2000 Buy-Recycled Series

Miscellaneous Products

United States 

Environmental Protection 

Agency

EPA530-F-00-012

April 2000

www.epa.gov/cpg

Solid Waste

and Emergency Response

(5306W)

1EPA

More and more procurement

officials are realizing that

buying recycled is an easy, costefficient, and earth-friendly alternative.

Today’s products made from recycled

materials offer the strength, durability, and

performance equivalent to those made from

virgin material. That’s why businesses and public sector buyers

across the country are buying and using recycled products. This

fact sheet contains information on miscellaneous products that

contain recycled materials.

To make it easier to buy recycled, the U.S. Environmental

Protection Agency (EPA) updates the Comprehensive Procurement

Guidelines (CPG) every 2 years. Through the CPG, EPA designates

items that must contain recycled content when purchased by

federal, state, and local agencies, or by government contractors,

using appropriated federal funds. EPA’s research shows that the

items designated in the CPG are of high quality, widely available,

and cost-competitive with virgin products. EPA also issues

nonregulatory companion guidance—the Recovered Materials

Advisory Notice (RMAN)—that recommends levels of recycled

content for those items.

EcoPurchasing means

considering attributes 

such as

❖

recycled content

toxicity

reusability

durability

repairability

❖

before you buy 

a product.

2 Printed on paper that contains at least 30 percent postconsumer fiber.
The CPG

requires

federal

agencies to

buy items

made from

recovered

materials.

Recycling is more than just dropping

off your cans, bottles, and

newspapers at the curb or at a local

collection facility. Diverting recyclables

from the waste stream is only the first of

three steps in the recycling process. The

second step occurs when companies use

these recyclables to manufacture new

products. The third step comes when you

purchase products made from recovered

materials. That’s how we close the loop. 

To support markets for the materials

collected in recycling programs and to

help these programs expand, the Resource

Conservation and Recovery Act requires

agencies to buy recycled-content products

designated by EPA. In addition, President

Clinton signed Executive Order 13101 in

September 1998, which called for an

increase in the federal government’s use of

recycled-content and other environmentally preferable products.

Issued in May 1995, the first CPG

designated 19 new products and

incorporated five previously designated

items in seven product categories.

Procuring agencies are required to

purchase these items with recycled

content. The first CPG update (CPG II) was

published in November 1997, and

designated an additional 12 products

including pallets. A second CPG update

(CPG III) was published in January 2000,

and designated an additional 18 products

including sorbents, awards and plaques,

industrial drums, mats, manual-grade

strapping, and signage.

Procuring agencies include all federal

agencies, and any state or local government agency or government contractor

that uses appropriated federal funds to

purchase the designated items. If your

agency spends more than $10,000 per year

on a product designated in the CPG, you

are required to purchase it with the

highest recycled-content level practicable.

The CPG also applies to lease contracts

covering designated items.

Once designated, an agency has 1 year

to develop an affirmative procurement

program (or revise an existing one) for a

designated item it purchases. By November 13, 1998, agencies were required to

develop an affirmative procurement

program to incorporate buy-recycled

requirements for pallets. Agencies also

must revise their affirmative procurement

programs to add the miscellaneous

products designated in CPG III by January

19, 2001. This effort might involve

reviewing specifications for those items

and eliminating provisions that pose

barriers to procuring them with recycled

content (such as aesthetic requirements

unrelated to product performance).

The CPG acknowledges, however, that

specific circumstances might arise that

preclude the purchase of products made

with recovered materials. Your agency

may purchase designated items that do

not contain recovered materials if you

determine that: 1) the price of a given

designated item made with recovered

materials is unreasonably high, 2) there is

inadequate competition (not enough

sources of supply), 3) unusual and

unreasonable delays would result from

obtaining the item, or 4) the recycledcontent item does not meet the agency’s

reasonable performance specifications.

What Is The CPG?
1 EPA’s recommendations do not preclude a procuring agency from purchasing these items manufactured from another material. They

simply require that a procuring agency purchase these items made with recovered materials when these items meet applicable

specifications and performance requirements. 

2 Steel used in steel drums is manufactured using the Basic Oxygen furnace (BOF) process, which contains 25-30% total recovered

materials, of which 16% is postconsumer steel. Steel used in manual-grade strapping is manufactured using either the BOF process

or the Electric Arc Furnace (EAF) process, which contains 100% total recovered materials, of which 67% is postconsumer steel.

3 Plastic signs and sign posts are recommended for nonroad applications only, such as, but not limited to, trailway signs in parks and

directional/informational signs in buildings.

4 The recommended recovered materials content levels for steel in this table reflect the fact that the designated items can be made

from steel manufactured in either a Basic Oxygen Furnace (BOF) or an Electric Arc Furnace (EAF). Steel from the BOF process

contains 25-30% total recovered materials, of which 16% is postconsumer steel. Steel from the EAF process contains a total of 100%

recovered steel, of which 67% is postconsumer. 

5 “Wood” includes materials such as sawdust and lumber mill trimmings.

6 Examples of other organics include, but are not limited to, peanut hulls and corn stover. An example of multimaterial sorbents would

include, but not be limited to, a polymer and cellulose fiber combination.

Awards and Plaques

—Glass

—Wood

—Paper

—Plastic and Plastic/Wood Composites

Industrial Drums

—Steel2

—Plastic (HDPE)

—Fiber (paper)

Mats

—Rubber 

—Plastic

—Rubber/Plastic Composite

Pallets

—Wood

—Plastic

—Thermoformed

—Paperboard

Signage

—Plastic3

—Aluminum

—Plastic Sign Posts/Supports3

—Steel Sign Posts/Supports4

Sorbents

—Paper

—Textiles

—Plastics

—Wood5

—Other Organics/Multimaterials6

Manual-Grade Strapping

—Polyester

—Polypropylene

—Steel2

75–100% (postconsumer)/100% (total)

100% (total)

40–100% (postconsumer)

50–100% (postconsumer)/95–100% (total)

16% (postconsumer)/25–30% (total)

30–100% (postconsumer)

100% (postconsumer)

75–100% (postconsumer)/85–100% (total)

10–100% (postconsumer)/100% (total)

100% (postconsumer)

95–100% (postconsumer)

100% (postconsumer)

25–50% (postconsumer)

50% (postconsumer)

80–100% (postconsumer)

25% (postconsumer)

80–100% (postconsumer)

16% (postconsumer)/25–30% (total)

67% (postconsumer)/100% (total) 

90–100% (postconsumer)/100% (total)

95–100% (postconsumer)

25–100% (total)

100% (total)

100% (total)

50–85% (postconsumer)

10–40% (total)

16% (postconsumer)/25–30% (total)

67% (postconsumer)/100% (total)

How Do I Purchase Recycled-Content Products?

EPA issues guidance

in RMANs, which

are designed to

make it as easy as possible

to buy the designated

items. The RMAN recommends recycled-content

levels to look for when

purchasing miscellaneous

products, as shown in the

chart on this page. Following the RMANs’ recommended levels will help

ensure your affirmative

procurement program and

standards meet the buyrecycled requirements.

Rather than specifying

just one level of recycled

content, the RMANs recommend ranges that reflect

actual market conditions.

The recommendations are

based on market research

identifying recycledcontent products that are

commercially available,

are competitively priced,

and meet buyers’ quality

standards.

Refer to EPA’s availability list entitled “MiscellaneousProducts Containing

Recovered Materials” for

sources of the designated

miscellaneous items. See

the last section of this fact

sheet for this and other

helpful resources.

Miscellaneous Products1 Recovered Material Content

EPA’s Recommended Content Levels for Miscellaneous Products
How Can I Get More Information?

Information Available 

From EPA

This fact sheet and the following publications on

buying recycled-content products are available or

can be accessed in electronic format on the Internet at

<www.epa.gov/cpg>. Use Internet e-mail to order paper copies of

documents. Include the requestor’s name and mailing address on

all orders. Address e-mail to: rcra-docket@epamail.epa.gov. 

Paper copies also may be ordered by calling the RCRA

Hotline. Callers within the Washington Metropolitan Area must

dial 703 412-9810 or TDD 703 412-3323 (hearing impaired).

Long-distance callers may call 800 424-9346 or TDD 800 553-

7672. The RCRA Hotline operates weekdays, from 9:00 a.m. to

6:00 p.m., e.s.t.

❖ EPA Expands Comprehensive Procurement Guideline

(CPG) (EPA530-F-00-017). This fact sheet provides general

information about the CPG and the development of affirmative

procurement programs.

❖ Federal Register (FR) notices promulgating CPG I (60 FR

21370/EPA530-Z-95-006) and RMAN I (60 FR 21386/EPA530-

Z-95-007), May 1, 1995. FR notices promulgating CPG II (62

FR 60961/EPA530-Z-97-009) and RMAN II (62 FR 60975/

EPA530-Z-97-010), November 13, 1997. FR notices

promulgating CPG III (65 FR 3070) and RMAN III (65 FR

3082), January 19, 2000.

❖ Miscellaneous Products Containing Recovered Materials

(EPA530-B-99-010). This list identifies manufacturers and

suppliers of pallets.

❖ A Study of State and Local Government Procurement

Practices that Consider Environmental Performance of

Goods and Services (EPA742-R-96-007). This report provides

important program elements and case studies of state and

county agencies purchasing environmentally preferable

products and services. For a copy of the report or more

information on EPA’s Environmentally Preferable Purchasing

(EPP) program, contact the Pollution Prevention Information

Clearinghouse at 401 M Street, SW. (7409), Washington, DC

20460. Phone: 202 260-1023. Fax: 202 260-4659. Visit the

EPP Web site at <www.epa.gov/oppt/epp>.

Other Sources of

Information

❖Buy Recycled Business Alliance. The Alliance

includes over 3,200 companies and organizations

committed to increasing their use of recycled-content products and

materials in their day-to-day operations. The Alliance offers

educational materials, a quarterly newsletter, and product-specific

guides. Public purchasing entities can join for free. For more

information, contact Kevin Barry, National Recycling Coalition, 1727

King Street, Suite 105, Alexandria, VA 22314-2720. Phone: 703 683-

9025, Ext. 210. Fax: 703 683-9026. Web site: www.nrc-recycle.org 

E-mail: brbainfo@nrc-recycle.org

❖ U.S. General Services Administration (GSA). GSA publishes

various supply catalogs, guides, and schedules for recycledcontent products available through the Federal Supply Service. For

copies of the following document and other information, contact

GSA, Centralized Mailing List Service (7CAFL), 4900 Hemphill

Street, P.O. Box 6477, Fort Worth, TX 76115-9939. Phone: 

817 334-5215. Fax: 817 334-5561. You can also access GSA

Advantage!, GSA’s Internet-based online ordering system, to order

any GSA product at <www.fss.gsa.gov/cgi-bin/advwel>.

– Environmental Products Guide. This guide is designed to

help procurement officials identify environmentally

preferable products and services. It contains nearly 3,000

items, including many recycled-content products.

❖ Greening the Government: A Guide to Implementing

Executive Order 12873. This guide provides detailed information

on establishing and implementing federal affirmative procurement

plans. Updated in the summer of 1997, it is available without

charge from the Office of the Federal Environmental Executive,

Ariel Rios Building, Mail Code 1600S, 1200 Pennsylvania Ave.,

NW., Washington, DC 20460. Phone: 202 564-1297. 

Fax: 202 564-1393. Web site: www.ofee.gov

You can also download an electronic version on the Internet at

<www.ofee.gov/html/guide/html>.

❖ National Association of State Procurement Officials

(NASPO). NASPO’s Internet-based Database of Recycled

Commodities (DRC) includes information from states on their

recycled product procurement. Data include product

distributors, manufacturers, brand names, recycled and

postconsumer content, “Energy Star” rating, units purchased,

unit of measurement, unit price, and type of procurement. Visit

the NASPO Web site at <fcn.state.fl.us/bpsr/drc_notice.html>.

❖ Official Recycled Products Guide. This directory lists more

than 5,000 manufacturers and distributors of recycled-content

products. Contact: Recycling Data Management Corporation,

P.O. Box 577, Ogdensburg, NY 13669. Phone: 800 267-0707.

Fax: 315 471-3258.
How Can I Get More Information? (Continued)

❖ Plastic Lumber Trade Association (PLTA). PLTA is a

nonprofit, membership organization working to promote the

interests of the recycled plastic lumber industry. Their work

includes collaborating with the American Society for Testing

and Materials to set industrywide standards for recycled plastic

lumber. For more information, contact Alan E. Robbins,

President, P.O. Box 80311, Akron, OH 44308-9998. Phone:

330 762-8989. Fax: 330 762-1613.

❖ Recycled Plastic Products Source Book. This booklet lists

more than 1,300 plastic products from approximately 300

manufacturers, including pallets. For more information, call the

American Plastics Council (APC), 1801 K Street, NW., Suite

7010, Washington, DC 20006. Phone: 202 974-5400. 

Fax: 202 296-7119. Web site: www.plasticsresource.com

Internet Sites

❖ The Comprehensive Procurement

Guidelines: <www.epa.gov/cpg>. This site

describes EPA’s effort to facilitate the procurement

of products containing recovered materials, including information

on CPG, RMANs, and the Buy-Recycled Series.

❖ Environmentally Preferable Purchasing (EPP):

<www.epa.gov/oppt/epp>. EPA’s Environmentally Preferable

Purchasing program encourages and assists federal agencies

to purchase environmentally preferable products and services.

The site explains EPA’s proposed guiding principles for

including environmental performance in purchasing decisionmaking, and posts case studies of successful pilot projects in

both the public and private sectors.

❖ Office of the Federal Environmental Executive (OFEE):

<www.ofee.gov>. OFEE’s mission is to advocate, coordinate,

and assist environmental efforts of the federal community in

waste prevention, recycling, affirmative procurement of CPG

items, and the acquisition of recycled and environmentally

preferable products and services.

❖ Federal Trade Commission:

<www.ftc.gov/bcp/guides980427.htm>. The Federal Trade

Commission issued Guides for the Use of Environmental

Marketing Claims in May 1998. 

❖ Jobs Through Recycling: <www.epa.gov/jtr>. EPA’s Jobs

Through Recycling program stimulates economic growth and

recycling market development by assisting businesses and

supporting a network of state and regional recycling contacts.

This Web site provides information on financing and technical

assistance for recycling businesses, as well as other market

development tools.

❖ Municipal Solid Waste: <www.epa.gov/msw>. This site

includes information on recycling, source reduction, and reuse.

Contains state municipal solid waste data and the latest facts

and figures on waste generation and disposal.

❖ WasteWise: <www.epa.gov/wastewise>. WasteWise is a 

free, voluntary EPA program through which organizations

eliminate costly municipal solid waste, benefitting their bottom

line and the environment. The program provides hands-on

assistance to members to help them purchase or manufacture

recycled-content products, prevent waste, and recycle solid

waste materials.

❖ King County Recycled Product Procurement Program:

<www.metrokc.gov/oppis/recyclea.html>. This site describes

the tools and techniques developed by King County,

Washington, agencies for purchasing recycled products. 

Other Sources—Industrial Drums

❖ Association of Container Reconditioners. This association

represents about 100 container reconditioners, including

industrial drums. For more information, contact Paul Rankin or

Dana Worcester, Reusable Packaging Association (RIPA),

8401 Corporate Drive, Suite 140, Landover, MD 20785-2224.

Phone: 301 577-3786. Fax: 301 577-6476. Or visit the RIPA

Web site at <www.reconditioners.com>.

❖ Fiber Drum Institute. This organization represents fiber drum

manufacturers. For more information, please contact Gordon

Rousseau, 1850 K Street, NW., Suite 200, Washington, DC

20006. Phone: 202 463-3511.

❖ Plastic Drum Institute. This organization represents plastic

drum manufacturers across the nation. For more information,

please contact John Malloy, 1801 K Street, NW., Suite 600,

Washington, DC 20006. Phone: 202 974-5245.

Other Sources—Pallets

❖ National Wooden Pallet and Container Association

(NWPCA) This international trade association represents

manufacturers, recyclers, and distributors of pallets,

containers, and reels. NWPCA also developed the Uniform

Standards for Wood Pallets as a resource for pallet users and

suppliers. For more information, contact Heather Heishman at

NWPCA at 1800 North Kent Street, Suite 911, Arlington, VA

22209-2109. Phone: 703 527-7717 or 703 527-7667. 

Fax: 703 527-7717. Web site: www.nwpca.com

❖ National Wood Recycling Directory. This reference book

provides a list of manufacturers of recovered wood products,
How Can I Get More Information? (Continued) 

including remanufactured wooden pallets. For more

information, contact the American Forest and Paper

Association (AF&PA), 1111 19th Street, NW., Suite 800,

Washington, DC 20036. Phone: 202 463-2700. Fax: 202 463-

5180. Users can also search the directory online at AF&PA’s

Web site at <www.afandpa.org/Recycling/Wood/Search.htm>.

❖ Sustaining Business & Jobs Through Pallet Repair &

Reuse. This report lists pallet reuse and recycling operations

across the country and highlights case studies of model

reuse programs. For more information, contact Brenda Platt

at the Institute for Local Self-Reliance, 2425 18th Street,

NW., Washington, DC 20009-2096. Phone: 202 232-4108.

Fax: 202 332-0463.

1EPA

United States

Environmental Protection Agency

(5306W)

Ariel Rios Building

1200 Pennsylvania Avenue, NW.

Washington, DC 20460

Official Business 

Penalty for Private Use $300

In addition, contact your state solid waste

management agency for information about local

and regional businesses that produce or distribute

recycled-content products.