United States Government Accountability Office

GAO

Report to Congressional Requesters

November 2005

ELECTRONIC WASTE
Strengthening the Role
of the Federal
Government in
Encouraging
Recycling and Reuse

GAO-06-47

a

November 2005

ELECTRONIC WASTE
Accountability Integrity Reliability

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

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

Why GAO Did This Study

What GAO Found

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.

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.

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 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.

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.
United States Government Accountability Office

Contents

Letter

1
3
6

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

25
28
30
30

Scope and Methodology

34

Survey of Selected Stakeholders on Recycling Used
Electronics

37

Comments from the Environmental Protection Agency

55

GAO Contact and Staff Acknowledgments

57

8
10

Appendixes
Appendix I:
Appendix II:
Appendix III:
Appendix IV:

Figure

Figure 1: A Woman in Guiyu, China, Disassembling a CRT Monitor
22

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GAO-06-47 Electronic Waste

Contents

Abbreviations
ARF
BPA
CRT
DOE
EPA
EPEAT
EPR
EU
FEC
NEPSI
RCRA

advanced recycling fee
Bonneville Power Administration
cathode ray tube
Department of Energy
Environmental Protection Agency
Electronic Product Environmental Assessment Tool
extended producer responsibility
European Union
Federal Electronics Challenge
National Electronic Product Stewardship Initiative
Resource Conservation and Recovery Act

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reproduce this material separately.

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GAO-06-47 Electronic Waste

A

United States Government Accountability Office
Washington, D.C. 20548

November 10, 2005

Leter

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.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

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.

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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

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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.

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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

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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

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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.

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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 lesstoxic 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

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and reuse, toxic chemical reduction, and resource conservation.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
1997.3 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) technology4 is replaced by new technologies such as plasma
screens.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

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.

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annually in U.S. landfills—only a fraction of the amount estimated to
become obsolete annually, according to EPA.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.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.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

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.

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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.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.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
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.

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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.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

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.

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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.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.13

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.

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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.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.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

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).

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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.

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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.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
16

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

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two major proposals being discussed—an advanced recovery fee (ARF) or
extended producer responsibility (EPR)—or, a hybrid of the two.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.

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.

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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.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

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.

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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-bystate 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

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recycling and reuse of used electronics. The process ultimately dissolved in
2005, however, in large part because EPA withdrew its participation and
funding.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 takeback sites and 15 recycling plants in Japan.
In Europe, the European Union (EU) enacted the Waste Electrical and
Electronic Equipment Directive, which established comprehensive takeback and recycling requirements for retailers, manufacturers, and
importers of electrical and electronic products, including televisions,
computers, and monitors. The directive requires that producers and

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.

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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 ecommerce 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

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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.20 According to a report by these groups, most of the
used electronics being handled in this manner were of North American
origin.

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.

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

Source: Basel Action Network.

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

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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.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.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

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.

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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.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.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,

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.

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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”

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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.

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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

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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

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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

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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.

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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.

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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.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

25

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

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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 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.

John B. Stephenson
Director, Natural Resources and Environment

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Appendix I

Scope and Methodology

AA
ppp
ep
ned
n
x
id
e
x
Iis

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.1 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

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.

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Appendix I
Scope and Methodology

stakeholders.2 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.

2
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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Appendix I
Scope and Methodology

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.

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Appendix II

Survey of Selected Stakeholders on Recycling
Used Electronics

Appendx
Ii

DRAFT
United States Government Accountability Office

Survey of Selected Stakeholders on
Recycling Used Electronics
Introduction
The U.S. Government Accountability Office (GAO) is an agency that assists the U.S. Congress in
evaluating federal programs. GAO has been asked by members of the U.S. Senate to identify (1) the
amount of used electronics and the problems they may pose, (2) practices that encourage recycling of
used electronics, and (3) factors that discourage the recycling of these products. The electronic products
in the scope of our analysis include televisions, computer monitors, and computer central processing units
(CPUs), including laptops.
To obtain stakeholder perspectives on recycling used electronics, we are sending this survey to
participants in the NEPSI dialogue. Please note that we will not publish individual responses to this
survey. We intend to use the information gained through this survey in a report that we will ultimately
provide to the Congress.
Instructions
This questionnaire can be filled out using MS-Word and returned via e-mail to EWasteSurvey@gao.gov.
If you prefer, you may print copies of the questionnaire and complete them by hand. If you complete the
survey by hand, fax your completed questionnaire to GAO at (202) 512-2514 or (202) 512-2502.
x Please use your mouse to navigate by clicking on the field or check box

you wish to answer.

x To select a check box or button, simply click on the center of the box.
x To change or deselect a check box response, simply click on the check box and the ‘X’ will disappear.
x To answer a question that requires that you write a comment, click on the answer box ____ and begin
typing. The box will expand to accommodate your answer.
If you have any questions about the content of this questionnaire, please e-mail or call Nathan Anderson
at AndersonN@gao.gov or (206) 287-4804 or Arvin Wu at WuA@gao.gov or (206) 287-4793. If you
experience any technical difficulties with the questionnaire, please call Jenny Chanley at
ChanleyV@gao.gov or (202) 512-4801 or Monica Wolford at WolfordM@gao.gov or (202) 512-2625.
We recommend reading through the survey once before answering the questions so you have a
clear idea of the broad range of questions you will be asked.
Thank you for your cooperation.

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Appendix II
Survey of Selected Stakeholders on Recycling
Used Electronics

DRAFT
Contact information
Please provide the following contact information in the event we need to clarify a response.
Name:
Title:
Organization:
Phone Number:
Address:
Email Address:
Preferred means of contact:
Background
1. Which of the following type of organization are you primarily affiliated with? (Select one.)
Federal government ......................................
State government ..........................................
Local government .........................................
Trade organization ........................................
Environmental organization .........................
Electronics recycler ......................................
Retailer .........................................................
Original equipment manufacturer .................
Other .............................................................

¨ Please specify:

2. Briefly, what is your organization’s interest and role in managing used electronics?

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Appendix II
Survey of Selected Stakeholders on Recycling
Used Electronics

DRAFT
Factors that may affect recycling
We would like to know, in your professional opinion, the extent to which the following factors may affect
domestic recycling of used electronics.
Public awareness
3. In general, how aware do you feel the public is of recycling options for used electronics (such as
whether a product is recyclable or how to get it to a recycler)?
Extremely aware ............................
Very aware .....................................
Moderately aware ...........................
Slightly aware ................................
Not at all aware ..............................
--------------Don’t know ....................................

4. To what extent, if at all, does the current level of public awareness of recycling options for used
electronics discourage recycling?
Very great extent ............................
Great extent ....................................
Moderate extent ..............................
Little extent ....................................
No extent ........................................
--------------Don’t know or no opinion ..............
If you wish, describe the basis for your answer:

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Appendix II
Survey of Selected Stakeholders on Recycling
Used Electronics

DRAFT
Collection
5. In general, for households across the nation, do you feel that the existing waste collection
infrastructure, such as municipal curbside collection programs, is adequate to facilitate recycling of
used electronics?
Yes .................................................
No ...................................................
--------------Don’t know ....................................

6. In your professional opinion, to what extent, if at all, are existing collection options for recycling used
electronics convenient for households?
Very great extent ............................
Great extent ....................................
Moderate extent ..............................
Little extent ....................................
No extent ........................................
--------------Don’t know or no opinion ..............

7. What are the most important challenges to facilitating the recycling of used electronics facing the
existing waste collections infrastructure?

Exports and Prison Labor

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Appendix II
Survey of Selected Stakeholders on Recycling
Used Electronics

DRAFT
8. In your professional opinion, to what extent, if at all, does the option to export used electronics reduce
the viability of the private domestic recycling infrastructure?
Very great extent .........................................
Great extent .................................................
Moderate extent ...........................................
Little extent .................................................
No extent .....................................................
--------------Don’t know or no opinion ...........................
If you wish, describe the basis for your answer:

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Appendix II
Survey of Selected Stakeholders on Recycling
Used Electronics

DRAFT
9. In your professional opinion, would restricting exports of used electronics to certified processors
overseas encourage greater recycling in the U.S.?
Yes ..............................................................
No ................................................................
--------------Don’t know or no opinion ...........................
If you wish, describe the basis for your answer:

10. What types of used electronics should be allowed to be exported to non-OECD developing nations?
Working units ................................................................................
Non-working whole units ..............................................................
Circuit boards ................................................................................
CRT glass cullet ............................................................................
Hazardous commodities (e.g., hazardous metals) .........................
Non hazardous commodities (e.g., non hazardous plastics) ..........
None at all .....................................................................................
--------------Don’t know or no opinion .............................................................
If you wish, describe the basis for your answer:

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Appendix II
Survey of Selected Stakeholders on Recycling
Used Electronics

DRAFT
11. To what extent, if at all, does the option to use prison labor diminish the viability of the private
domestic recycling infrastructure?
Very great extent ............................
Great extent ....................................
Moderate extent ..............................
Little extent ....................................
No extent ........................................
--------------Don’t know or no opinion ..............
If you wish, describe the basis for your answer:

12. Should prison industries, as currently operated, be allowed to compete with the private sector for nongovernment business in the area of used electronics recycling?
Yes .................................................
No ...................................................
--------------Don’t know or no opinion ..............

If you wish, describe the basis for your answer:

13. Are there any other issues regarding exports and prison labor that diminish the viability of the
domestic recycling infrastructure?
Yes
...............................
Î
No .........................

Please describe these other issues :

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Appendix II
Survey of Selected Stakeholders on Recycling
Used Electronics

DRAFT
Recycling/processing
14. To what extent, if at all, does the way in which electronic products are currently designed discourage
recycling?
Very great extent ............................
Great extent ....................................
Moderate extent ..............................
Little extent ....................................
No extent ........................................
------------Don’t know ....................................

15. Some electronic products contain toxic materials that require special handling and processing when
recycled. Does this discourage recycling of used electronics?
Yes .................................................
No ...................................................
------------Don’t know or no opinion ..............

16. We have been told that some used electronics are difficult to manually disassemble. Does this
discourage recycling?
Yes ..................................................
No ...................................................
------------Don’t know or no opinion ..............
If you wish, describe the basis for your answer:

17. Are there other issues regarding product design that discourage recycling?
Yes
...............................
Î

Please describe these other issues :

No .........................

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Appendix II
Survey of Selected Stakeholders on Recycling
Used Electronics

DRAFT
Other issues
18. In your professional opinion, to what extent, if at all, do unacceptable or potentially illegal activities
occur in the recycling industry? (By unacceptable or potentially illegal activities, we mean activities
such as recyclers “dumping” the used electronics they collect or “disposing” of them in ways other
than advertised.)
Very great extent ............................
Great extent ....................................
Moderate extent ..............................
Little extent ....................................
No extent ........................................
------------Don’t know ....................................

19. Other than the issues discussed above (i.e., product design, exporting and prison labor options,
collection, and public awareness), are you aware of any other factors that affect the recycling of used
electronics domestically?
Yes
...............................
Î
No
...............................

Please describe these other issues :

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Appendix II
Survey of Selected Stakeholders on Recycling
Used Electronics

DRAFT
Historic, Orphan, and Future Waste
20. In your professional opinion, who should pay for recycling historic waste? (By historic waste, we
mean used electronics that are in storage and have not yet been disposed of or recycled.) (Select one.)
Producers ........................................
Users/consumers ............................
Taxpayers .......................................
Other ...............................................
--------------Don’t know or no opinion ..............

Î Please identify:

If you wish, describe the basis for your answer:

21. In your professional opinion, who should pay for recycling orphan waste? (By orphan waste, we
mean used electronics whose manufacturers no longer exist.) (Select one.)
Producers ........................................
Users/consumers ............................
Taxpayers .......................................
Other ...............................................
--------------Don’t know or no opinion ..............

Î Please identify:

If you wish, describe the basis for your answer:

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Appendix II
Survey of Selected Stakeholders on Recycling
Used Electronics

DRAFT
22. In your professional opinion, which financing system will be most effective at recycling historic and
orphan waste? (By ARF, we mean a fee imposed on consumers when they purchase a product that is
used to recycle other used electronics. By extended producer responsibility, we mean that a
manufacturer charges an invisible fee, and the price of the product covers all the costs involved in
taking back and recycling their product at its end-of-life.)
Advanced recovery fee (ARF) .......
Extended producer responsibility ...
General tax base funding ................
Other ...............................................
--------------Don’t know or no opinion ..............

Î Please identify:

If you wish, describe the basis for your answer:

23. In your opinion, what financing system would be most effective at recycling future wastes? (By
future wastes, we mean products that are being sold, or will be sold, but will someday become
wastes.)
Advanced recovery fee (ARF) .......
Extended producer responsibility ...
General tax base funding ................
Other ...............................................
--------------Don’t know or no opinion ..............

Î Please identify:

If you wish, describe the basis for your answer:

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Appendix II
Survey of Selected Stakeholders on Recycling
Used Electronics

DRAFT
Potential federal legislation
24. Should national legislation be enacted to overcome the factors that discourage recycling?
Yes .................................................
No ...................................................
--------------Don’t know ....................................
25. In the absence of national legislation, which sector(s) should take the lead in the voluntary efforts to
encourage recycling of used electronics? (Select all that apply.)
Private sector/industry ..............................................
Public sector/government .........................................
Non-profit sector/environmental organizations .......
Other sector(s) ..........................................................
None of the above ....................................................

Î Please specify:

If you wish, describe the basis for your answer:

26. If enacted, which of the following provisions should national legislation include? (Select one in each
row.)
Yes

No

No opinion

d

d

d

a. Disposal bans.............................................................................................................
b. Export restrictions .....................................................................................................
c. Toxic constituent restrictions ....................................................................................
d. Universal waste designation under RCRA for used electronics (to aid in collection
and transportation).....................................................................................................
e. Tax credits or subsidies for recyclers/processors .....................................................
f. Tax credits or subsidies for manufacturers who used recycled materials..................
g. Certification requirements for recyclers/processors ..................................................
h. Requirement that federal agencies purchase environmentally friendly electronics...
i. Consumer education programs ..................................................................................
j. Other – Specify:

..............................................................................................

27. If enacted, which, if any, of the following financing mechanisms should national legislation include?
(Select one)
Advanced recycling fee (ARF) .................................

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Appendix II
Survey of Selected Stakeholders on Recycling
Used Electronics

DRAFT
Extended producer responsibility (EPR)...................
ARF/EPR hybrid .......................................................
End-of-life fees .........................................................
General tax base funding...........................................

28. How effective would the following implementation scenarios be for funding recycling of historic and
orphan used electronics and future used electronics?(Select one answer in each row.)
Very
effectiv
e

Somewha
t effective

d

d

Neither
effective
nor
ineffective
d

Somewha
t
ineffectiv
ed

Not at
all
effectiv
ed

No
opinion
d

a. ARF collected at retail level and managed
by the federal government (covering
collection, transportation, and recycling) .......
b. ARF collected at retail level and managed
by a third-party organization (covering
collection, transportation, and recycling) ........
c. ARF/EPR hybrid: ARF for historic waste
with a transition to EPR after “X” years..........
d. ARF for collection/transportation of used
electronics, and EPR for
recycling/processing ........................................
e. EPR with market share divisions for orphan
waste................................................................
f. EPR with retroactive liability for historic
waste................................................................
g. End of life fees ................................................
h. Local tax base funding for
collection/transportation, and EPR for
recycling/processing ........................................
i. Deposit/refund for collection/transportation,
and EPR for recycling .....................................
j. Deposit/refund .................................................
k. Other – Specify:

....................................

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Appendix II
Survey of Selected Stakeholders on Recycling
Used Electronics

DRAFT
29. How willing would you (the organization or entity you represent) be to operate within the various
financing scenarios? (Select one answer in each row.)

Very
willing

Somewh
at willing

Neither
willing
nor
unwillin
g

d

d

d

Somewh
at
unwillin
g

Not at all
willing

No
opinion

d

d

d

a. ARF collected at retail level and managed
by the federal government (covering
collection, transportation, and recycling).......
b. ARF collected at retail level and managed
by a third-party organization (covering
collection, transportation, and recycling).......
c. ARF/EPR hybrid: ARF for historic waste
with a transition to EPR after “X” years........
d. ARF for collection/transportation of used
electronics, and EPR for
recycling/processing ......................................
e. EPR with market share divisions for
orphan waste ..................................................
f. EPR with retroactive liability for historic
waste ..............................................................
g. End of life fees...............................................
h. Local tax base funding for
collection/transportation, and EPR for
recycling/processing ......................................
i. Deposit/refund for collection/
transportation, and EPR for recycling............
j. Deposit/refund ...............................................
k. Other – Specify:

..................................

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Appendix II
Survey of Selected Stakeholders on Recycling
Used Electronics

DRAFT
EPA’s management of used electronics
The Environmental Protection Agency’s Office of Solid Waste (OSW) developed shared responsibility
pilots, for example, under the “Plug-In to eCycling” campaign to help demonstrate the kinds of voluntary
partnerships that can significantly increase recycling of used electronics in the United States.
Additionally, EPA sponsored the Federal Electronics Challenge (FEC), which encourages federal
agencies to procure environmentally responsible electronic products. The FEC aims to promote energy
star features, extend the life span of electronic equipment, expand the recycling infrastructure for
electronics, and reduce the volume and toxicity of used electronics.

30. In your opinion, to what extent, if at all, have EPA efforts (such as Plug-In to eCycling and its pilots)
encouraged recycling of used electronics?
Very great extent ............................
Great extent ....................................
Moderate extent ..............................
Little extent ....................................
No extent ........................................
--------------Don’t know or no opinion ..............
31. Given that the federal government purchases nearly $60 billion worth of electronics equipment
annually, to what extent, if at all, would practices such as “green” product design and the recycling of
used electronics be encouraged if federal agencies were required to procure electronic products that
meet the goals of the Federal Electronics Challenge?
Very great extent ............................
Great extent ....................................
Moderate extent ..............................
Little extent ....................................
No extent ........................................
--------------Don’t know or no opinion ..............
32. In your opinion, to what extent, if at all, have the following factors hindered EPA’s ability to
encourage recycling of used electronics? (Select one answer in each row.)
Very
great
extent

Great
extent

Moderate
extent

Some
extent

No
extent

Don’t
know or
no
opinion

d

d

d

d

d

d

a. Lack of program goals..................................
b. Lack of performance measures for pilot
programs.......................................................
c. Lack of data on quantity of used
electronics ....................................................
d. Lack of legislative authority.........................
e. Other – Please identify:

....................

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Appendix II
Survey of Selected Stakeholders on Recycling
Used Electronics

DRAFT
If you wish, describe the basis for your answer:

33. In your opinion, how can EPA improve its effectiveness in encouraging recycling of used electronics?

International efforts
34. In your opinion, to what extent, if at all, will the Waste Electrical and Electronic Equipment (WEEE)
Directive facilitate collection, transportation, and processing of used electronics in the E.U.?
Very great extent ..............................
Great extent ......................................
Moderate extent ...............................
Little extent ......................................
No extent .........................................
--------------Don’t know or no opinion ................
If you wish, describe the basis for your answer:

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Appendix II
Survey of Selected Stakeholders on Recycling
Used Electronics

DRAFT
35. In your opinion, to what extent, if at all, will the Restriction of Hazardous Substances in Electrical
and Electronic Equipment (RoHS) Directive encourage “green” product design in the E.U.?
Very great extent ............................
Great extent ....................................
Moderate extent ..............................
Little extent ....................................
No extent ........................................
--------------Don’t know or no opinion ..............
If you wish, describe the basis for your answer:

Health and Environmental Problems
36. In your opinion, to what extent, if at all, are the following health and/or environmental problems
associated with the disposal of used electronics in the U.S.? (Select one answer in each row.)
Very
great
extent

Great
extent

Moderate
extent

Some
extent

No
extent

Don’t
know or
no opinion

d

d

d

d

d

d

a. Leaching of toxic substances from a municipal
landfill into groundwater or surface water................
b. Toxic emissions from incinerators............................
c. Worker exposure to toxic substances at
electronics disassembly facilities..............................
d. Volume of wastes in municipal landfills ..................
e. Loss of natural resources ..........................................
f. Other – Identify:

............................................

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Appendix II
Survey of Selected Stakeholders on Recycling
Used Electronics

DRAFT
37. Please indicate which problem from the prior question you think is the most significant problem
associated with the disposal of used electronics in the U.S., and if you wish, describe why.

38. If you have any other comments that you would like to share with us concerning any issue related to
the recycling of used electronics, please use the space below.

Thank you very much for your help.

Please save this file now and send an e-mail with your saved questionnaire file as an
attachment to EWasteSurvey@gao.gov.

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Appendix III

Comments from the Environmental
Protection Agency

Page 55

Appendx
iI

GAO-06-47 Electronic Waste

Appendix III
Comments from the Environmental
Protection Agency

Page 56

GAO-06-47 Electronic Waste

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)

Page 57

Appendx
iIV

GAO-06-47 Electronic Waste

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