Testimony 

Before the Subcommittee on Superfund 

and Waste Management, Committee on 

Environment and Public Works, U.S. 

Senate

United States Government Accountability Office

GAO

For Release on Delivery 

Expected at 2:30 p.m. EDT 

Tuesday, July 26, 2005 ELECTRONIC WASTE

Observation on the Role of 

the Federal Government in 

Encouraging Recycling and 

Reuse 

Statement of John B. Stephenson, Director 

Natural Resources and Environment 

GAO-05-937T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-937T.

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. 

Highlights of GAO-05-937T, a testimony 

before the Subcommittee on Superfund 

and Waste Management, Committee on 

Environment and Public Works, United 

States Senate 

July 26, 2005

ELECTRONIC WASTE

Observations on the Role of the Federal 

Government in Encouraging Recycling 

and Reuse 

Available estimates suggest that the amount of used electronics is large and 

growing, and that 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 are either 

recycled, reused, disposed of in landfills, or stored by users in places such as 

basements, garages, and company warehouses. Available data suggest that 

most used electronics are probably stored. The units still in storage have the 

potential to be recycled and reused, or disposed in landfills; or, they may be 

exported for recycling or reuse overseas. If disposed of in landfills, valuable 

resources, such as copper, gold, and aluminum, are lost for future use. 

Additionally, standard regulatory tests show that some toxic substances with 

known adverse health effects, such as lead, have the potential to leach from 

discarded electronics into landfills. Although one study suggests that this 

leaching does not occur in modern U.S. landfills, it appears that many used 

electronics end up in countries without either modern landfills or with 

considerably less protective environmental regulations. 

Economic factors, such as cost, 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 their used electronics 

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. Recyclers and refurbishers 

charge these fees because costs associated with their processes outweigh 

the revenue received from recycled commodities or refurbished units. In 

addition to the challenges posed by these economic factors, federal 

regulatory requirements provide little incentive for environmentally 

preferable management of used electronics. The governing statute, the 

Resource Conservation and Recovery Act, regulates the disposal practices of 

large generators of hazardous waste (including electronic waste) but 

exempts individuals and households from these requirements. 

In the absence of a national framework for dealing with the problem, a 

patchwork of potentially conflicting state requirements appears to be 

emerging. Manufacturers in one state, for instance, may have an advance 

recovery fee placed on their products, but the same manufacturers may have 

to take back their products and pay for recycling in another. This patchwork 

may be placing a substantial burden on recyclers, refurbishers, and other 

stakeholders. As GAO concludes its work, it will examine the implications of 

these findings for the ongoing efforts among the states to deal with this 

growing problem, for the various legislative solutions that have been 

proposed to create a uniform national approach, and for options the federal 

government can pursue to encourage recycling and reuse of electronics. 

Advances in technology have led to 

rapidly increasing sales of new 

electronic devices, particularly 

televisions, computers, and 

computer monitors. With this 

increase comes the dilemma of 

how to manage these products 

when they come to the end of their 

useful lives. Concerns have been 

increasingly expressed that while 

millions of existing computers 

become obsolete each year, only a 

fraction of them are being recycled. 

Some have alleged that the disposal 

of used electronics causes a 

number of environmental 

problems. They note, for example, 

that toxic substances such as lead 

can leach from used electronics. 

They have also noted that 

computers and other electronic 

equipment contain precious metals 

that require substantial amounts of 

energy and land to extract. These 

metals, they say, can often be 

extracted with less environmental 

impact from used electronics than 

from the environment. 

In this testimony, GAO summarizes 

existing information on the 

amounts of, and problems 

associated with, used electronics. 

GAO also examines the factors 

affecting the nation’s ability to 

recycle and reuse electronics when 

such products have reached the 

end of their useful lives. 

This testimony discusses 

preliminary results of GAO’s work. 

GAO will report in full at a later 

date. 
Page 1 GAO-05-937T 

Mr. Chairman and Members of the Subcommittee: 

Thank you for the opportunity to discuss our work to date on the issues 

surrounding the growing volume of used electronics accumulating in the 

nation’s basements, attics, and landfills. Rapid advancements 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 come to 

the end of their useful lives. The Environmental Protection Agency (EPA) 

has estimated that in 2003 alone, about 50 million existing computers 

became obsolete, but one estimate forecast that less than 6 million were 

recycled. 

Disposal of used electronics creates potential problems that can be 

averted through recycling or reuse. For example, concerns have been 

raised because toxic substances such as lead, which have welldocumented adverse health effects, can potentially leach from used 

electronics. Concerns have also been raised over used electronics that are 

exported from the United States to countries with less stringent 

environmental regulations. In addition, computers contain precious 

metals, such as gold, silver, and platinum, that 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. 

In this context, you and several other Members of the Congress asked that 

we address a number of issues surrounding this problem. Specifically, we 

were asked to (1) summarize existing information on the volumes of, and 

problems associated with, used electronics and (2) examine the factors 

affecting the nation’s ability to recycle and reuse electronics when such 

products have reached the end of their useful lives. 

To address these issues, we are examining studies that provide nationwide 

estimates on the amount of used electronics,1

 as well as federal and state 

 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. 
Page 2 GAO-05-937T 

government studies (including those by EPA and task forces in Oregon 

and Washington), industry and interest group studies, and local studies 

(including municipal solid waste characterization studies) that discuss the 

problems associated with used electronics. We are also visiting states and 

localities that have implemented programs or passed legislation to 

responsibly manage used electronics, including California, Maine, 

Maryland, Massachusetts, Oregon, and Washington. In addition, we are 

surveying participants in the National Electronics Product Stewardship 

Initiative and other key stakeholders, which include key stakeholders from 

federal, state, and local governments, environmental organizations, 

recyclers, retailers, equipment manufacturers, and academicians. To date, 

we have received responses from 41 of the 53 survey participants. We are 

also comparing current government and industry practices with existing 

practices for promoting recycling in other industries, such as bottle- and 

can-recycling programs and the Rechargeable Battery Recycling 

Corporation program. Further, we are examining EPA-sponsored federal, 

state, and local pilot programs that attempt to encourage recycling of 

electronic products. Our work is being done in accordance with generally 

accepted government auditing standards, which include an assessment of 

data reliability and internal controls. 

We are here to present our preliminary observations on these issues. We 

will report the final results of our study and any recommendations we may 

develop at a later date. In summary: 

• Available estimates suggest that the volume of used electronics is large 

and growing and that 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 either recycled, reused, disposed of in landfills, or stored 

by users in places such as basements, garages, and company warehouses. 

Available data suggest that most used electronics are probably stored. 

These units have the potential to be recycled and reused, disposed of in 

landfills, or exported for recycling and reuse 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. 

Additionally, standard regulatory tests show that some 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 the environmental 

regulations comparable to the U.S. 
Page 3 GAO-05-937T 

• Both economic and regulatory factors discourage recycling and reuse of 

used electronics: 

• 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. Consumers in Snohomish County, Washington, 

for instance, may have to travel more than an hour to the nearest dropoff 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 averagesized 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 provide little incentive for 

environmentally preferable management of used electronics. The 

governing statute, the Resource Conservation and Recovery Act, bars 

entities that dispose of more than 220 pounds of hazardous waste per 

month from depositing hazardous waste (including some used 

electronics) in landfills. However, RCRA does not prohibit households 

and entities that generate less than 220 pounds of hazardous waste per 

month from sending hazardous waste to municipal landfills. 

Consequently, since only four states currently ban disposal of used 

electronics in their trash or local landfill, 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, 

available data suggest that states and localities that do not have landfill 

bans have dramatically lower levels of recycling than the four states 

that have enacted landfill bans. In addition, federal regulations provide 

for neither a financing system for responsible management of used 

electronics, nor oversight of these products when exported—a 

particular problem in the case of some developing countries, where 

risks to the environment and human health may be more likely because 

of less stringent environmental regulations. 
Page 4 GAO-05-937T 

In the absence of a national approach, a patchwork of potentially 

conflicting state requirements is developing. This patchwork may be 

placing a substantial burden on recyclers, refurbishers, and other 

stakeholders. As we conclude our work, we will be examining the 

implications of our findings for the ongoing efforts among the states to 

deal with the problem, for the various legislative solutions that have been 

proposed to create a uniform national approach, and for options the 

federal government can pursue to encourage recycling and reuse of used 

electronics. 

Few people are aware of recycling options for their old televisions and 

personal computers. Because of the perceived value of used electronics, 

some pass their used equipment to family members or friends before 

eventually storing these units in their attics, basements, or garages. 

Eventually, though, consumers need to dispose of these units in some 

manner. By choosing to have these products recycled, consumers ensure 

the recovery of resources like copper, iron, aluminum, and gold, which 

would otherwise be procured through less environmentally friendly 

practices such as mining. Likewise, consumers who choose to recycle also 

reduce the amount of waste entering the nation’s landfills and 

incinerators. Since used electronics typically contain toxic substances like 

lead, mercury, and cadmium, recycling or refurbishing will prevent or 

delay such toxic substances from entering landfills. 

The Congress affirmed its commitment to reducing waste and encouraging 

recycling, first through enactment of the Resource Conservation and 

Recovery Act (RCRA) of 1976, and then again with passage of the 

Pollution Prevention Act of 1990. Both RCRA and the Pollution Prevention 

Act address alternatives to waste disposal. RCRA promotes the use of 

resource recovery, either through facilities that convert waste to energy or 

through recycling. To promote recycling, RCRA required EPA to develop 

guidelines for identifying products that are or can be produced with 

recovered materials. RCRA also requires federal agencies to procure items 

that are, to the maximum extent practicable, produced with recovered 

materials. The Pollution Prevention Act provides 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. It 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 on September 14, 1998, 

also affirmed the federal government’s commitment to encourage 

recycling by directing federal agencies to consider procuring products 

Background 
Page 5 GAO-05-937T 

that, among other things, use recovered materials, can be reused, facilitate 

recycling, and include fewer toxic substances. 

Nonetheless, while large-quantity generators, such as businesses, schools, 

and government agencies, must treat some used electronics as hazardous 

waste due to the relatively high level of toxic substances, it is not illegal 

for households or for small quantity generators—non-household entities 

disposing of less than 220 pounds per month—to dispose of used 

electronics in landfills in most states. Under RCRA, household hazardous 

wastes, including used electronics, may be disposed of at municipal solid 

waste landfills. However, some states have begun imposing more stringent 

disposal requirements for used electronics. For example, because of 

concerns regarding the potential environmental and health effects of 

leaded glass in cathode ray tubes (CRTs), California, Maine, 

Massachusetts, and Minnesota recently banned them from disposal in 

municipal landfills. 

As national awareness of potential problems associated with the disposal 

of used electronics has grown, EPA has taken steps to encourage recycling 

of used electronics. For instance, EPA, together with electronics 

manufacturers, retailers, and recyclers, sponsored several pilot programs 

in 2004 to measure the success of convenient collection options for used 

electronics. Other recent EPA efforts, such as the Federal Electronics 

Challenge and the Electronic Product Environmental Assessment Tool 

(EPEAT) program, attempt to leverage U.S. government procurement 

power to drive environmentally preferable design for electronic products. 

Finally, through the establishment of the National Electronic Product 

Stewardship Initiative (NEPSI) in 2001, EPA established a voluntary, multistakeholder initiative to reach consensus on a national approach to 

encourage recycling of used electronics. This voluntary effort ultimately 

dissolved in 2005 without agreement, however, because stakeholders 

could not reach consensus on a nationwide financing system. 
Page 6 GAO-05-937T 

The information we have reviewed to date 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 would become obsolete in 2003—a three-fold 

increase over the 33 million obsolete computers and monitors in 1997.2

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 CRT technology is replaced by new 

technologies such as plasma screens.3

Thus far, it appears that relatively few units have found their way into 

either landfills or recycling centers. Available EPA data indicate that less 

than 4 million monitors and 8 million televisions are disposed of annually 

in U.S. landfills—only a fraction of the amount estimated to become 

obsolete annually, according to EPA. 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 units that are obsolete (or becoming obsolete), and 

the quantity either in landfills or sent to recycling centers, suggests that 

most used electronics are still in storage—such as attics, basements, and 

garages—and that their ultimate fate is still not certain, 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. Further, 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 

 2

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. 

3

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. 

Volume of Used 

Electronics and the 

Problems They Pose 
Page 7 GAO-05-937T 

lower levels of harmful elements common to ores, such as arsenic, 

mercury, and sulfur.4

 The research we have thus far 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 a 

computer’s life can be saved through reuse instead of producing a new 

unit from raw materials.5

Regarding the issue of toxicity, the research we have reviewed to date is 

unclear on the extent to which toxic substances may leach from used 

electronics in landfills. On one hand, according to a standard regulatory 

test RCRA requires to determine whether a solid waste is hazardous and 

subject to federal regulation, lead (a substance with known adverse health 

affects) leaches from some used electronics under laboratory conditions. 

Tests conducted at the University of Florida indicate that lead leachate 

from computer monitors and televisions with cathode ray tubes exceeds 

the regulatory limit and, as a result, could be considered hazardous waste 

under RCRA.6

 On the other hand, the study’s author told us that these 

findings are not necessarily predictive of what could occur in a modern 

landfill. Furthermore, a report by the Solid Waste Association of North 

America 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.7

 4

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 have not yet reviewed this study, this data should be used with caution. 

5

The United Nations University is a think tank for the United Nations and is not a degree 

granting university. 

6

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 we have not yet 

reviewed this study, these estimates should be used with caution. 

7

Solid Waste Association of North America, The Effectiveness of Municipal Solid Waste 

Landfills in Controlling Releases of Heavy Metals to the Environment (2004). Because we 

have not yet reviewed this study, this data should be used with caution. 
Page 8 GAO-05-937T 

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 often inconvenient locations to 

have them recycled or refurbished for reuse. Recyclers and refurbishers 

charge fees to cover the costs of their operations. In most states, 

consumers have an easier and cheaper alternative—they can take them to 

the local landfill. These easy and inexpensive alternatives help explain 

why so little recycling of used electronics has thus far taken place in the 

United States. 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. 

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. For example, transfer stations in Snohomish County, 

Washington, charge consumers between $10 and $27 per unit for collecting 

used electronics and transporting them to recyclers. Moreover, such 

transfer stations are generally not conveniently located, and rural 

residents, such as those in Snohomish County, may need to drive more 

than an hour to get to the nearest drop-off station.8

 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 the consumer 

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 

 8

Over 70 percent of the survey respondents felt that existing collection options for 

recycling used electronics were inconvenient for households. 

Economic and 

Regulatory Factors 

Deter Recycling and 

Reuse of Used 

Electronics 

Cost and Consumer 

Inconvenience Discourage 

Recycling and Reuse of 

Used Electronics 
Page 9 GAO-05-937T 

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.9

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 their 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. 

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 machinery is being used to 

process the relatively limited supply of used electronics being recycled in 

the United States. The firm’s officials noted that in Europe, by contrast, 

where manufacturers are required to take financial responsibility for the 

disposal of their products, the increased supply of recyclable electronics 

 9

This point is further underscored by our interviews with 8 electronics recyclers, who were 

unanimous in emphasizing that they could not cover costs without charging fees. 
Page 10 GAO-05-937T 

has decreased the firm’s per-unit processing costs and increased the 

profitability of recycling used electronics. 

Finally, recyclers incur additional expenses when handling and disposing 

of toxic components (such as batteries) and toxic constituents (such as 

lead), which are all commonly found in used electronics. These expenses 

include removing the toxic components and constituents from the 

product, as well as handling and processing them as hazardous material. 

Once separated from the product, these wastes are considered hazardous 

wastes and are 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. Since CRT manufacturing is declining in 

the United States, some recyclers send their CRT glass to a lead smelter in 

Missouri that charges recyclers for their CRT glass. 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.10

Refurbishers charge similar fees to cover the costs involved in 

guaranteeing data security by “wiping” hard drives, upgrading systems, 

installing software, and testing equipment. A program manager for a 

nonprofit technology assistance provider told us that it generally costs 

about $100 to refurbish a Pentium III computer system, plus an additional 

licensing fee of about $80 for an operating system. 

To encourage used electronics recycling, EPA sponsored pilot programs 

that addressed the cost and inconvenience issues. Office Depot and 

Hewlett-Packard, for example, partnered to provide free take-back of used 

electronics at Office Depot retail stores. Collected used electronics were 

sent 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. 

 10Boon, 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). Because we have not yet reviewed this study, this data should be used with 

caution. 
Page 11 GAO-05-937T 

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 little to preclude electronic products generated in the 

United States from being exported and subsequently threatening human 

health and the environment overseas. While several promising federal 

initiatives supporting electronics recycling have been launched, their 

voluntary nature makes their success uncertain. 

Regulation of used electronics at the federal level 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. However, households and small quantity generators are 

exempt from many RCRA regulations, thus allowing them to deposit their 

used electronics in municipal solid waste landfills—even though cathode 

ray tubes 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 it lacks 

the authority to require environmentally preferable management of used 

electronics through recycling and reuse or to establish a mandatory 

national approach, such as a disposal ban. As a result, all of the office’s 

efforts with regard to the recycling of used electronics are voluntary. 

In response to RCRA’s exemption for household hazardous waste and the 

growing volume of obsolete electronics within their boundaries, four 

states—California, Maine, Massachusetts, and Minnesota—recently 

banned from landfills some used electronics.11 Our preliminary work 

suggests that such bans 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 told us that their states have seen substantial increases in used 

electronics recycling. One international electronics recycler, for instance, 

 11The landfill bans in Maine and Minnesota take full effect in 2006. 

Federal Regulatory 

Framework Governing 

Used Electronics Provides 

Little Incentive for 

Recycling or Reuse 

Hazardous Used Electronics 

Are Allowed in Municipal 

Landfills 
Page 12 GAO-05-937T 

set up recycling facilities in the San Francisco area in 2003 because of the 

large volume of used electronics that were no longer being disposed of in 

landfills. In Massachusetts, an official with the Department of 

Environmental Protection told us that six businesses dedicated to 

electronics recycling were created following the enactment of a landfill 

ban. Finally, about 75 percent of the survey respondents to date said that a 

national disposal ban should be enacted to overcome the economic and 

regulatory factors that discourage recycling and reuse of used electronics. 

Given the inherent economic disincentives to recycle used electronics, we 

found widespread agreement among our survey respondents and others 

we contacted that the establishment of some type of financing system is 

critical to making recycling and reuse sufficiently inexpensive and 

convenient to attract the participation of consumers. For instance, almost 

90 percent of survey respondents believe that either an advanced recycling 

fee (ARF), extended producer responsibility (EPR), or a hybrid of the two 

should be implemented if national solution is instituted. Yet despite broad 

agreement in principle, participants in the recent multi-stakeholder 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 for used electronics had sufficient capacity to recycle large 

volumes, consumers and large-quantity generators 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 20 cents per pound to collectors 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 

Experts Believe a National 

Financing System is Needed to 

Support Recycling 
Page 13 GAO-05-937T 

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 boundary, however, may 

prove difficult because the payout for used electronics may attract units 

originating in other states. Preventing this problem, they say, requires 

substantial documentation for each unit, and may require a substantial 

enforcement effort. 

While California’s ARF focuses on consumers of electronics, Maine’s 

approach focuses on producers. 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 their end 

of life—a strategy referred to as EPR. 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 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: they must still 

take their products to a consolidation point, and will still likely have to pay 

a fee. 

Several other states, as well as some countries, 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.12 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 manufacturer take-back programs. In 

Europe, the European Union implemented the Waste Electrical and 

Electronic Equipment Management Regulations in July 2004, which 

requires producers of electronic products to be financially responsible for 

the recycling or reuse of their products at end of life. In our final report, 

 12An 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. 
Page 14 GAO-05-937T 

we will provide a more complete examination of various strategies for 

financing environmentally preferable management of used electronics. 

The lack of oversight over exports of used electronics could also 

discourage environmentally preferable management of used electronics. In 

the United States, businesses, schools, government agencies, and other 

organizations, as well as households, face multiple options for their used 

electronics. In some instances, organizations and recyclers receive e-mails 

from brokers, who typically have partners in Asia, willing to pay them for 

their used electronics, regardless of whether they can be reused. For 

example, one broker requests up to 50,000 used monitors per month and 

does not require the monitors to be tested. Another broker specifically 

requests nonworking monitors and wanted to fill at least 10 containers, 

which equals anywhere from 6,000 to 11,000 units, depending on their size. 

One Seattle area recycler said that brokers such as these are probably not 

handling the units in environmentally preferable ways once the units are 

exported. Even so, one business we contacted said it regularly receives email requests such as these. 

Companies export used electronics because the largest markets for reused 

computers and computer parts are overseas, according to an EPA official. 

Likewise, demand is high for recycled commodities, which can be 

processed more cheaply due, in part, to lower wages and less stringent 

environmental requirements. Also, unlike their counterparts in some other 

developed countries, the United States officials have permitted the export 

of hazardous used electronics, such as CRT monitors and televisions, if the 

exporter asserts that the equipment is destined for reuse. While some 

environmental groups have called for a ban on exports of used electronics, 

the Congressional Research Service noted that such a ban would cut 

recyclers off from many of the markets able to reuse the materials.13

However, few safeguards are in place to ensure that exported used 

electronics are indeed destined for reuse.14 Used electronics that are 

destined for reuse are not considered to be waste subject to RCRA export 

regulations. Instead, such electronics are considered to be commodities, 

 13Congressional Research Service, Recycling Computers and Electronic Equipment: 

Legislative and Regulatory Approaches for “E-Waste,” (Washington, D.C.: 2003). 

14The following are generally not classified as solid wastes under RCRA: Used electronics 

for reuse, whole circuit boards, shredded circuit boards, if free of certain hazardous 

materials, metal from used electronics, and scrap metal. 

Oversight of Exported Used 

Electronics Is Limited 
Page 15 GAO-05-937T 

which means that they can be exported with little or no documentation, 

notification, and oversight. Nonetheless, instances have been recently 

documented in which environmental and human health threats have 

resulted from the less-regulated disassembly and disposal of U.S.-

generated used electronics overseas. For example, 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.15 Without the 

ability to track the exported units to importing countries, or to audit 

companies exporting used electronics, it is difficult to verify that exported 

used electronics are actually destined for reuse, or that they are ultimately 

managed responsibly once they leave U.S. shores. As our work continues, 

we will further examine the extent of the problems associated with 

irresponsible management of used electronics overseas. 

The federal government has taken some steps to affirm its commitment to 

encourage recycling of used electronics through the implementation of 

two voluntary programs sponsored by EPA. The Federal Electronics 

Challenge (FEC) and the Electronic Product Environmental Assessment 

Tool (EPEAT) both leverage U.S. government purchasing power to 

promote environmentally preferable management of electronic products 

from procurement through end of life. For example: 

• 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 their 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 the end of their useful lives. To 

date, 11 federal agencies and 26 individual federal facilities participate in 

the FEC to some extent. The Bonneville Power Administration (BPA) 

recently documented cost savings associated with its FEC participation. 

BPA noted, for example, that the program 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 told us 

 15The 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. 

Opportunities Exist for Federal 

Initiatives to Enhance 

Electronics Recycling 
Page 16 GAO-05-937T 

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 each monitor’s life. 

• The EPEAT program promotes environmentally preferable management of 

electronics by allowing large purchasers, such as government agencies, to 

compare and select laptop computers, desktop computers, and monitors 

with environmentally preferable attributes. For example, EPEAT evaluates 

an electronic product’s design 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. EPA expects EPEAT to be instituted in 2006, and products 

with higher environmental ratings could receive preferred consideration in 

federal procurement decisions. 

While we will continue to examine the FEC and EPEAT programs in 

greater detail, including how stakeholders say they might be improved, our 

preliminary work suggests that the federal government can build on these 

initiatives by using its purchasing power to lead markets for electronic 

products in environmentally friendly directions. In fact, there is ample 

precedent for such a strategy, perhaps most notably in EPA’s and the 

Department of Energy’s Energy Star program. In that program, the federal 

government partners with industry to offer businesses and consumers 

energy-efficient products that ultimately save money and protect the 

environment. 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. Part of Energy Star’s success can be attributed to 

federal actions, particularly those outlined in two executive orders that 

required federal agencies to purchase products equipped with Energy Star 

features. Since the federal government will spend over $60 billion on 

information technology products in fiscal year 2005, including televisions, 

computers, and computer monitors, it could go beyond the voluntary and 

limited FEC and EPEAT programs by broadening the programs’ scope and 

requiring agency participation in, or adherence to, some of the programs’ 

key practices. As with the Energy Star program, such actions may lead to 

cost savings and greater environmental protection. Of particular note, over 
Page 17 GAO-05-937T 

80 percent of the survey respondents to date said that federal government 

procurement criteria along the lines of FEC and EPEAT should be 

required, and about 95 percent of the survey respondents to date said that 

such procurement criteria would encourage environmentally preferable 

product design, as well as recycling and reuse. 

In our future work, we will continue to examine factors affecting recycling 

in greater detail, and the diverse efforts by individual states and others to 

deal with these issues. It is becoming clear, though, that in the absence of 

a national approach, a patchwork of potentially conflicting state 

requirements is developing, and that this patchwork may be placing a 

substantial burden on recyclers, refurbishers, and other stakeholders. 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. Further, a 

retailer may have to set up a system in one state to collect fees on specific 

products and, at the same time, set up a different system in another state 

to take back a particular manufacturer’s product. Hence, manufacturers 

we contacted said that while they had their preferences regarding, for 

instance, an ARF or EPR system, their main preference is to operate 

within a uniform national system that mandates a financing mechanism 

that preempts varying state requirements. Our preliminary survey results 

substantiate these views, with over 90 percent of survey respondents 

indicating that national legislation should be enacted and, if so, almost 90 

percent believe a financing mechanism should be included. 

Our future work will also discuss some of the options—both legislative 

and administrative—being considered to encourage environmentally 

preferable management of used electronics at a national level. Frequently 

cited options include disposal bans, consumer education programs, a 

variety of financing systems, export restrictions, and federal government 

procurement requirements. These options may offer suggestions for a 

uniform national approach and what aspects should be considered. 

Additionally, an examination of EPA’s voluntary programs—the FEC and 

EPEAT—may shed light on other, more effective options available to the 

federal government that can save money over electronic products’ life 

cycle; enhance environmental protection; drive markets for 

environmentally preferable product design; and establish a recycling 

infrastructure and markets for recycled commodities. 

Finally, with rapid advances in technology, particularly in consumer 

electronics, new products are reaching the marketplace with remarkable 

Observations on 

Federal Actions to 

Encourage Recycling 

and Reuse of Used 

Electronics 
Page 18 GAO-05-937T 

speed. Consequently, our future work will also examine the implications 

of these newer generations of electronics entering the nation’s waste 

stream. 

Mr. Chairman, this completes my prepared statement. I would be happy to 

respond to any questions you or other Members of this Subcommittee may 

have at this time. 

For further information, please contact John B. Stephenson at (202) 512-

3841 or stephensonj@gao.gov. 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, and Arvin Wu. 

Contact and 

Acknowledgments 

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