirm the assertions of 
some recyclers and environmental groups that human health and 
environmental threats have resulted from the less-regulated disassembly 
and disposal of many of these U.S.-generated used electronics overseas-
-products that were allegedly destined for reuse (See fig. 1.) A 2002 
documentary by the Basel Action Network and Silicon Valley Toxics 
Coalition videotaped egregious disassembly practices in China that 
involved open burning of wire to recover copper, open acid baths for 
separating precious metals, and human exposure to lead and other 
hazardous materials.[Footnote 20] According to a report by these 
groups, most of the used electronics being handled in this manner were 
of North American origin. 

Figure 1: A Woman in Guiyu, China, Disassembling a CRT Monitor: 

[See PDF for image] 

[End of figure] 

Additionally, it appears that nonworking whole electronic products are 
more frequently handled in an irresponsible manner. Specifically, seven 
recyclers we interviewed, along with a majority of survey respondents, 
told us that nonworking whole products (CRT televisions and computer 
monitors in particular) are much more likely to pose environmental and 
human health risks if they are not disassembled in the United States 
prior to being exported. Accordingly, one survey respondent told us 
that the export of such products should be regulated more closely than 
the export of specific commodities, such as copper, because they still 
contain toxic substances likely to be handled improperly in countries 
without regulations to protect human health and the environment. Our 
survey respondents generally supported these views: while more than 75 
percent believe that exports of working units should be allowed to help 
developing countries advance technologically, only about 20 percent 
said that export of nonworking whole products should be 
allowed.[Footnote 21] 

Despite the additional risks posed by the export of nonworking whole 
CRT televisions and monitors, few legal safeguards are in place to 
ensure that these units are managed responsibly or indeed destined for 
reuse overseas, and one proposed rule by EPA aims to reduce the few 
safeguards that currently exist.[Footnote 22] Under U.S. law, hazardous 
electronic products that will be disassembled in another country are 
subject to a number of export regulations. Such products may only be 
exported with the consent of the government of the receiving country, 
and the Department of State must forward to that government a 
description of the federal regulations that would apply to the waste if 
it remained in the United States. The receiving government may specify 
the terms of its consent and, under U.S. law, the exporter must comply 
with these terms. In addition, the exporter must know the final 
destination of the wastes and must obtain verification that it reached 
the destination. The exporter must also make yearly reports to EPA 
detailing the type, quantity, frequency, and ultimate destination of 
exported hazardous waste. 

In practice, however, U.S. legal restrictions on the export of 
hazardous waste have had little apparent effect on exporters of used 
electronics, even if the units will be disassembled when they reach 
their final destination overseas. One reason for this is that EPA has 
long interpreted the definition of "waste" (and, thus, "hazardous 
waste") to exclude products that will be reused "as is" or after minor 
repairs. Therefore, although U.S. export regulations on hazardous waste 
apply to products that will not be reused at their destination, the 
regulations do not apply to products that are bound for reuse. 
Moreover, nothing in RCRA or its regulations requires exporters to 
demonstrate that their products will be reused. Exporters can simply 
assert that their exported used electronics are bound for reuse, even 
if the exports instead are completely disassembled when they reach 
their destination. 

Of additional concern is EPA's June 2002 proposed rule, which would, 
under most circumstances, exclude hazardous CRT televisions and 
computer monitors from RCRA's existing notification and consent 
regulations for hazardous waste exports. The purpose of the rule, as 
outlined in the Federal Register, is to encourage greater reuse and 
recycling of these products in the United States by streamlining the 
management requirements for used CRTs, while maintaining necessary 
environmental protection.[Footnote 23] Many stakeholders support this 
rule, including recyclers and manufacturers, because it helps reduce 
the costs of recycling CRT televisions and computer monitors. However, 
under the proposed rule, EPA also proposed that CRT televisions and 
computer monitors, including broken units, be excluded from RCRA's 
export notification and consent laws and regulations. Thus, exporters 
would be excluded from having to obtain the consent of the receiving 
country before exporting the waste and from having to make yearly 
reports to EPA detailing the quantity and destination of used CRT 
exports. This provision is in stark contrast to recommendations 
developed by EPA's Common Sense Initiative between 1994 and 1998, which 
recommended that entities exporting CRTs be subject to the same export 
regulations as other generators of hazardous waste.[Footnote 24] 

According to one EPA official closely involved in this proposed 
rulemaking effort, EPA received numerous comments from individuals and 
organizations concerned that the rule would increase the export of 
eventual hazardous wastes to countries ill-equipped to manage them in a 
manner protective of human health and the environment. As a result, 
this and another EPA official told us that EPA is making changes to the 
final rule that address these stakeholders' concerns while, at the same 
time, helping the domestic recycling infrastructure. Currently, the 
rule--along with language addressing oversight of hazardous exports--is 
being reviewed by the Office of Management and Budget. 

In addition to the added health and environmental risks posed by 
nonworking whole electronic products, several recyclers who disassemble 
domestically told us they cannot compete with exporters of nonworking 
whole products because these exporters do not bear the costs of 
adherence to U.S. environmental regulations. In support of this view, 
75 percent of survey respondents said that exports such as these reduce 
the viability of the U.S. recycling infrastructure. Additionally, 
concerned about potential environmental and human health risks 
resulting from U.S.-generated used electronics, over 70 percent of 
survey respondents said the U.S. government should place some 
restrictions on used electronics exports. 

Federal Efforts to Increase Recycling and Reuse of Used Electronics Can 
Be Strengthened: 

EPA has implemented several promising voluntary programs to encourage 
recycling and reuse of used electronics. Without EPA authority to 
require recycling of these products or to require other federal 
agencies to participate, however, these programs' successes have been 
and will continue to be limited. 

Voluntary EPA Programs Show Promise: 

In 2002, EPA organized its voluntary efforts for environmentally 
preferable management of used electronics under a broadly scoped 
program called the Resource Conservation Challenge. This program 
focuses EPA resource conservation efforts on four critical areas, two 
of which are directly related to used electronics: (1) promoting 
environmentally preferable management of used electronics, such as 
recycling, and (2) reducing toxic substances potentially entering the 
waste stream. This program also challenges the federal government to 
lead by example. Since 2000, EPA has spent about $2 million on 
voluntary pilot programs, projects, and grants related to recycling 
used electronics. Three particularly promising projects under this 
program include (1) the Federal Electronics Challenge (FEC); (2) the 
Electronic Product Environmental Assessment Tool (EPEAT), both of which 
leverage U.S. government purchasing power to promote environmentally 
preferable management of electronic products from procurement through 
end of life; and (3) the "Plug-In To eCycling" campaign, which aims to 
minimize the economic factors that deter recycling. 

The FEC program challenges federal agencies and facilities to procure 
environmentally preferable electronic products, extend the lifespan of 
these products, and expand markets for recycling and recovered 
materials by recycling them at end of life. The FEC provides guidance 
on environmentally preferable attributes of electronic products, 
information on operating and maintaining them in an energy-efficient 
manner, and on options for recycling or reusing them at end of life. 
Currently, 12 federal agencies and 61 individual federal facilities 
participate in the FEC to some extent. Of note, the Bonneville Power 
Administration (BPA) recently documented cost savings associated with 
its FEC participation. BPA noted, for example, that through the 
program, it extended the lifespan of its personal computers from 3 to 4 
years. With over 500 computers procured each year at an annual cost of 
more than $500,000, a BPA official said that extending computer life 
spans could generate substantial savings. Additionally, BPA decided to 
procure new flat-screen monitors instead of CRT monitors, reducing both 
hazardous waste tonnage and end of life recycling costs. According to 
BPA, it expects to save at least $153 per monitor over the life of each 
monitor. 

Relatedly, the EPEAT program promotes environmentally preferable 
management of electronics by helping large purchasers, such as 
government agencies, compare and select laptop computers, desktop 
computers, and monitors with environmentally preferable attributes. For 
example, using EPEAT, purchasers can evaluate the design of an 
electronic product for energy conservation, reduced toxicity, extended 
lifespan, and end of life recycling, among other things. EPEAT's three-
tier system--bronze, silver, and gold--provides purchasers with the 
flexibility to select equipment that meets the minimum performance 
criteria, or to give preference to products with more environmental 
attributes. For manufacturers, EPEAT provides flexibility to choose 
which optional criteria they would like to meet to achieve higher 
levels of EPEAT qualification. EPEAT was developed along the lines of 
EPA and DOE's Energy Star program, in which the federal government 
rewards manufacturers that offer businesses and consumers energy-
efficient products that ultimately save money and protect the 
environment by providing them with the Energy Star label for their 
products. In fact, specific EPEAT procurement criteria are drawn 
heavily from Energy Star standards. EPA expects EPEAT to be instituted 
in 2006. 

Another promising program, the Plug-In To eCycling campaign, has led to 
the collection and recycling of over 45 million pounds of used consumer 
electronics in the United States, including computers, monitors, and 
televisions, since 2003. The "Plug-In To eCycling" campaign is 
partnering with over 20 industry affiliates and 27 state and local 
governments to provide the public with information about recycling and 
to establish pilot projects to test innovative approaches to collect 
and manage used electronics. In the pilot projects funded through Plug-
In To eCycling, partnering organizations have reduced the cost and 
inconvenience of recycling used electronics. For example, manufacturers 
have helped pay the cost of recycling used electronics; retailers have 
helped provide collection opportunities; recyclers have helped provide 
lower costs for larger quantity, longer-term contracts that meet 
environmentally safe management guidelines; and consumers have taken 
their used electronics from storage to designated locations. In 2004, 
Plug-In To eCycling sponsored four pilot projects, which all involved 
holding collections events at retailers such as Best Buy, Good Guys, 
Office Depot, Staples, and Target. These pilot collection events lasted 
from a few weeks to a few months and collected over 11 million pounds 
of used electronics. 

Lack of EPA Authority for Requiring Federal Agency Participation Limits 
Programs' Successes: 

While the voluntary EPA programs outlined above have produced tangible 
results, their ultimate potential is constrained by the lack of EPA 
authority to require broader participation. Currently, for example, 
only 61 out of thousands of federal facilities are participating in the 
FEC. Requiring participation by private parties and state and local 
governments in these programs may be neither realistic nor desirable. 
However, as discussed below, there is ample precedent for actions that 
would engender greater federal participation in these types of 
programs. Wider federal participation would likely benefit both the 
environment and the development of the electronics recycling industry-
-federal agencies were expected to spend over $60 billion on 
televisions, computers, monitors, and other information technology 
products and services in fiscal year 2005 alone. 

Perhaps the best precedent for requiring broader federal participation 
in electronics recycling is the Energy Star program, co-sponsored by 
EPA and the Department of Energy. According to EPA, in 2004 alone, 
Energy Star products helped save approximately $10 billion in energy 
costs and reduced greenhouse gas emissions by an amount equivalent to 
that produced by 20 million automobiles. Also, in 2005, public 
awareness of Energy Star reached over 60 percent. Because of Energy 
Star's high profile, EPA officials told us that although manufacturers 
do not have to design their products to meet Energy Star criteria, many 
manufacturers view Energy Star as a de facto requirement for design of 
their products--suggesting that if their products do not have the 
Energy Star label then they are at a competitive disadvantage in the 
marketplace. 

According to an EPA official who has worked on the Energy Star program 
since its inception, part of Energy Star's success can be attributed to 
two executive orders that required federal agencies to purchase 
products equipped with Energy Star features. Specifically, Executive 
Order 12845, issued in 1993, required federal agencies to procure 
computers and monitors that meet Energy Star requirements for energy 
efficiency. This EPA official told us that the early success of Energy 
Star was enhanced by this executive order. Executive Order 13123, 
issued in 1999, directs federal agencies to select Energy Star products 
when procuring any energy-using product. For product groups where 
Energy Star labels are not yet available, agencies are directed to 
select products that are in the upper 25 percent of energy efficiency, 
as designated by the Federal Energy Management Program. 

In contrast, the potential success of the FEC and EPEAT programs is 
presently limited because, unlike the Energy Star program, federal 
agencies' participation is not required. The potential benefits from 
broader federal participation were illustrated by BPA's experience, 
which, as noted earlier, demonstrated significant cost and energy 
savings and greater environmental protection. They were also 
underscored by the results of our survey--almost 90 percent of 
respondents said that federal government procurement criteria along the 
lines of FEC and EPEAT should be required, and over 95 percent said 
that such procurement criteria would encourage environmentally 
preferable product design, and greater recycling and reuse. 

Conclusions: 

Despite the significant environmental benefits of recycling and reusing 
used electronics, these environmentally preferable practices will 
likely remain underutilized unless concerted actions are taken. Two 
overarching factors contribute to this problem. First, consumers have 
the cheaper and more convenient option of simply throwing these 
products away in most states. Without a fundamental change in the 
incentive structure affecting their decisions, such as through the 
implementation of a consistent nationwide financing system, consumers 
will continue to choose disposal as the preferable option of dealing 
with used electronics in the overwhelming number of states where 
disposal is allowed. Also in the absence of federal action, states are 
taking measures to address their unique recycling challenges. This 
state-by-state approach, however, has the unintended consequence of 
increasing costs for manufacturers, retailers, and consumers, while 
discouraging recyclers from investing in a domestic recycling 
infrastructure. It has also led to an array of legislative proposals 
that take very different approaches to address the problem. 

Second, rather than paying for proper disassembly in the United States, 
some organizations discarding used electronics (and some recyclers) 
sell these units to overseas buyers with no guarantee that they will be 
properly handled. The problem is particularly serious in the case of 
nonworking whole products, such as CRT televisions and computer 
monitors, which are often handled in a manner that causes adverse 
environmental and human health effects in receiving countries. Current 
RCRA regulations require EPA to oversee the export of many used CRT 
televisions and computer monitors if such products will not be reused 
at their final destination. In practice, however, there has been little 
oversight over the export of these products because neither RCRA nor 
its regulations require exporters to demonstrate that exported 
electronic products will actually be reused. In addition to posing 
health and environmental risks in developing countries, this practice 
undermines the domestic recycling industry by providing a cheap 
alternative to domestic recycling, which is more protective of human 
health and the environment. Importantly, EPA's proposed CRT rule would 
further exacerbate the problem if adopted as presently worded because 
it would restrict EPA's regulatory authority to oversee the exportation 
of most used CRT televisions and computer monitors. 

These factors have prevented much recycling from occurring to date and, 
if not addressed, will continue to stymie recycling and reuse efforts. 
EPA has implemented several promising voluntary programs to encourage 
recycling and reuse of used electronics, but without the authority to 
require recycling of these products or to require other federal 
agencies to participate, the success of these programs is and will 
continue to be limited. In the past, the federal government has taken 
steps to encourage environmentally preferable choices by leveraging its 
substantial market power, but these actions required the participation 
of all federal agencies. Using the success of the Energy Star program 
as a precedent, the federal government has the opportunity to lead by 
example by building on existing EPA programs to (1) enhance the 
domestic recycling infrastructure for used electronics by ensuring a 
steady and substantial supply of used electronics; (2) stimulate 
markets for environmentally preferable electronic products by 
purchasing energy efficient, easily recyclable products with high 
recycled content and less toxic substances; and (3) save energy by 
extending the lifespan of used electronics. 

Recommendations: 

Given the numerous and varying legislative proposals for nationwide 
financing systems, we recommend that the Administrator, EPA, direct the 
Offices of Solid Waste and Pollution Prevention and Toxics to bring its 
expertise to bear on the issue by drafting a legislative proposal 
including, but not limited to, recommendations for a consistent, 
nationwide financing system that addresses the barriers to recycling 
and reuse. 

As EPA finalizes its proposed rule regarding CRTs, we also recommend 
that the Administrator ensure that the final rule reflects the concerns 
of numerous commenters that it will not constrict EPA's regulatory 
authority to oversee the exportation of CRT televisions and monitors 
(many of which exhibit the traits of hazardous wastes currently 
regulated by EPA) to countries that do not have the environmental 
protections in place to ensure their safe disassembly. 

In addition, to establish a national recycling infrastructure and 
encourage environmentally preferable management of used electronics 
throughout their life-cycle, we also recommend that the Administrator 
direct the Office of Solid Waste to take necessary action (in 
collaboration with the Office of the Federal Environmental Executive) 
to require federal agencies to participate in the Federal Electronics 
Challenge and to procure electronic products that meet or exceed the 
minimum performance criteria set by the Electronic Product 
Environmental Assessment Tool. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Administrator of the 
Environmental Protection Agency for review and comment. In its October 
14, 2005 letter, EPA expressed agreement with most of the report's 
findings, noting further that agency reviewers found the report "to be 
very well written, carefully researched, and clearly argued." EPA 
disagreed, however, with our recommendations that the agency play a 
more active role in promoting electronic waste recycling and reuse by 
(1) developing a legislative proposal that would address key barriers 
to recycling and reuse and (2) taking additional steps to ensure 
broader implementation by federal agencies of EPA's initiatives to 
promote wider use of electronics recycling and reuse across the federal 
government. 

EPA commented that it does not believe it is appropriate for the agency 
to develop a proposal for establishing a nationwide financing system 
that addresses the barriers to recycling and reusing used electronics. 
EPA explained that since there is no consensus among manufacturers 
regarding the optimal financing solution to meet these ends, the agency 
is "not in the best position to choose between competing financing 
solutions, given that this decision is one that is fundamentally a 
business and economic issue, rather than an environmental issue." We 
acknowledge the lack of consensus among manufacturers cited by EPA, but 
disagree that this lack of consensus provides a compelling reason for 
EPA to abstain from acting on this recommendation. 

First, for the reasons cited in this report and those of other 
organizations, electronic waste is becoming an increasingly important 
environmental issue. As such, the fact that a key barrier involves 
disagreement over competing financing solutions should not preclude EPA 
from helping to resolve the problem. There are also ample precedents 
for EPA's active involvement in addressing complex financial issues 
affecting solutions to key environmental problems. EPA played a central 
role, for example, in developing the Clean Water State Revolving Fund 
and Drinking Water State Revolving Fund programs. These programs have 
become instrumental in helping communities address their water 
infrastructure needs efficiently and at lower cost to the federal 
government. 

Second, our survey results show that while there is disagreement on 
precisely what financing mechanism should be used to resolve the 
problem, there is an overwhelming consensus that (1) legislation will 
be needed to deal with the problem and (2) a uniform nationwide 
financing solution would be preferable to none at all. As we noted 
above, the manufacturers we contacted said that while they have 
individual preferences for one financing mechanism or another, their 
overriding goal is to operate within a uniform national system that 
mandates a financing system preempting varying state requirements. Our 
survey results substantiated these views, with over 95 percent of 
survey respondents indicating that some type of national legislation is 
needed to move electronics recycling forward. Additionally, over 90 
percent of these respondents believe that a financing system should be 
included in national legislation. In essence, inaction itself is the 
choice that has the least support among stakeholders in dealing with 
electronics waste at the national level. 

Third, an active EPA role in proposing options to Congress for a 
nationwide financing system is consistent with the goals EPA has set 
forth in its own strategic plan for electronics recycling.[Footnote 25] 
In this plan, EPA commits to removing barriers to recycling and 
identifying opportunities to reduce wastes. The plan also says that 
sustainable funding systems must be available for recycling, 
particularly for products in which recycling is not economically 
viable. As noted earlier in our report, such is the case for used 
electronics. Finally, EPA's plan notes that within 5 years, the agency 
aims for "it to be as easy for consumers to recycle or find a re-user 
for their television or computer as it is for them to buy one." 

EPA's letter also disagreed with our recommendation that EPA take steps 
aimed at requiring federal agencies to participate in the Federal 
Electronics Challenge and Electronic Product Environmental Assessment 
Tool program. In particular, citing its specific technical comments 
provided to us under separate cover, EPA disagreed with our view that 
participation in the FEC is limited. Among other things, EPA's 
technical comments echoed often-cited data showing that the 12 federal 
agencies participating in the program to date "represent over 80 
percent of the Information Technology purchasing in the government." 
The figure, however, overstates federal agency adherence to the goals 
of the FEC. Participation by these 12 agencies, for example, does not 
mean that 80 percent of all Information Technology products are 
procured, operated, and recycled or reused at end of life in an 
environmentally preferable fashion. Instead, participation simply means 
these agencies have identified their current practices for managing 
electronic products and set goals to improve them. However, 
participating agencies and facilities are not required to meet these 
goals. As a practical matter, 61 out of thousands of federal facilities 
participate in the Federal Electronics Challenge, and only 5 are 
meeting electronic product management criteria that the Federal 
Electronics Challenge steering committee has asked them to attain. 

We believe this track record falls short of the goals of EPA's Resource 
Conservation Challenge, which asks the federal government to "lead by 
example" in promoting recycling, reducing the use of toxic chemicals, 
and conserving energy and materials in its life-cycle management of 
electronic products. Past experience with similar programs (such as the 
Energy Star program), together with EPA's experience to date with the 
FEC, suggests that merely encouraging participation in these programs 
will not meet these goals. Because the federal government will spend 
about $65 billion on information technology in fiscal year 2006 while 
discarding approximately 10,000 computers per week, we continue to 
believe that our recommendation on this matter is both practical and 
appropriate. Specifically, either through an executive order, changes 
to the Federal Acquisition Regulations, or through some other means, 
federal participation in the FEC and EPEAT programs should be required 
to help ensure environmentally preferable management of used 
electronics by the federal government. 

EPA also provided technical clarifications on the text of our draft 
report, which we have incorporated into the final report as 
appropriate. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution of this report 
until 30 days from the date of this letter. At that time, we will send 
copies of this report to interested congressional committees; the 
Administrator of the Environmental Protection Agency; and other 
interested parties. We will make copies available to others upon 
request. In addition, the report will be available at no charge on the 
GAO Web site at http://www.gao.gov. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-3841 or [Hyperlink, stephensonj@gao.gov]. 
Contact points for our Office of Congressional Relations and Public 
Affairs may be found on the last page of this report. Key contributors 
to this report are listed in appendix IV. 

Signed by: 

John B. Stephenson: 
Director, Natural Resources and Environment: 

[End of section] 

Appendixes: 

Appendix I: Scope and Methodology: 

To summarize existing research on the quantity of end-of-life 
electronics and the problems they may pose, we reviewed scientific 
studies and reports conducted by government agencies, nonprofits, trade 
organizations, and academics. We also consulted with federal, state, 
local, nonprofit, and industry officials, as well as academic and 
research organization experts. For studies estimating the volume of 
used electronics, we focused on those that generated original data 
analyses rather than summaries of existing literature. In addition, we 
limited our review to studies that provided nationwide 
estimates.[Footnote 26] For studies that we cited in this report, we 
reviewed their methodology, assumptions, limitations, and conclusions 
to ensure that we properly represented the validity and reliability of 
their results and conclusions. We also interviewed experts and study 
authors from government, industry, and academia to obtain their views 
on the quantity of used electronics and problems they may pose. 

To examine the factors that affect the nation's ability to recycle and 
reuse electronics, we examined current federal laws, regulations, and 
guidance regarding solid and hazardous waste disposal as they relate to 
the disposal of used electronics. We also reviewed pertinent state and 
local laws, regulations, and guidance. In particular, we reviewed the 
electronic waste legislation passed in Massachusetts, California, 
Maine, Minnesota, and Maryland. We visited states and localities that 
have implemented programs or passed legislation to responsibly manage 
used electronics, including California, Maine, Massachusetts, Oregon, 
and Washington. In addition we interviewed federal, state, local, 
government officials. We also interviewed officials from original 
equipment manufacturers, recyclers, trade organizations, nonprofit 
organizations, and environmental advocacy groups, as well as academic 
and research organization experts. Further, we examined EPA-sponsored 
federal, state, and local pilot programs that attempt to encourage 
recycling of electronic products. Finally, we also examined regulations 
that manage used electronics in Japan and the European Union. 

In addition, to obtain the views of informed stakeholders regarding the 
factors that affect the nation's ability to recycle and reuse used 
electronics, we conducted a survey of a nonprobability sample of 
participants in the National Electronics Product Stewardship Initiative 
(NEPSI) and other key stakeholders.[Footnote 27] The NEPSI stakeholders 
met in a series of meetings between 2001 and 2004 in an attempt to 
develop solutions to the issue of managing used electronics. NEPSI was 
comprised of 48 stakeholders, with 15 representing federal, state, and 
local governments; 16 representing equipment manufacturers; and 17 
other stakeholders from environmental organizations, recyclers, 
retailers, and academics. We attempted to contact all the NEPSI 
stakeholders listed on NEPSI's Web site, but we could not obtain 
current contact information for 4 of the 48 stakeholders or their 
alternates. We also sent surveys to 3 alternate NEPSI stakeholders 
because we were told by other stakeholders that they were active 
participants in NEPSI deliberations and did not work in the same agency 
as the primary stakeholder. We sent another 7 surveys to non-NEPSI 
participants to provide more balance in our survey population. These 7 
stakeholders included two retailers, two recyclers (one for profit and 
one nonprofit), a recycling trade organization, a retail trade 
organization, and an EPA consultant who is an expert on recycling 
issues. Finally, we excluded from our survey population 4 stakeholders 
that did not respond to our survey who the coordinator of NEPSI 
characterized as "inactive" during the NEPSI deliberations, and 1 
stakeholder who now works for the same organization as another 
stakeholder. In total, our survey population comprised of 49 
individuals, 42 of which completed surveys and submitted them to us, 
yielding an 86 percent response rate. 

To develop the questions for our survey, we identified key information 
to gain a general understanding of recycling and reuse issues for used 
electronics. In particular, the survey focused on areas such as public 
awareness, collections, exports, costs, historic and orphan waste, and 
hypothetical provisions in potential federal legislation. After 
initially developing, reviewing, and modifying the survey questions, we 
conducted a total of six pretests, two with GAO employees who were not 
associated with this review, and four non-GAO employees who were chosen 
on the basis of having characteristics similar to the NEPSI 
stakeholders. The final changes to the survey were made on the basis of 
the combined observations from the six pretests. 

We conducted our review from October 2004 to September 2005 in 
accordance with generally accepted government auditing standards, which 
include an assessment of data reliability and internal controls. 

[End of section] 

Appendix II: Survey of Selected Stakeholders on Recycling Used 
Electronics: 

[See PDF for image] 

[End of figure] 

[End of section] 

Appendix III: Comments from the Environmental Protection Agency: 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY: 
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE: 
WASHINGTON, D.C. 20460: 

October 14, 2005: 

Mr. John B. Stephenson: 
Director: 
Natural Resources and Environment: 
Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Stephenson: 

This letter provides EPA's comments and responses to the draft report 
"Electronic Waste: Strengthening the Role of the Federal Government in 
Encouraging Recycling and Reuse." 

We appreciate your report and the work that lies behind it. We have 
carefully reviewed the report and find it to be very well written, 
carefully researched and clearly argued. We had a number of technical 
and editorial suggestions which are provided in the attached document. 

We agree with most of the findings made in this report. However, we 
take issue with your specific recommendations on development of 
legislation and on how to ensure broader implementation within the 
Federal Government of the Federal Electronics Challenge and the 
Electronic Products Environmental Assessment Tool. Our specific 
suggestions with regard to those recommendations follow. 

On page 33 of the draft report, GAO recommends that EPA "draft a 
legislative proposal including, but not limited to, recommendations for 
a consistent, nationwide financing system that addresses the barriers 
to recycling and reuse." We do not believe it is appropriate for EPA 
(on behalf of the Administration) to develop such a proposal. As GAO 
knows, there is no consensus among manufacturers about what the best 
financing solution is to enable widespread electronics recycling, even 
though manufacturers and many other stakeholders have expressed the 
view that a national solution is better than a patchwork of state 
solutions. Manufacturers are sharply divided over whether it should be 
a visible fee at point of sale charged to the consumer or some kind of 
internalized fee charged to the manufacturers. Retailers appear to be 
strongly opposed to a visible fee at point of sale. While EPA has 
gained some expertise on the issues of financing electronics recycling 
through participation in the NEPSI dialogue and its observation of 
development of state laws, EPA is not in the best position to choose 
between competing financing solutions, given that this decision is one 
that is fundamentally a business and economic issue, rather than an 
environmental issue. However, if the House Working Group on E-Waste or 
a yet to be formed House/Senate Working Group on E-Waste were to take 
up the task of developing a national financing bill modeled on some of 
the financing solutions discussed in NEPSI or being implemented at the 
state level, EPA could provide technical assistance, as requested. 

GAO also calls on EPA to "take necessary action (in collaboration with 
the Office of the Federal Environmental Executive) to require federal 
agencies to participate in the Federal Electronics Challenge and to 
procure electronic products that meet or exceed the minimum performance 
criteria set by the Electronic Product Environmental Assessment Tool." 
As we explain in more detail in our specific comments, we disagree with 
GAO's view that participation in the FEC is limited, especially 
considering that this program was just launched in the past year. And 
we are not yet convinced that an Executive Order mandating 
participation is the best approach to ensuring broad and effective 
participation. However, we will explore this and other options with the 
Office of the Federal Environmental Executive and will continue to work 
with federal agencies and their facilities to encourage them to join 
FEC and use EPEAT. 

Thank you for the opportunity to review the draft. Once again, we 
commend you on an excellent draft. 

If you need additional information, you may contact Thea McManus, 
Associate Director of the Municipal and Industrial Solid Waste 
Division, Office of Solid Waste, at (703) 308-8738 or Clare Lindsay, 
Office of Solid Waste, at (703) 308-7266. 

Sincerely, 

Signed for: 

Thomas P. Dunne: 
Acting Assistant Administrator: 

Enclosure: 

cc: Office of Pollution Prevention and Toxics, 
Office of Administration and Resources Management. 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

John B. Stephenson (202) 512-3841: 

Staff Acknowledgments: 

Individuals making key contributions to this report included Nathan 
Anderson, Charles Bausell, Virginia Chanley, Bernice Dawson, Steve 
Elstein, Omari Norman, Alison O'Neill, Judy Pagano, Carol Herrnstadt 
Shulman, Monica Wolford, and Arvin Wu. 

(360517): 

FOOTNOTES 

[1] For the purposes of our study, used electronics includes computers, 
computer monitors, and televisions that have reached the end of their 
original useful life. 

[2] States are subject to minimum national standards for the management 
of municipal solid waste in landfills, but they are free to implement 
more stringent policies as well. 

[3] National Safety Council, Electronic Product Recovery and Recycling 
Baseline Report, May 1999. These estimates are based on major 
assumptions, as well as responses from only 38 percent of sampled 
companies. Although the study supports the existence of a large and 
growing problem, the precise estimates should be used with caution. 

[4] CRTs are the technology used in most televisions and computer 
display screens. 

[5] International Association of Electronics Recyclers, IAER 
Electronics Recycling Industry Report, 2003. These estimates are based 
on major assumptions, as well as responses from only 20 percent of 
sampled companies. Although the study supports the existence of a large 
and growing problem, the precise estimates should be used with caution. 

[6] "Flow and Capacity Analysis of Cathode Ray Tube Management for 
Households and Conditionally Exempt Small Quantity Generators," 
prepared for EPA by ICF, June 2004. Because we were unable to review 
the methodology of this study, these data should be used with caution. 

[7] Bleiwas, Donald and Kelly, Thomas, Obsolete Computers, "Gold 
Mines," or High-Tech Trash? Resource Recovery from Recycling 
(Washington, D.C. U.S. Geological Survey, 2001). Because we were unable 
to review the methodology of this study, these data should be used with 
caution. 

[8] The United Nations University is a think tank for the United 
Nations and is not a degree granting university. 

[9] Townsend, Timothy, et al, Characterization of Lead Leachability 
from Cathode Ray Tubes Using the Toxicity Characteristic Leaching 
Procedure. (University of Florida, Department of Environmental 
Engineering Sciences: 2000). Because this study did not test a 
representative sample of each type of electronic device, the results 
cannot be generalized to the population. However, the results do 
indicate that color monitors and televisions with CRTs have the 
potential to be toxicity characteristic hazardous wastes. 

[10] Solid Waste Association of North America, The Effectiveness of 
Municipal Solid Waste Landfills in Controlling Releases of Heavy Metals 
to the Environment (2004). We did not independently evaluate and 
validate the reliability of the information from the studies reviewed 
in this report. 

[11] Data from recent EPA-sponsored pilot projects show that the costs 
of collecting and transporting used electronics can be as much as two-
thirds of the total cost associated with recycling. 

[12] Hewlett-Packard officials said they are currently modifying their 
computers to reduce Noranda's recycling costs. 

[13] The percentages used in this report reflect those survey 
respondents who provided an answer for the question being examined and 
does not include non-responses to the question. 

[14] EPA does not regulate whole circuit boards that contain batteries 
and minimal quantities of mercury. However, once these materials are 
removed from the circuit boards, EPA may consider them to be hazardous 
wastes. 

[15] Boon, J.E., Isaacs, J.A., and Gupta, S.M. "Economic Sensitivity 
for End of Life Planning and Processing of Personal Computers." Journal 
of Electronics Manufacturing (Vol. 11, 81-93, 2002). 

[16] The landfill bans in Maine and Minnesota take full effect in 2006. 

[17] An ARF involves placing an additional fee on a product at the 
point of sale. EPR involves the manufacturers of a product having 
financial or physical responsibility for taking back their products for 
recycling or reuse at end of life. 

[18] An official with the Maryland Department of Environment estimated 
that anywhere from 40 to 200 computer manufacturers might be required 
to pay the fee. He cited one estimate that the fee will provide the 
state with about $400,000 to use toward recycling used electronics. 

[19] EPA provided funding for NEPSI through a cooperative agreement 
with the University of Tennessee. EPA's Office of General Counsel 
recommended that EPA withdraw from NEPSI because discussions had, by 
late 2003, evolved to the point where some stakeholders were discussing 
jointly lobbying for federal legislation. The Office of General Counsel 
was concerned that EPA's continued involvement in this dialogue (and 
continued funding of a grant to facilitate the dialogue) could raise 
questions relating to anti-lobbying restrictions applicable to EPA 
staff and EPA grantees. 

[20] The Basel Action Network is an environmental group that works to 
prevent the trade of toxic wastes from developed countries to 
developing countries. The Silicon Valley Toxics Coalition is an 
environmental group that works to prevent environmental and human 
health problems caused by the electronics industry. 

[21] Also of note, about 65 percent said that export of commodities 
like copper and shredded plastic should be allowed once disassembled 
domestically. 

[22] The following are generally not classified as solid wastes under 
RCRA, which means they cannot be regulated as hazardous waste: Used 
electronics for reuse, whole circuit boards, shredded circuit boards, 
if free of certain hazardous materials, metal from used electronics, 
and scrap metal. 

[23] Hazardous Waste Management System; Modification of the Hazardous 
Waste Program; Cathode Ray Tubes and Mercury-Containing Equipment, 67 
Fed. Reg. 40507 (proposed June 12, 2002). 

[24] EPA's Common Sense Initiative was an advisory committee formed 
under the Federal Advisory Committee Act. 

[25] Environmental Protection Agency, Resource Conservation Challenge 
Strategic Plan, What Can You Save Tomorrow? Five Year Plan. 

[26] For the purposes of our study, used electronics includes 
computers, computer monitors, and televisions that have reached the end 
of their original useful life. 

[27] Results from nonprobability samples cannot be used to make 
inferences about a population, because in a nonprobability sample some 
elements of the population being studied have no chance or an unknown 
chance of being selected as part of the sample. 

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