Federal Response to CRT 

Recycling Concerns

2014 E-SCRAP CONFERENCE 

OCTOBER 22, 2014

AMANDA KOHLER, U.S. ENVIRONMENTAL PROTECTION 

AGENCY

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Agenda

 How EPA regulates CRTs 

 What is the issue?

 EPA response to CRT recycling concerns

 Potential future actions

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How EPA Regulates CRTs

• Under the Resource Conservation and Recovery Act (RCRA), used cathode ray 

tubes (CRTs) and CRT glass generally contain hazardous levels of lead and are 

therefore regulated as RCRA hazardous waste when disposed by non-household 

sources.

• CRT glass is typically sorted into two categories – panel glass (which generally is 

not hazardous waste) and funnel glass (which generally is hazardous). 

• In 2006, EPA excluded used CRTs and CRT glass being recycled from RCRA 

hazardous waste regulation, provided certain conditions are met (“CRT rule,” 40 

CFR 261.4(a)(22)).

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How EPA Regulates CRTs

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• Conditions include storage and management requirements for used, broken CRTs and 

export requirements for used CRTs exported for recycling or reuse.

• Additionally, used CRTs and processed CRT glass are subject to speculative accumulation

limits, meaning there must be a feasible means of recycling and at least 75% of the 

material is recycled or transferred for recycling during the calendar year.

• Currently, CRT glass can be recycled under the CRT rule by being sent to a lead smelter 

(to reclaim the lead and to use the silica as a flux agent) or to a CRT glass manufacturer. 

• CRT glass may also qualify for another exclusion from hazardous waste regulation, such 

as the “use/reuse exclusion” (40 CFR 261.2(e)), for example, when used as a fluxing 

agent in a copper smelter or used as an ingredient in ceramic-making.
What is the Issue? 

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• CRTs and CRT glass were once easily recycled into new CRTs; however, the 

demand for new CRTs has collapsed in favor of new flat panel 

technologies. 

• Because of rising costs, negative economic incentives, and shifts in CRT 

glass markets, some CRT processors and recyclers are choosing to store 

the glass indefinitely rather than send it for recycling (or disposal), which 

increases the risk of mismanagement and/or abandonment of the CRTs.

• TransparentPlanet’s December 2012 report estimates that about 330,000 

tons were being stockpiled. Other sources estimate 3.2 to 6.6 million tons 

of CRTs have yet to be collected. One electronics recycler estimates that 

the cost to recycle CRTs will reach over two billion dollars in the next 

decade.
What is the issue? 

 2013 (PA, NY) – 12,000 tons of CRT glass abandoned. 

 Aug 2013 (CO) –8,000 tons of CRT glass abandoned.

 Aug 2013 (AZ) – 3,000 tons of CRTs and CRT glass 

abandoned. 

 Mar 2014 (OH) –1,500-3,000 tons of CRT glass 

abandoned. Recycler was both R2 and e-Stewards 

certified. 

 Mar 2014 (AZ) – CRT recycler was fined $120,000 for 

improper storage and recycling of CRTs. 

 Mar 2014 (UT) – Fire occurred at CRT recycler, which may 

have been ignited from storing CRTs outside where 

reflection from the sun could ignite a blaze.

 Additionally, a number of attendees on EPA’s May 2013 

webinar indicated they knew of stockpiles, including 

ones in Pennsylvania, North Carolina, and Florida. 

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EPA Response to CRT Recycling Concerns

• Over the last eighteen months, we have met with a number of stakeholders on this 

issue. We also hosted a public webinar in May 2013.

• We published a final rule in June 2014 that amends provisions related to exports of 

CRTs in order to enable better tracking and help ensure environmentally sound 

management abroad.

• Exporters of CRTs for reuse – now must submit notice every 12 months

• Exporters of CRTs for recycling – now must submit annual reports

• We have provided regulatory support to stakeholders exploring options for 

recycling CRT glass, including frequently asked questions (FAQs) and three 

regulatory determinations that are publicly available from our website.

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EPA Letter on Copper Smelters

• Clarifies that CRT funnel glass sent to 

copper smelters would be excluded 

from hazardous waste regulation under 

the “use/reuse” exclusion (rather than 

the CRT rule).
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EPA Letter on Alternative Daily 

Cover (“ADC”)

• Explains how the hazardous waste regulations 

apply to CRT funnel glass sent for land 

disposal.

• Confirms that CRT funnel glass can be land 

disposed as long as the glass meets land 

disposal restriction requirements, which for 

lead is 0.75 mg/L, as determined using the 

TCLP.
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EPA Letter on CRT Glass Used as a 

Substitute for Lead Oxide in 

Manufacturing of Ceramic Tiles

• Communicates EPA’s determination that CRT 

glass used as a substitute for lead oxide in the 

manufacturing of ceramic tiles is legitimate.

• Provides EPA’s rationale for this determination 

based on the four factors for legitimate 

recycling.
Electronics Community Call to Action 

• This is a challenging problem that needs the collective power of the electronics 

community to address.

• On September 23, EPA held a multi-stakeholder meeting with the electronics 

community to identify the factors that have influenced the problem and to 

begin an evaluation of the existing and emerging end uses for CRT funnel glass.

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Potential Ideas for Action Generated from 

Electronics Community

a) Work with R2 and e-Stewards to ensure compliance with the CRT rule, including speculative 

accumulation, as a means of maintaining certification.

b) Improve alignment of financial incentives to facilitate actual recycling, versus collection, of CRTs.

c) Consistently and effectively enforce CRT rule and other regulations.

d) Provide guidance for those engaging in contracts with electronic recyclers to ensure proper 

downstream processing of CRT glass.

e) Identify available recycling/recovery options and capacity and associated cost.

f) Improve awareness of regulations (e.g., training) by states and electronics community.

g) Improve tracking of CRTs to ensure proper recycling (or disposal) of glass and to reduce use of “air 

pounds” to claim manufacturer credits.

h) Grant variances, with performance management conditions (e.g., performance management 

standards, financial assurance, payments to receive set aside for capital investment), for longerterm accumulation of CRT glass by CRT glass processors.

i) Conduct/invest in research, development, and lifecycle analyses of technologies to recycle CRT 

glass. 

j) Need to coordinate systems-wide approach to the issue. 

k) Improve consistency in interpretation and application of state law. 

l) Ensure accountability for mismanaged CRTs.

m) Provide incentives for properly managing CRTs and for recycling CRT glass.

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US EPA Meeting on CRTs

Thursday, 1:00 PM

Gatlin A

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We need to work together to solve this problem.

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