Buy-Recycled Series

EPA530-F-07-038 

www.epa.gov/osw

October 2007

2007

CPG

COMPREHENSIVE 

PROCUREMENT 

GUIDELINES

Buying recycled products...

...conserves natural resources

...saves energy

...reduces solid waste

...reduces air and water pollutants

...reduces greenhouse gases

...creates new jobs

The soda bottle you recycled after lunch might end up back on your 

desk as a recycled binder or pencil holder. Used toner cartridges 

and printer ribbons once considered “trash” are now remanufactured and returned, providing 

your office with highperformance products at 

considerable savings. 

To make it easier to 

buy recycled, the U.S. 

Environmental Protection Agency (EPA) periodically updates the 

Comprehensive Procurement Guidelines (CPG) 

Through the CPG, EPA 

designates items that 

must contain recycled 

materials when purchased with appropriated federal funds by 

federal, state, and local 

agencies, or by government contractors. 

Several nonpaper office 

products are among 

these items. 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 

NONPAPER OFFICE PRODUCTS

Advisory Notice (RMAN)—that 

recommends levels of recycled 

content for those items.

Why Buy Recycled?

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. 

Buying recycled products results in many environmental 

benefits. It supports local recycling programs by creating 

markets for the collected materials that are processed and used 

to manufacture new products. 

This creates jobs and helps 

strengthen the economy; conserves natural resources; saves 

energy; and reduces solid waste, 

air and water pollutants, and 

greenhouse gases that contribute to global warming.
NONPAPER OFFICE PRODUCTS

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The Resource Conservation and Recovery Act (RCRA) requires procuring agencies to buy recycled-content products designated by EPA in the CPG. Issued in 

May 1995, the first CPG designated 19 new 

products (including binders, office recycling 

containers, office waste receptacles, plastic 

desktop accessories, plastic trash bags, and 

toner cartridges) and incorporated five previously designated items in eight product categories. The first CPG update (CPG II) was 

published in November 1997 and designated 

an additional 12 items, including plastic envelopes and printer ribbons. A second CPG update (CPG III) was published in January 2000 

and designated an additional 18 items, including plastic binders, plastic clipboards, plastic 

file folders, plastic clip portfolios, and plastic 

presentation folders. The third CPG update 

(CPG IV), published in April 2004, designated 

seven new products, including office furniture. 

The fourth CPG update (CPG V), published in 

September 2007, designated one new item and 

revised another designation, but did not designate any new nonpaper office products. For 

more information, visit <www.epa.gov/epaoswer/non-hw/procure/about.htm>.

Procuring agencies include all federal agencies, and any state or local government agencies or government contractors that use 

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. Executive 

Order (E.O.) 13423 and the Federal Acquisition Regulation also call for an increase in the 

federal government’s use of recycled-content 

and environmentally preferable products.

Once any new items are designated in a published CPG update, an agency has 1 year to 

develop an affirmative procurement program 

(or revise an existing one) to include these 

new items. In previous years, agencies have 

had to revise their affirmative procurement 

programs to incorporate buy-recycled requirements for items such as recycling containers; 

waste receptacles; plastic desktop accessories; 

plastic covered, paper covered, and pressboard 

binders; trash bags; toner cartridges; printer 

ribbons; plastic envelopes; plastic binders; 

plastic clipboards; plastic file folders; plastic 

clip portfolios; and plastic presentation folders. Agencies must have revised their affirmative procurement programs to add the items 

designated under CPG IV by April 30, 2005. 

This effort might have involved reviewing 

specifications for this product and eliminating provisions that pose barriers to procuring 

it with recycled content (such as aesthetic 

requirements unrelated to product performance). Also, be aware that paper envelopes 

were designated in CPG I. Recommended recycled-content ranges for paper envelopes are 

addressed in the RMAN for paper products 

and also can be found in the Buy-Recycled 

Series Paper Products resource guide.

The CPG acknowledges 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 it 

determines 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 CPG?
NONPAPER OFFICE PRODUCTS

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EPA issues purchasing guidance in 

RMANs, which are designed to make 

it as easy as possible to buy the designated items. The RMANs recommend 

recycled-content levels to look for when 

purchasing office products, as shown in 

the table below. Following the RMANs’ 

recommended levels will help ensure your 

affirmative procurement program and standards meet the buy-recycled requirements. 

The RMANs also provide other purchasing 

guidance. Please refer to <www.epa.gov/

cpg/products.htm> for more information on 

individual products.

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 recycled-content products that are commercially available, are competitively priced, and meet 

buyers’ quality standards. 

Access EPA’s online recycled-content products database by going to <www.epa.gov/

cpg> and selecting “Supplier Database.” See 

the last section of this resource guide for 

other helpful resources.

How Do I Purchase RecycledContent Nonpaper Office Products?

EPA’s Recommended Content Levels for Nonpaper Office Products

NONPAPER OFFICE 

PRODUCT

MATERIAL RECOVERED POST-CONSUMER 

RECOVERED CONTENT

TOTAL RECOVERED 

CONTENT

Recycling Containers and 

Waste Receptacles1

Plastic

Steel2

Paper

– Corrugated

– Solid Fiber Boxes

– Industrial Paperboard

20–100%

16%

25–50%

40%

40–80%

—

25–30%

25–50%

—

100%

Desktop Accessories 

including Desk Organizers, 

Sorters, Trays, and Memo, 

Note, and Pencil Holders1

Plastic (Polystyrene [PS]) 25–80% —

Binders1 Plastic-covered

Paper-covered

Pressboard

Solid Plastic

– High-density 

 Polyethylene (HDPE)

– Polyethylene (PE)

– Polyethylene 

 Terephthalate (PET)

– Miscellaneous Plastics

—

75–100%

20%

90%

30–50%

100%

80%

25–50%

90–100%

50%

90%

30–50%

100%

80%
NONPAPER OFFICE PRODUCTS

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NONPAPER OFFICE 

PRODUCT

MATERIAL RECOVERED POST-CONSUMER 

RECOVERED CONTENT

TOTAL RECOVERED 

CONTENT

Trash Bags1 Plastic 10–100% —

Toner Cartridges1,3 See Endnote 3 See Endnote 3 See Endnote 3

Printer Ribbons1,4 See Endnote 4 See Endnote 4 See Endnote 4

Plastic Envelopes1 Plastic 25% 25–30%

Plastic Clipboards1 HDPE

PS

Miscellaneous Plastic

90%

50%

15%

90%

50%

15–80%

Plastic File Folders1 HDPE 90% 90%

Plastic Clip Portfolios HDPE 90% 90%

Plastic Presentation 

Folders1

HDPE 90% 90%

Office Furniture Furniture Structure

– Steel2

– Aluminum

Particleboard/Fiberboard 

Component5

– Wood or Wood Composite

– Agricultural Fiber

Fabric

– PET

Plastic Furniture 

Component

– HDPE

Remanufactured or 

Refurbished Furniture

– Various

16%

—

Greater than 0%

—

100%

70–75%

25–75%

25–30%

75–100%

80–100%

100%

100%

95%

25–75%

1 EPA’s recommendations do not preclude procuring agencies from purchasing nonpaper office products made from the materials manufactured using other 

materials, such as wood or cloth. EPA simply recommends that procuring agencies, when purchasing nonpaper office products made from the materials 

designated in the procurement guidelines, purchase these products containing recovered materials.

2 The recommended recovered materials content levels for steel in this table reflect the fact that the designated item is generally made from steel manufactured 

in a Basic Oxygen Furnace (BOF). Steel from the BOF process contains 25–30 percent total recovered materials, of which 16 percent is post-consumer steel.

3 EPA recommends the return of used toner cartridges for remanufacturing and reuse or purchasing a remanufactured or recycled-content replacement cartridge.

4 EPA recommends the procurement of printer ribbon reinking or reloading services, or reinked or reloaded printer ribbons.

5 Particleboard and fiberboard used in the wood components of office furniture also may contain other recovered cellulosic materials, including paper, wheat 

straw, and bagasse. The percentages of these materials contained in the product also would count toward the recovered materials content level of the item. 

In addition, while EPA has no evidence or indication that wood treated with chromated copper arsenate (CCA) is currently used in office furniture, EPA is 

not recommending the use of CCA-treated wood as a recovered material in office furniture. The arsenic in CCA is a known human carcinogen and EPA is 

currently conducting a thorough and comprehensive risk assessment of CCA as a part of the pesticide reregistration process for CCA. In addition, EPA is 

conducting a risk assessment for children who contact CCA treated wood playsets and decks.
NONPAPER OFFICE PRODUCTS

PAGE 

How Can I Get More Information?

Information Available 

From EPA

Other Government 

Sources

This resource guide and the following resources on buying recycled-content products can be accessed on the Internet.

The CPG: <www.epa.gov/cpg>. This site describes EPA’s effort to facilitate the procurement 

of products containing recovered materials, 

including information on CPG and RMANs, and 

an online database of manufacturers and suppliers of designated items.

EPA CPG Program: <www.epa.gov/cpg/pdf/cpgfs.pdf>. This resource guide provides general 

information about the CPG and the development 

of affirmative procurement programs. 

Environmentally Preferable Purchasing (EPP): 

<www.epa.gov/epp>. EPA’s EPP program encourages and assists federal agencies in purchasing 

environmentally preferable products and services. The site explains EPA’s proposed guiding 

principles for including environmental performance in purchasing decision-making, and posts 

case studies of successful pilot projects in both 

the public and private sectors.

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. It 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 

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manufacture recycled-content products, prevent 

waste, and recycle solid waste materials.

Federal Register (FR): <www.epa.gov/cpg/backgrnd.htm> and <www.epa.gov/epaoswer/nonhw/procure/about.htm>. Notices promulgating CPG I (60 FR 21370) and RMAN I (60 FR 

21386), May 1, 1995. FR notices promulgating 

CPG II (62 FR 60961) and RMAN II (62 FR 

60975), November 13, 1997. FR notices promulgating CPG III (65 FR 3070) and RMAN III (65 

FR 3082), January 19, 2000. FR notices promulgating CPG IV (69 FR 24028) and RMAN IV (69 

FR 24039), April 30, 2004. FR notices promulgating CPG V (72 FR 52475) and RMAN V (72 

FR 52561), September 14, 2007.

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U.S. General Services Administration (GSA) 

Environmental Products Overview: <www.gsa.

gov/Portal/gsa/ep/channelView.do?pageTypeId

=8207&channelPage=/ep/channel/gsaOverview.

jsp&channelId=-12972>. GSA offers a variety of 

environmental products and services to its federal 

customers to assist them in their efforts to comply with procurement responsibilities outlined in 

federal environmental laws and regulations. This 

overview contains information about environmentally oriented products and services in the 

Federal Supply Service Supply System. To access 

GSA Advantage!, GSA’s Internet-based ordering 

system, and order any GSA product, visit <www.

gsaadvantage.gov>.

Recycling Collection Containers and Specialty Waste Receptacles, Federal Supply 

Schedule Group 72, Part 7, Schedule B: Lists 

a variety of containers and receptacles available for purchase. For more information, 

contact GSA.

Environmental Products Guide: <www.gsa.

gov/Portal/gsa/ep/home.do?tabId=2>. 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.

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NONPAPER OFFICE PRODUCTS

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King County Recycled Product Procurement Program: <www.metrokc.gov/procure/green/>. This 

site describes the tools and techniques developed 

by King County, Washington, agencies for purchasing recycled products.

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.

Greening the Government: A Guide to 

Implementing Executive Order 13101: 

<http://ofee.gov/eo/greening.pdf>. This guide 

provides detailed information on the requirements of E.O. 13101, which established a 

process for amending the CPG and issuing 

RMANs. E.O. 13101 preceded E.O. 13423 

and established many requirements and 

definitions that are still in effect. Updated 

in February 2001, the E.O. is available from 

OFEE at <www.ofee.gov>.

Executive Order 13423: Strengthening 

Federal Environmental, Energy, and Transportation Management: < http://ofee.gov/

eo/eo13423_main.asp>. Published in January 

2007, this Order replaced E.O. 13101 and 

requires federal agencies to purchase green 

products and services, including recycledcontent products, energy- and water-efficient 

products, biobased products, and environmentally preferable products and services. 

Although E.O. 13423 revoked E.O. 13101, 

EPA continues to follow certain procedures 

of E.O. 13101 since they are consistent with 

the requirements of RCRA 6002 (e). 

Federal Green Purchasing Program: <www.

ofee.gov/gp/gp.asp>. This program assists 

federal agencies to promote the acquisition 

of recycled-content, environmentally preferable, and biobased products; non-ozone 

depleting substances; and products containing alternatives to certain priority chemicals. 

Training tools and other green purchasing 

guidance are available.

Federal Trade Commission: <www.ftc.gov/bcp/

grnrule/guides980427.htm>. The Federal Trade 

Commission issued Guides for the Use of Environmental Marketing Claims in May 1998.

California Recycled-Content Product Database: 

<www.ciwmb.ca.gov/RCP>. This site contains 

information on reasons to buy recycled-content 

products and how to procure them, and provides access to a database with information on 

products, as well as manufacturers, distributors, 

reprocessors, mills, and convertors across the 

country who procure or produce these products.

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Additional Sources

Buy Recycled Business Alliance: <www.nrc-recycle.org/>. The Alliance includes over 3,200 

companies and organizations committed to 

increasing the 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. 

Javits-Wagner-O’Day (JWOD): <www.jwod.com>. 

The JWOD Program creates jobs and training 

opportunities for people who are blind or have 

other severe disabilities. JWOD’s online “environmentally friendly products store” provides office 

supplies, including several CPG-designated items 

such as recycled-content clipboards. 

Official Recycled Products Guide: <www.dep.

state.pa.us/wm_apps/recycledproducts/>. This 

directory lists more than 5,000 manufacturers 

and distributors of recycled-content products.

Recycled Plastic Products Source Book: <www.

americanplasticscouncil.org>. This booklet lists 

more than 1,400 plastic products from approximately 300 manufacturers, including nonpaper 

office products. 

Recycling Data Network Information Services: 

<www.recyclingdata.com/contents.htm>. This 

commercial Web site provides access, on a subscription basis, to a recycled-content products 

database of over 4,500 listings in 700 product 

classifications. It also provides a reference guide 

and a newsletter. The product database is considered to be the largest of its kind.

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