NATIONAL STRATEGY 

FOR ELECTRONICS 

STEWARDSHIP

JULY 20, 2011

INTERAGENCY TASK FORCE ON ELECTRONICS STEWARDSHIP

Co-Chairs:

White House Council on Environmental Quality

Environmental Protection Agency

General Services Administration
July 2011

National Strategy for Electronics Stewardship 1

CONTENTS

EXECUTIVE SUMMARY..................................................................................................................................... 1

Summary of Recommendations .................................................................................................. 2

INTRODUCTION................................................................................................................................................... 4

THE NATIONAL STRATEGY FOR ELECTRONICS STEWARDSHIP.................................................... 8

Build Incentives for Design of Greener Electronics, and Enhance Science, 

Research and Technology Development in the United States ......................................... 8

Ensure that the Federal Government Leads By Example ................................................13

Increase Safe and Effective Management and Handling of Used Electronics 

in the United States ........................................................................................................................21

Reduce Harm from US Exports of E-Waste and Improve Safe Handling 

of Used Electronics in Developing Countries .......................................................................24

CONCLUSION ......................................................................................................................................................31

ABBREVIATIONS...............................................................................................................................................32
July 2011

National Strategy for Electronics Stewardship 1

EXECUTIVE SUMMARY

From computers and cell phones, to portable communication and music devices -- the 

United States of America is, and will continue to be, a global leader in designing and 

developing new and improved electronic technologies. These technologies have become 

critical to our way of life and to our growing economy. With these technologies, however, 

comes the increasing challenge of protecting human health and the environment from the 

harmful effects associated with the unsafe handling and disposal of these products. 

Meeting this challenge will require a new strategy for electronics stewardship – one that is 

innovative, flexible, and pragmatic – that allows Americans to manage the electronics we 

use today more sustainably, and simultaneously promotes the new and innovative 

technologies of the future. Innovation is woven throughout America’s history and culture 

and is an asset we must employ to find solutions to the challenges we face today to 

sustainably manage our electronics.

Some of the problems caused by the mismanagement of used electronics create an 

opportunity for individuals, communities, non-governmental organizations (NGOs), 

businesses, local governments, states, tribal nations, and the Federal Government to work 

together toward becoming better stewards of the global environment. Better management 

of electronics through the product lifecycle – from design and manufacturing through their 

use and eventual recycling, recovery, and disposal – is an opportunity to prevent 

environmental harm, conserve valuable resources, save money, create jobs, and invest in 

our economic development.

By implementing the recommendations presented in this National Strategy for Electronics 

Stewardship, developed by an interagency Task Force, the Federal Government will lay the 

groundwork for improving the design of electronic products and enhancing our 

management of used or discarded electronics. This Strategy provides a roadmap of how 

the Federal Government can use its authorities and leverage resources to seize this 

opportunity.
July 2011

National Strategy for Electronics Stewardship 2

Summary of Recommendations

The National Strategy for Electronics Stewardship provides four overarching goals, the 

action items under each goal, and the projects that will implement each action item. These 

recommendations are summarized below and described in more detail in the main body of 

this document.

Build Incentives for Design of Greener Electronics, and Enhance Science, 

Research and Technology Development in the United States

 Establish multi-stakeholder groups to address key research questions and design 

challenges, and accelerate development of and investment in green electronics 

design standards.

 Promote consumer purchasing of green electronics that are certified as meeting 

stringent environmental performance criteria that address environmental 

impacts across the entire lifecycle of the products.

 Promote scientific research and technological developments that improve our 

ability to recover and market valuable materials from used electronics, especially 

precious metals and rare earth elements.

 Launch electronics stewardship prize competitions to stimulate innovations in 

green product design, recycling solutions, and other phases of the electronics 

lifecycle.

 Ensure expansion of quality green electronics certification programs, including 

EPEAT, 1

Ensure that the Federal Government Leads By Example

to consider environmental impacts across entire product lifecycles and 

to cover additional types of electronics.

 Establish a comprehensive and transparent government-wide policy on used 

Federal electronics that maximizes reuse, clears data and information stored on 

used equipment, and ensures that all Federal electronics are processed by 

certified recyclers.

 Encourage electronics manufacturers to expand their product take-back 

programs, and use certified recyclers as a minimum standard in those programs, 

by expanding the use of manufacturer take-back agreements in Federal 

electronics purchase, rental and service contracts.

 Require and enable recipients of former Federal equipment that has been sold, 

transferred, or donated for reuse to use certified recyclers and follow other 

environmentally sound practices to the greatest extent possible.

 Improve tracking of used Federal electronics throughout the lifecycle and post 

comprehensive data sets on Data.gov and other publicly accessible websites.

 1 Electronic Product Environmental Assessment Tool
July 2011

National Strategy for Electronics Stewardship 3

 More effectively direct Federal Government spending on electronics toward 

green products through procurement changes.

 Expand the use of the intergovernmental cooperative agreements between the US

Postal Service and other federal agencies to make it more convenient, efficient,

and cost effective for government agencies with remote offices to directly ship

used electronics to original equipment manufacturers, certified recyclers, or

entities that will reuse the equipment.

 Identify, characterize, and document markets, as well as market and financial 

assistance opportunities, associated with managing and recycling used 

electronics.

Increase Safe and Effective Management and Handling of Used Electronics 

in the United States

 Launch voluntary partnerships with the electronics industry.

 Provide guidance to electronics recycling employers on providing facilities that 

offer safe and healthy working environments.

 Establish approaches to gather, track, and provide public access to information 

on quantities and movement of used electronics within the US.

Reduce Harm from US Exports of E-Waste and Improve Safe Handling of 

Used Electronics in Developing Countries

 Improve information on trade flows and handling of used electronics, and share

data with Federal and international agencies, within the limits of existing legal 

authorities.

 Provide technical assistance and establish partnerships with developing 

countries to better manage used electronics.

 Work with exporters to explore how to incentivize and promote the safe handling 

of remanufactured, recycled, and used electronics at home and abroad.

 Propose regulatory changes to improve compliance with the existing regulation 

that governs the export of cathode ray tubes from used computer monitors and 

televisions that are destined for reuse and recycling.

 Support ratification of the Basel Convention on the Control of Transboundary 

Movements of Hazardous Wastes and their Disposal.

An on-line annex of benchmarks of projects, posted on the Web at www.fedcenter.gov, lists 

each of the projects, the primary agency responsible for the project and any agencies 

supporting the primary agency in that effort, and the target date for completion of the 

project. As the National Strategy is developed in further detail by the departments and 

agencies, and as the Strategy is implemented, the annex will be updated. As appropriate, 

action items and projects under them may be realigned as efficiencies and opportunities for 

further improvement are identified.
July 2011

National Strategy for Electronics Stewardship 4

INTRODUCTION

From computers and cell phones, to portable communication and music devices -- the 

United States of America is, and will continue to be, a global leader in designing and 

developing new and improved electronic technologies. These technologies have become 

critical to our way of life and to our growing economy. With these technologies, however, 

comes the increasing challenge of protecting human health and the environment from the 

potentially harmful effects associated with the improper handling and disposal of these 

products. Currently, most discarded consumer electronics end up in our landfills.2 While 

accurate data on the amount of e-waste being exported from the US are not available, the 

Federal Government is concerned that these exports may be mismanaged abroad,3 causing 

serious public health4 and environmental hazards5

Increasing the capacity to carry out recycling, refurbishing, and remanufacturing activities 

in the US could generate opportunities for US-based green jobs, and increase exports of 

and representing a lost opportunity to 

recover valuable resources.

 2 EPA. Electronics Waste Management in the United States through 2009. EPA 530-R-11-002, May 2011; 

www.epa.gov/epawaste/conserve/materials/ecycling/docs/FullBaselineReport2011.pdf. 3 See, e.g., eCycling Frequent Questions, www.epa.gov/epawaste/conserve/materials/ecycling/faq.htm; 

Cleaning Up Electronic Waste, www.epa.gov/international/toxics/ewaste.html; CEC Projects on Electronics 

Waste, www.epa.gov/international/regions/na/nacec/cecewaste.html. 4 Yang F, Jin S, Xu Y, Lu Y. Comparisons of IL-8, ROS and p53 responses in human lung epithelial cells exposed 

to two extracts of PM2.5 collected from an e-waste recycling area, China. Environmental Research Letters 

6(2) 024013, May 31, 2011; http://iopscience.iop.org/1748-9326/6/2/024013. 5 Tsydenova O, Bengtsson M. Chemical hazards associated with treatment of waste electrical and electronic 

equipment. Waste Management 31(1) 45–58, January 2011; www.sciencedirect.com/science/article/B6VFR5132N42-1/2/b6df41a27003a9c5b8b08ef4a85b4712.

Figure 1: Life-cycle flow chart 

for electronic products. Solid 

boxes refer to life cycle stages 

modeled by the EPA in 2011; 

dashed and gray boxes refer to 

stages where information was 

collected by recycler surveys, or 

that were not in 2011 modeled. 

See footnote 2.
July 2011

National Strategy for Electronics Stewardship 5

remanufactured electronic goods. For example, the National Export Initiative highlights 

opportunities for domestic job creation through increased exports. Increased domestic 

recycling that includes sorting, dismantling, and recovery of valuable materials could also 

spur the development of better and more efficient recycling technologies. Improved

lifecycle management of electronics, through refurbished and remanufactured electronic 

goods can also reduce total quantities of waste to be managed, both domestically and 

globally.

Meeting this challenge will require a new national strategy for electronics stewardship –

one that is innovative, flexible, and pragmatic – that allows Americans to manage the 

electronics we use today more sustainably, while simultaneously promotes the new and 

innovative technologies of the future. Innovation is woven throughout America’s history 

and culture, and American innovation is an asset we must employ to meet the challenges 

we face today to sustainably manage our electronics.

As global leaders, many American companies have been working to improve the way 

electronics are designed and managed by using more environmentally-preferable materials 

and finding better ways to reuse, refurbish and recycle. As responsible consumers, more 

and more Americans understand the human health and environmental hazards of 

improper handling and disposal, and are already taking some steps to buy greener 

products and safely recycle discarded electronics. Although the Task Force recognizes and 

appreciates the importance of these early efforts, it is convinced that the Nation needs to do 

much more.

Used Electronics versus E-Waste

“E-waste,” “electronic waste,” “electronics waste,” “e-scrap,” and “end-of-life electronics” are terms 

that are often used to describe used electronics that are nearing the end of their useful life, and are 

discarded, donated or given to a recycler. The Task Force recognizes that the term “e-waste” and 

similar terms are commonly used in many parts of the world. For the purposes of this document, 

however, the Task Force considers “e-waste” a subset of “used electronics.” Used electronics can be 

reused, refurbished, and recycled, and can be a source of valuable parts and/or raw materials (e.g., 

gold, copper, glass), which can be returned to the supply chain to reduce overall waste. There is a 

general acknowledgement globally that some used electronics are exported to developing countries 

where they are not managed properly, and become e-waste.

The use of the term “e-waste” is intentionally minimized in this document simply to emphasize the 

importance of reuse and responsible recycling. Reuse of used electronics will reduce the amount of 

waste generated, and proper recycling of used electronics can yield raw materials (e.g., gold, copper, 

glass, aluminum) that can produce an economic benefit as well as serve to return materials to the 

supply chain and reduce overall waste. It should be noted that many countries have their own 

definitions, policies, and laws regarding management of used electronics and e-waste, including 

import and export restrictions.
July 2011

National Strategy for Electronics Stewardship 6

Resource Conservation 

and Recovery Act (RCRA) Urban Mining

This 1976 Federal law authorizes EPA to protect 

public health and the environment against many 

kinds of waste that is disposed of or recycled in 

certain ways. However, electronic devices sent 

for reuse for their original purpose (i.e., 

electronics sold or donated to be used again) are 

not “waste” governed by RCRA. Although EPA 

has issued a rule under RCRA for cathode ray 

tubes (CRTs) (see pages 29-30), which have high 

lead content, electronic devices are complex and 

consist of a wide variety of materials, many of 

which would not be classified as hazardous 

under RCRA regulations. In particular, the “CRT 

rule” encourages recycling and reuse of used 

CRTs and glass removed from CRTs. The rule 

excludes these materials from the RCRA 

definition of solid waste if certain conditions are 

met.

“Urban mining” refers to the recovery of 

precious metals and other valuable materials 

from products or what some people consider 

waste, as opposed to mining of minerals from 

ores, or drilling of petroleum or other organics, 

in the ground. Reusing and recycling unwanted 

electronics helps the environment by saving 

energy and keeping valuable materials out of 

landfills. Electronics are made out of precious 

metal, copper, plastics and glass, all of which 

require energy to mine and manufacture. 

Recycling not only conserves these materials, 

but reduces air and water pollution, erosion, 

and greenhouse gas emissions.

In proclaiming November 15, 2010 as America Recycles Day, President Obama stated that 

Americans must build upon this progress and increase our capacity to recycle our used 

electronics responsibly. Increasing our domestic recycling efforts can create green jobs, 

can lead to more productive reuse of valuable 

materials, increase the value of American exports, 

and support a vibrant American recycling and 

refurbishing industry. If done properly, we can

increase our domestic recycling efforts, reduce 

harm from exports of e-waste being handled 

unsafely in developing countries, strengthen 

domestic and international markets for viable and 

functional used electronic products and prevent 

health and environmental threats at home and 

abroad.
July 2011

National Strategy for Electronics Stewardship 7

To seize these opportunities and address the problems caused by discarded used 

electronics, the White House Council on Environmental Quality (CEQ), acting under 

Executive Order (EO) 13514,6 and building on previous EOs,

7 established the Interagency 

Task Force on Electronics Stewardship, co-chaired by the Environmental Protection 

Agency (EPA) and the General Services Administration (GSA), as well as CEQ, to develop a 

national strategy that builds upon existing Federal Government efforts and incorporates 

recommendations proposed by electronics stakeholders and the public.8

This National Strategy for Electronics Stewardship provides recommendations on steps the 

Federal Government, businesses, and all Americans can take toward achieving the goals 

identified by President Obama. The following agencies and departments contributed to 

this National Strategy and participated in drafting the recommendations:

• White House Council on Environmental Quality • Department of Energy

• Environmental Protection Agency • Department of Labor

• General Services Administration • Department of Justice

• Office of Management and Budget • Department of State

• Office of the US Trade Representative • Department of Veterans Affairs

• Department of Commerce • Federal Communications Commission

• Department of Defense • US Customs and Border Protection

• Department of Education • US Postal Service

On behalf of the Task Force, EPA solicited public comment from stakeholders through a 

notice published in the Federal Register;9

 6 Executive Order (EO) 13514, Federal Leadership in Environmental, Energy, and Economic Performance 

(October 5, 2009). 

about 130 unique sets of comments were 

received in response to the notice, including 2050 letters from a mail-in campaign. Also on 

behalf of the Task Force, CEQ held three stakeholder listening sessions in March 2011 with 

State and local government agencies, non-governmental organizations, and industry, 

respectively. Comments provided through both of these methods were evaluated by the 

Task Force and considered in developing the strategy. Additional consideration to 

comments received in drafting this National Strategy will be given during the 

implementation of the Task Force recommendations.

http://edocket.access.gpo.gov/2009/pdf/E9-24518.pdf. 7 These previous EOs include EO 12780, Federal Agency Recycling and the Council on Federal Recycling and 

Procurement Policy (October 31, 1991); EO 12873, Federal Acquisition, Recycling, and Waste Prevention 

(October 20, 1993); EO 13423, Strengthening Federal Environmental, Energy, and Transportation 

Management (January 24, 2007); and EO 13534, National Export Initiative (March 11, 2010). EOs issued 

since 1937 are available through www.archives.gov/federal-register/executive-orders/disposition.html. 8 Task Force establishment letter, November 8, 2011, 

www.epa.gov/osw/conserve/materials/ecycling/docs/ewaste_task_force_memo.pdf. 9 76 Federal Register (FR) 11243-44; March 1, 2011; http://federalregister.gov/a/2011-4505. EPA later 

extended the March 11 deadline to March 16. The FR notice and the public submissions responding to the 

notice are available (as of the publication of this report) at www.regulations.gov by entering “EPA-HQ-RCRA2011-0185” (either with or without the quotes) in the Enter Keyword or ID window.
National Strategy for Electronics Stewardship 8

THE NATIONAL STRATEGY FOR ELECTRONICS 

STEWARDSHIP

Build Incentives for Design of Greener Electronics, and Enhance Science, 

Research and Technology Development in the United States

Our responsibility to manage electronics depends on our ability to innovate, find new 

methods to reuse and recycle, and design greener products that have reduced 

environmental impacts across their lifecycles and are easier to recycle. Specifically, 

greener and more sustainable electronics may include the following characteristics:

 They contain recycled materials and fewer hazardous and virgin materials.

 They include lists of intentionally added chemicals, generated by suppliers and 

manufacturers, which are available to certifying bodies, as necessary.

 They are capable of being recycled to maximize the recovery of the rare or 

valuable materials they contain and minimize the amount of waste, especially 

hazardous waste, they could ultimately generate.

 They are energy efficient through the product lifecycle.

 They are designed to have long useful lives and facilitate reuse through multiple 

users.

 They generate minimal emissions which are harmful to public health or the 

environment during the manufacturing, use, recycling, and disposal phases.

The rapidly growing interest among business and consumers in more-sustainable 

electronics and other products presents opportunities for the Federal Government to lead 

and achieve major economic, energy, environmental, and public health improvements. 

Major advances in electronics design, including flexible electronics, offer new opportunities 

to design sustainability into the lifecycle of electronics.

Many companies, NGOs, and other stakeholders are calling on the Federal Government to 

provide greater leadership in product sustainability, looking to the government’s technical 

and policy expertise, program experience, and overall credibility. Currently the Federal 

Government is promoting greener design and more sustainable use of electronics through

the EPA–Department of Energy (DOE) ENERGY STAR program,10

 10 Energy Star Program, 

DOE’s Federal Energy 

www.energystar.gov.
July 2011

National Strategy for Electronics Stewardship 9

Management Program (FEMP),11

EPEAT

and use of the Electronic Product Environmental 

Assessment Tool ( )12 programs. These programs help the Federal Government and 

private consumers identify and purchase greener electronics, and provide a solid 

foundation to build more efforts to encourage the design, manufacture, and purchase of 

green electronics. Currently, the government uses these programs to guide its 

procurement of green electronics and has aggressive green purchasing mandates (notably 

the goal of 95% of sustainable acquisitions specified in Executive Order 13514).13

The Federal Government can help drive improved electronic product design, manufacture, 

and technology development in a variety of ways. The Interagency Task Force has 

identified steps to advance green design and ensure that better design standards are 

supported by consumer demand and are economically viable.

However, there are large gaps in its data and ability to demonstrate performance against 

those mandates, especially outside of the product categories covered by the EPEAT 

program.

 Establish multi-stakeholder groups to address key research questions and design 

challenges, and accelerate development of and investment in green electronics 

design standards.

EPA has a unique ability to bring diverse groups of stakeholders to the table to address 

common challenges. There are several opportunities for EPA to use its influence to 

advance the state of green electronics design by convening multi-stakeholder groups 

with the goals of:

oDeveloping a shared vision of what truly sustainable electronics should look like, 

and providing clear end-goals for design standards development.

oPromoting the integration of end-of-life considerations into front-end product 

designs.

oExtending the useful life of electronic products, and assessing the optimal amount of 

time to keep products in operation.

oSupporting the creation of environmental criteria for refurbished equipment.

oAddressing other high-priority questions and challenges identified by the 

stakeholder community.

 11 Federal Energy Management Program, http://www1.eere.energy.gov/femp/. 12 Green Electronics Council. Electronic Product Environmental Assessment Tool, www.epeat.net. 13 EO 13514, http://edocket.access.gpo.gov/2009/pdf/E9-24518.pdf, section 2(h).
July 2011

National Strategy for Electronics Stewardship 10

EPA, in cooperation with GSA, will support convening of multi-stakeholder groups, 

including electronic product designers, refurbishers, recyclers, NGOs, and academic and 

other technical experts to address those and other challenges. The Federal Government

will consider joining or supporting industry initiatives when appropriate.

 Promote consumer purchasing of green electronics that are certified as meeting 

stringent environmental performance criteria that address environmental 

impacts across the entire lifecycle of the products.

Advancing the state of green electronics design will not have any long term effect if 

consumers do not purchase green electronics. As the Federal Government directs its 

purchasing toward electronics that meet ENERGY STAR, EPEAT, and other standards, it 

should also encourage private consumers to adopt green electronics certifications in 

their purchasing decisions.

EPA will initiate an outreach program to encourage purchasing of green electronic by 

private consumers.

EPA will encourage consumer procurement of products that are EPEAT registered and 

will continue supporting ENERGY STAR program outreach to consumers.

EPA will launch a Greener Products Website to help consumers more easily find 

information on greener products.

 Promote scientific research and technological developments that improve our 

ability to recover and market valuable materials from used electronics, especially 

precious metals and rare earth elements.

Currently, there is limited, but growing, domestic capacity in the US to recover valuable 

materials from used electronics (e.g., precious and rare earth metals). Used electronics 

in the US are often exported to facilities outside the US that are capable of extracting 

these materials.14

 14 Per preliminary results from an industry survey focusing on R2 certified recycling firms in 2010. Eric 

Harris, presentation on 2011 Electronics Recycling Survey (Preliminary Report), Institute of Scrap Recycling 

Industries, Inc., April 7, 2011; summarized at 

 Increased domestic recovery capacity has the potential to stimulate 

investment and the creation of jobs in the reuse and recycling industries. Some of the 

challenges to investing in domestic capacity include development of advanced 

techniques for metal/material recovery, the cost of such a facility, and reliability of a 

stream of source material for recycling/recovery.

www.isri.org/iMIS15_PROD/ISRI/Whats_New/ISRI_Unveils_Preliminary_Findings_from_2011_Electronics_Re

cycling_Industry_Survey.aspx.
July 2011

National Strategy for Electronics Stewardship 11

At the same time, there are numerous 

federal programs to support 

technology innovation, economic 

development, and advanced 

manufacturing, as well as state and 

local programs to promote economic 

and workforce development. These 

programs could support the 

development of a more robust 

domestic electronics recycling 

industry.

The Federal Electronics Stewardship Working Group (FESWG)15 helps develop Federal 

policies, guidance, reporting metrics and other documents in support of EO 13514, and 

is a forum for information exchange and coordination on electronics stewardship. The 

Interagency Sustainable Acquisition and Materials Management Practices Workgroup 

(SAMM)16

In order to meet US environmental and economic goals, EPA will lead an interagency 

effort, involving the Department of Defense, Department of Energy, and the Department 

of the Interior’s US Geological Survey, and in partnership with FESWG and SAMM and 

those workgroups’ member agencies, to explore and develop recommendations for 

identifying and addressing market, financial, and regulatory barriers to investment in 

domestic material recovery from used electronics.

helps to identify, characterize, and document markets and market 

opportunities associated with acquisition, materials management and recycling. In 

conjunction with improved tracking of electronics products, improved understanding of 

the market opportunities for electronics recycling would facilitate development and 

implementation of improved approaches and policies for managing Federal used 

electronics, encourage domestic development and investment in these market 

opportunities, and discourage production of e-waste.

To address health issues and challenges regarding recovery of rare earth elements, EPA 

will support research into the toxicology, exposure pathways, and recovery 

methodologies of the rare earth elements (and their compounds) used in electronics 

and during their recycling, remanufacturing and disposal.

 15 FESWG is convened by Office of the Federal Environmental Executive (OFEE). 16 SAMM is convened by the OFEE.
July 2011

National Strategy for Electronics Stewardship 12

 Launch electronics stewardship prize competitions to stimulate innovations in 

green product design, recycling solutions, and other phases of the electronics 

lifecycle.

The America COMPETES Reauthorization Act of 201017

EPA, in cooperation with GSA, CEQ and the Office of Science and Technology Policy 

(OSTP) and relevant agencies, will launch the development of a series of prize 

competitions and leverage private sector and philanthropic support for awards to spur 

innovations in technology and design to be applied across the lifecycle of electronics.

gave every Federal agency the 

authority to conduct prize competitions to accelerate problem-solving by tapping 

America’s top talent and best expertise wherever it may lie. In particular, the Act 

authorizes agencies to use not only Federal funds for cash and other prizes, and for 

prize programs’ design and administration, but also private sector funds for cash prizes 

and prize program design and administration. The opportunity to leverage privatesector funds to provide prize purses is a particularly important one for the government 

in the current and projected fiscal climate, and prize competitions can be effectively 

applied to design and systems challenges across the electronics lifecycle.

EPA, GSA CEQ and OSTP will, as part of developing these competitions, coordinate with 

other agencies to initiate the solicitation of public comment on how to most effectively 

target limited prize resources toward the highest-impact challenges.

 Ensure expansion of quality green electronics certification programs, including 

EPEAT, to consider environmental impacts across entire product lifecycles and to 

cover additional types of electronics.

Existing green electronics programs, including ENERGY STAR and EPEAT, help Federal 

and private consumers identify and purchase greener electronics that are held to 

transparent standards. Although these programs encourage green design and drive 

Federal purchasing toward more sustainable products, they can be improved to cover 

additional electronics products and to identify the lifecycle impacts that electronics 

have on the environment.

There is an opportunity, especially in the EPEAT program, which currently only covers 

laptops, desktops and monitors, to expand and become more robust at a faster rate with 

more support from key Federal agencies.

 17 Public Law 111-358, section 105, Prize Competitions; 15 U.S.C. § 3719; www.gpo.gov/fdsys/pkg/PLAW111publ358/html/PLAW-111publ358.htm.
July 2011

National Strategy for Electronics Stewardship 13

EPA will support and engage in development of new standards addressing products not 

covered by EPEAT, and include stakeholder input into standards development.

GSA will join the EPEAT standard development process to represent the interests of the 

Federal Government as a consumer.

The Task Force also supports EPA’s efforts 

to expand the ENERGY STAR program 

beyond its focus on energy consumed by 

electronics while in use. For many of the 

electronics products covered by the 

ENERGY STAR program, EPA is exploring 

the possibility of expanding its 

specifications to include energy outside the 

use phase and other environmental aspects 

as appropriate.

GSA and EPA, building upon existing Federal Government efforts, such as the 

Interagency Sub-Working Group on Standards and Ecolabeling operating under 

Section 13 of EO 13514, to develop guidance for selecting environmental standards and 

ecolabels in Federal procurement, will identify any additional standards and eco-labels 

to include in expanded green electronics certification programs, and additional 

programs in which Federal participation should be considered.

Ensure that the Federal Government Leads By Example

As one of the largest consumers of electronics, the Federal Government has the particular 

opportunity and responsibility to purchase, use, and recycle its electronics with the goals 

of: protecting public health and the environment; creating new and strengthening existing 

markets for reused, refurbished, and recycled electronic equipment and materials; 

expanding opportunities for domestic job creation; improving electronics design and 

management practices; and safeguarding data.

The Federal Government will lead by example in this effort by ensuring that it is the 

Nation’s most responsible consumer of electronics. This approach will bring an 

unprecedented level of transparency to the Federal Government’s efforts and waste 

stream, so private organizations and consumers can learn from its successes and highlight 

opportunities for improvement. The Federal Government will leverage its purchasing 

power to drive the electronics manufacturing and recycling industries toward more 

sustainable products and practices.
July 2011

National Strategy for Electronics Stewardship 14

Through the following efforts, the Federal Government will foster improved electronics 

stewardship at home and abroad:

 Establish a comprehensive and transparent government-wide policy on used 

Federal electronics that maximizes reuse, clears data and information stored on 

used equipment, and ensures that all Federal electronics are processed by 

certified recyclers.

The Federal Government generates the most used electronics in the US, resulting, in 

part, from its efforts to meet the ever increasing needs of citizens and businesses in an 

ever more efficient manner, which requires contemporary electronic equipment. The 

Federal Government currently follows a policy to employ environmentally sound 

disposition practices when handling excess Federal electronics and has several 

programs to encourage reuse, including the GSA Xcess® website,18

Computers for 

Learning

through which 

agencies register excess property and search for opportunities for its reuse by other 

Federal agencies and eligible state and local recipients, and the 

19

GSA will issue, through interagency collaboration and with public input, a revised 

Federal Electronics Stewardship Policy to bring Federal management of used 

electronics in line with current best practices; these include:

program, through which agencies donate used computers to schools and 

many eligible educational non-profit organizations. The Interagency Task Force has 

identified many opportunities to improve these programs and the policies under which 

agencies use them as well as opportunities to develop new programs where 

appropriate.

 Division of functional and nonfunctional equipment into distinct streams, where:

o Functional equipment is directed through the government’s current hierarchy 

of reuse opportunities: transfer to Federal agencies, donation to schools, 

transfer to eligible state and non-profit organizations, or sale to private 

consumers; and

o Non-functional equipment is directed to third-party certified recyclers or 

refurbishers, or to manufacturer take-back programs that use certified 

recyclers;

 Consistent practices to wipe hard drives and other storage devices, in order to 

protect sensitive data and maximize reuse potential by using least-destructive 

sanitization procedures wherever appropriate;

 18 GSA Xcess® website, http://gsaxcess.gov/. 19 Computers for Learning. http://computersforlearning.gov/. The program evolved as a guide for 

implementing EO 12999, Educational Technology: Ensuring Opportunity for all Children in the Next Century, 

http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=1996_register&docid=fr19ap96-137.pdf.
July 2011

National Strategy for Electronics Stewardship 15

 Prohibition of sale of non-functional equipment through public auctions, except to 

certified recyclers or refurbishers; and

 A landfill ban on used Federal electronics.

Along with the revised Federal Electronics Stewardship Policy, GSA will propose 

revisions to the relevant sections of the Federal Management Regulation,20

Federal Acquisition Regulations

in addition 

to revisions already pending to the ,21 and related 

guidance documents. The revised Federal electronics policy and regulations will build 

on existing Federal programs to promote electronics reuse and recycling, clearly define 

what Federal agencies must do to comply with their electronics stewardship 

requirements under EOs 13423 and 13514, and work toward GSA's long-term goal of 

hosting all agencies’ asset management systems on one shared, cloud-based system, 

once funding for such a system is available. The revised policy will include a 

requirement that Federal agencies only dispose of non-functional electronic equipment 

using contracts with sales or sales to refurbishers or recyclers certified under an 

accredited, third-party electronics recycler certification program,22

EPA, in consultation with and support from GSA and other relevant departments and 

agencies, will develop a baseline set of criteria to be included, at a minimum, in 

electronics recycling standards that are to be used in managing the Federal 

Government’s used electronics.

or manufacturer 

take-back programs that utilize refurbishers or recyclers certified under such a 

certification program.

This baseline list of criteria will cover such basic principles as: developing and 

implementing an environmental, health and safety management system; complying 

with applicable environmental, health and safety requirements; promoting reuse and 

recycling over disposal; and ensuring that all downstream handlers of the used 

electronics, including handlers of e-waste, manage these materials in a way that 

protects the environment, public health and worker safety. Once developed, the full list 

of criteria will be made publicly available.

In addition, to ensure that the Federal Government’s used electronics are properly 

managed, EPA, in collaboration with GSA, will investigate with the applicable 

 20 GSA Federal Management Regulation, www.gsa.gov/portal/category/21221. 21 Federal Acquisition Regulation, www.acquisition.gov/far/index.html. Interim Federal Acquisition 

Regulation; Sustainable Acquisition, 76 FR 31395-31402; May 31, 2011; www.gpo.gov/fdsys/pkg/FR-2011-

05-31/pdf/2011-12851.pdf. See, especially, interim FAR section 39.101(b)(1) on electronic stewardship 

requirements for acquiring information technology, and its discussion in the rulemaking preamble at 

p. 31396. 22 See the discussion of certification on pp. 21-22.
July 2011

National Strategy for Electronics Stewardship 16

accreditation board the need to initiate a study of the implementation of the current 

used electronics certification programs. This review will be repeated as needed, and 

will evaluate such aspects of the certification programs as: vigorousness of facility and 

downstream audits; consistency and frequency of audits; and auditor training.

GSA will consider the published criteria, the results of the implementation study, and 

other requirements and considerations when determining which certification programs 

satisfy agencies’ requirements to use certified recyclers under the revised Federal 

Electronics Stewardship Policy.23

 Encourage electronics manufacturers to expand their product take-back 

programs, and use certified recyclers as a minimum standard in those programs, 

by expanding the use of manufacturer take-back agreements in Federal 

electronics purchase, rental and service contracts.

 GSA will make this initial determination once the 

regulations implementing the revised Federal Electronic Stewardship Policy are in 

place, and re-evaluate that determination every three years at a minimum thereafter.

Many electronics manufacturers have created product take-back programs, where they 

dispose of used equipment after taking it back from customers, either on a voluntary 

basis or through one of the many state or tribal recycling programs. Electronics 

procurements (for this document, this refers to purchases, rentals and service 

contracts) are sometimes made from manufacturers who have committed to provide 

take-back services to customers as part of demonstrating the product’s conformance to 

the standards used by the EPEAT certification program.24

Many federal procurement actions involve procuring a service, not a product. For 

example, many federal agencies have Print Management Service Contracts under which 

they lease multifunction copiers in order to procure the service of being able to print 

documents. Under these lease agreements or service contracts, the products return to 

the manufacturer at the end of their useful life or the end of the contract. These lease 

agreements can be improved to require any products taken back by the manufacturer 

to be evaluated for reusability and any nonfunctioning equipment to be sent to a 

recycler which is certified for recycling. Expanding the use of take-back agreements

 23 These programs may be domestic, foreign, and/or international. See Office of Management and Budget, 

Circular A-119 Revised, Federal Participation in the Development and Use of Voluntary Standards, 

February 10, 1998; www.whitehouse.gov/omb/circulars_a119/. 24 One of the minimum requirements manufacturers must meet to achieve EPEAT certification of their 

products is to make take-back services available to their first-tier institutional users. IEEE Standard 1680.1, 

IEEE Standard for Environmental Assessment of Personal Computer Products, Including Notebook Personal 

Computers, Desktop Personal Computers, and Personal Computer Displays, section 4.6.1.1, Provision of 

product take-back service; see www.epeat.net/Criteria.aspx#criteriatable and 

www.epeat.net/Docs/Summary%20of%20EPEAT%20Criteria.pdf.
July 2011

National Strategy for Electronics Stewardship 17

in Federal procurement will incentivize industry to increase remanufacture and 

environmentally responsible recycling of those products, as well as provide additional 

avenues for the users and re-users of Federal 

equipment to dispose of equipment no longer in use 

safely.

GSA will begin to pilot the use of manufacturer takeback agreements in additional electronic product 

categories through purchases it makes for GSA 

operations and changes to its internal purchasing 

policies, with the goal of developing guidelines for how 

all Federal agencies should include take-back 

agreements in all electronics purchases, as well as 

criteria to include in those agreements to ensure that 

manufacturers follow sound disposition practices when 

handling taken-back equipment, including the use of 

certified recyclers and those state and tribal recycling 

programs that use certified recyclers. GSA will develop the take-back agreements 

guidance through interagency collaboration and with public input.

 Require and enable recipients of former Federal equipment that has been sold, 

transferred, or donated for reuse to use certified recyclers and follow other 

environmentally sound practices, to the greatest extent possible.

Like almost all equipment owners, the Federal Government currently has little 

knowledge of, or influence over, how its downstream re-users (first-tier, second-tier, 

etc.) handle or dispose of surplus equipment when that equipment has reached the end 

of its useful life. When organizations or individuals purchase excess or surplus Federal 

equipment, or receive surplus equipment through transfer of donation programs (e.g., 

Computers for Learning25

The Federal Government has the opportunity to encourage and facilitate the proper 

recycling of electronic equipment at end of life and ensure that all Federal equipment is 

recycled properly, while preserving the opportunity for non-Federal entities, especially 

schools, to reuse Federal equipment at low- or no-cost, by requiring, wherever possible, 

its downstream re-users to follow the same requirements as Federal agencies disposing 

of non-functional equipment.

), they are not obliged to handle that equipment in an 

environmentally sound manner, nor are they typically provided the information about 

resources needed to do so.

 25 GSA Computers For Learning Program, http://computersforlearning.gov/.
July 2011

National Strategy for Electronics Stewardship 18

GSA, in coordination with EPA, DoD, and others as appropriate, will issue guidance to 

Federal agencies on how to incorporate requirements for sound disposition practices, 

including the use of certified recyclers, into the agreements signed by recipients of sold, 

donated, or transferred Federal used electronics. Those requirements will mirror those 

placed on Federal agencies handling end-of-life equipment under the revised Federal 

Electronics Stewardship Policy and, to the greatest extent practicable, make the same 

options available to Federal agencies for disposition of equipment (e.g., manufacturer 

take-back or Federal refurbishment or recycling programs) available to these 

recipients.

GSA, EPA, DoD, and other agencies as appropriate will develop educational materials for 

those recipients of Federal used electronics so they understand their obligations and 

how to fulfill them, with the first materials issued concurrently with the sound 

disposition practices guidance.

 Improve tracking of used Federal electronics throughout the lifecycle and post 

comprehensive data sets on Data.gov and other publicly accessible websites.

The current Federal tracking and reporting framework for electronic equipment does 

not collect data on all of the different streams of used electronics leaving Federal 

ownership, nor does it collect comprehensive data on the functionality or recipients of 

the equipment streams it does cover. This leaves the ultimate destination and 

disposition of this equipment unknown, making it difficult to measure the effectiveness 

of Federal policies and demonstrate responsible management of taxpayer assets. It also 

consists of several different, sometimes duplicative and inconsistent reporting 

mechanisms. Improving electronics lifecycle tracking systems would provide the 

opportunity to manage the use and disposition of this equipment more efficiently and to 

encourage and facilitate environmentally sound use and disposition practices.

GSA will issue revised property disposition reporting guidance to Federal agencies that 

streamlines all reporting mechanisms under the annual Report of Non-Federal 

Recipients. The new reporting system will gather data on the type, quantity, recipients, 

and intended use, including disposal as e-waste, of the electronics leaving Federal 

ownership, and be consistent with data gathered when the government purchases 

electronics, in order to track Federal electronics across their lifecycles more effectively.

GSA will then develop tools which agencies can adapt their internal tracking systems, 

and propose revisions to the relevant sections of the Federal Management Regulation.
July 2011

National Strategy for Electronics Stewardship 19

GSA will post data annually on Data.gov, 

beginning once the new Federal tracking 

system is in place.

The Federal Electronics Stewardship 

Working Group will recommend metrics 

and other reporting tools to measure 

agencies’ progress in implementing the 

revised Federal Electronics Stewardship 

Policy to CEQ, including efforts to monitor 

Federal acquisition, operation, management, and disposal of electronics.

GSA will coordinate with EPA, CEQ, DoD, DOJ, and other agencies to determine the most 

cost-effective level of detail at which to track Federal electronics, and the appropriate 

exceptions to protect the security of equipment used for national security purposes by 

DoD, DHS, and other agencies.

 More effectively direct Federal Government spending on electronics toward 

greener products through procurement changes.

The Federal Government currently directs its considerable spending on electronics 

toward greener products by requiring purchase of ENERGY STAR and EPEAT 

electronics whenever they are available. Some electronics not compliant with these 

programs are listed on procurement schedules; in many cases, these programs do not 

cover the products, in some they do. There are several changes that can be made to the 

way the government purchases electronics to improve implementation of these 

requirements.

GSA will work, to the maximum extent practicable, to remove all products that are not 

ENERGY STAR or EPEAT, within product categories where ENERGY STAR qualified and 

EPEAT registered products are available, from the standing Government-wide 

information technology acquisition contracts it maintains for Federal agencies’ use. 

GSA will implement this change as those contracts expire and are eligible for renewal.

GSA will work with OMB to expand the use of green purchasing training by Federal 

employees involved in electronics purchasing, including procurement professionals, 

purchase card holders, information technology professionals, and other procurement 

request originators, so they are aware of the requirements and benefits of purchasing 

green electronics.
July 2011

National Strategy for Electronics Stewardship 20

Since the DoD spends billions of dollars on procurement of electronics manufacturing, 

retail, rental, repair, and maintenance services annually,26

Finally, the Federal Government will work internally, as well as with the computer 

refurbishing industry to explore how best to make cost-effective refurbishment services 

available to Federal agencies to extend the useful life of non-functional equipment in 

Federal hands.

its massive buying power can 

be leveraged to promote green electronics throughout the US defense industrial base. 

The DoD will promote green electronics as a source selection preference (for weapon 

system procurements), but not necessarily as a requirement due to performance 

requirements tied to national security needs. Defense prime contractors (e.g., weapon 

systems integrators) will levy these preferences on their suppliers, and green 

electronics promotion will ripple through the entire defense supply chain.

GSA will, as part of this effort, solicit input from industry and the public on whether 

providing refurbishment as a service to Federal agencies fits into viable business 

models for refurbishers, what appropriate standards and certifications ought to be 

considered, and how best to build Federal contracts for such services.

 Expand the use of the intergovernmental cooperative agreements between the US 

Postal Service and other federal agencies to make it more convenient, efficient, 

and cost effective for government agencies with remote offices to directly ship 

used electronics to original equipment manufacturers, certified recyclers, or 

entities that will reuse the equipment.

The US Postal Service (USPS) has the Nation’s largest network of package delivery and 

pickup services. Typically, its delivery vehicles empty as the carriers complete their 

routes, yielding an available, if unused, opportunity for picking up used electronics at 

low incremental transportation cost. USPS can help government agencies with remote 

offices lead by example by providing more convenient and cost effective methods to 

ship used electronics. The USPS Merchandise Return Service, and its Carrier Pick-Up 

enable government agencies to provide remote offices with prepaid postage and 

shipping supplies to directly ship electronics to original equipment manufacturers, to 

certified recyclers, and entities that will reuse the equipment.

 26 At least the $5.46 billion in Fiscal Year 2009 DoD contracts to firms in industries with North American 

Industry Classification System (NAICS) codes focusing on electronics. DoD Office of Small Business Programs, 

FY09 DoD Contract Obligations by NAICS Code, www.acq.osd.mil/osbp/doing_business/index.htm. 

Additional funds for subcontracts dealing with electronics were awarded by DoD contractors in other 

industries.
July 2011

National Strategy for Electronics Stewardship 21

The USPS will work with other Federal agencies to establish intergovernmental 

Memoranda of Understanding (MOUs) to expand the use of USPS services (e.g., 

Merchandise Return Service, and Carrier Pick-Up) to provide government agencies, 

especially those with remote domestic offices, with more convenient and cost effective 

methods to directly mail or ship electronics to original equipment manufacturers, 

certified recyclers, or entities that will reuse the equipment.

Increase Safe and Effective Management and Handling of Used Electronics in the 

United States

American businesses, government, and individuals share the opportunity and 

responsibility in becoming better stewards of our global environment. The Federal 

Government recognizes its lead role in guiding and facilitating activities to achieve this 

shared goal. The Federal Government can engage communities, state, tribal and local 

governments, nonprofits, academia, and industry to increase recycling rates using certified 

recyclers, prevent discarded electronics from ending up in our landfills and expand our 

capacity to recycle used electronics for the betterment of our economy, health and 

environment.

There are a variety of players in the management of used electronics: collectors, who 

collect the electronics; brokers, who buy and sell used electronics, often via the Internet; 

refurbishers, who take computers no longer in use and 

refurbish them for reuse; and recyclers, who refurbish and 

dismantle the electronics, often into upgraded equipment 

or components. The number of collection programs and 

collection of used electronics has increased in recent years

due mainly to the number of state take-back laws that 

have been enacted.

There is a range of tools to help ensure used electronics 

are recycled in an environmentally sound manner, 

including accredited third-party certification programs, 

best practices, and increased knowledge and transparency 

of the companies and practices along the recycling chain. 

Quality electronics recycling certification programs not 

only advance best management practices, but also offer a 

way to assess the environmental, worker health and safety, and security practices of 

entities handling used electronics. Currently, there are two voluntary systems certifying
July 2011

National Strategy for Electronics Stewardship 22

electronics recyclers: R227 and e-Stewards.28

However, there is little information available on what happens to used electronics at the 

end of their useful life (i.e., reused, recycled, or disposed of as e-waste, and in what 

volumes). This type of information would be useful to determine the most effective 

approaches to collection, recycling and reuse. There is also opportunity to engage industry, 

NGOs, and other stakeholders to identify incentives for increasing responsible reuse and 

recycling by businesses, State, Tribal and local governments, and the general public. 

Although there is currently great capacity for managing used electronics in the US, there 

remain many opportunities to build upon these systems and improve the safe and effective 

handling of these materials throughout the process from collection to recycling.

 The electronics recycling industry has been 

quick to embrace the new certification programs. As of the publication of this document, 

about 57 companies have had one or more of their facilities certified, representing about 

100 different locations.

The Task Force has identified the following approaches to achieving this broader goal:

 Launch voluntary partnerships with the electronics industry to:

o Increase collection of used electronics that is safely managed by certified 

recyclers.

o Develop tools and materials that encourage the American public, businesses, 

states, and tribal nations to use certified recyclers.

o Increase consumer awareness about the importance of electronics recycling, 

as well as the tools and services available to do so.

o Involve States, tribal nations, NGOs and other stakeholders on the key 

elements of the voluntary initiative.

EPA will seek the commitment of electronics industry companies that use electronics 

recycler certification programs and those who also go above and beyond those practices to 

increase their use of certified recyclers and provide data in a transparent manner.

In the short-term, EPA will work with these companies and other industry stakeholders to 

launch a voluntary partnership aimed at increasing the safe management of used 

electronics through the use of certified recyclers as a floor.

EPA will work with the electronic industry and other stakeholders to recognize best 

management practices for downstream management, encourage public disclosure, and 

promote tracking beyond third-party certification.

 27 R2, www.R2solutions.org; operated by R2 Solutions.

28 E-Stewards, http://e-stewards.org/; operated by the Basel Action Network.
July 2011

National Strategy for Electronics Stewardship 23

In the longer-term, this EPA initiative will strive for continuous improvement of the safe 

and effective handling of these materials throughout the system from collection to 

recycling to downstream facilities. This program will also educate consumers on the 

importance of reusing or recycling used electronics, and the methods and locations to do 

so.

 Provide guidance to electronics recycling employers on providing facilities that 

offer safe and healthy working environments.

The Department of Labor’s (DOL’s) Occupational Safety and Health Administration 

(OSHA) provides compliance assistance,

29

green jobs

including on-line and printed materials to 

help employers comply with, and workers understand, OSHA requirements and learn 

about OSHA’s cooperative programs. One of the areas highlighted by these programs is 

on hazards in ,

30

Green Job Hazards: Waste Management and Recycling

which DOL defines broadly as jobs that help to improve the 

environment, and which includes the work covered in this strategy. Designing work 

processes and equipment in a way that eliminates hazards to workers that will help 

ensure that green jobs in electronics recycling and related industries are safe jobs. DOL 

recognizes recycling as one of the important industries within the green job sector, has 

posted a webpage on ,31

Guidance for the Identification and Control of Safety and Health Hazards in 

Metal Scrap Recycling

and has 

published 

.

32

Prevention through Design (PtD)

 DOL especially encourages those industries that are beginning 

to grow, such as electronics recycling and related industries (e.g., remanufacturing, 

refurbishing), to use the concept of ,33

DOL will develop and post material for its Green Job Hazards: Waste Management and 

Recycling webpage that addresses the electronics recycling and related industries.

that is, 

addressing occupational safety and health needs in the design process to prevent or 

minimize the work-related hazards and risks.

DOL will publish and post guidance for the identification and control of safety and 

health hazards in electronics recycling and related industries.

 29 OSHA Compliance Assistance, www.osha.gov/dcsp/compliance_assistance/index.html. 30 OSHA Green Job Hazards, www.osha.gov/dep/greenjobs/index.html. 31 OSHA Green Job Hazards: Waste Management and Recycling, 

www.osha.gov/dep/greenjobs/recycling.html. 32 OSHA Guidance for the Identification and Control of Safety and Health Hazards in Metal Scrap Recycling, 

www.osha.gov/Publications/OSHA3348-metal-scrap-recycling.pdf. 33 CDC Prevention through Design, www.cdc.gov/niosh/topics/PtD/.
July 2011

National Strategy for Electronics Stewardship 24

 Establish approaches to gather, track, and provide public access to information 

on quantities and movement of used electronics within the US.

As indicated above, the absence of a comprehensive tracking and reporting framework 

for electronic equipment makes the ultimate destination and disposition of this 

equipment unknown, making it difficult to measure the effectiveness of end-of-use and 

end-of-life practices. Improving electronics lifecycle tracking systems would provide 

the opportunity to manage the use and disposition of this equipment more efficiently 

and to encourage and facilitate environmentally sound use and disposition practices. 

Working with states, local jurisdictions, and other stakeholders that already have 

tracking and information systems in place will expedite and inform the development of 

improved tracking systems.

EPA, in coordination with DOC, GSA, and other federal agencies will work to identify 

methods for domestic tracking of used electronics through a research agenda.

EPA, in coordination with DOC, GSA, other federal agencies, universities and other 

entities, will determine if it can develop and publish an online tool so the public can 

access information on the quantities and flows of used electronics, and, if so, implement 

the tool.

Reduce Harm from US Exports of E-Waste and Improve Safe Handling of Used 

Electronics in Developing Countries

As American consumers continue to upgrade their computers, cell phones and TVs for the 

latest and most modern devices, a growing stream of e-waste from this turnover in 

products is producing unintended effects in the US and abroad. Used electronics in 

developing countries, which include exports from the US and other developed countries, 

combined with electronics discarded by their own consumers, are causing negative health 

and environmental effects. Though reliable and up-to-date information and data are 

scarce, a 2005 US industry report34 stated that recyclers export 74% of their used 

electronics for reuse, refurbishing and recycling. EPA estimated that the US generated 

2.4 million tons of e-waste in 2010,35 comparable to the 2.3 million tons36

 34 International Association of Electronics Recyclers. IAER Electronics Recycling Industry Report. 2006 

Update. 

that China 

produced that same year, according to a 2010 United Nations Environmental Programme 

www.iaer.org/communications/indreport.htm (report available at cost).

35 EPA. Electronics Waste Management in the United States through 2009. EPA 530-R-11-002, May 2011.

www.epa.gov/epawaste/conserve/materials/ecycling/docs/FullBaselineReport2011.pdf. 36 UNEP. Recycling – From E-waste to Resources. 2010; www.unep.org/PDF/PressReleases/EWaste_publication_screen_FINALVERSION-sml.pdf.
July 2011

National Strategy for Electronics Stewardship 25

(UNEP) report, making the two countries the generators of the largest amounts of used 

electronics.

As one of the largest consumers of electronics in the world, the US has the responsibility to 

minimize the negative effects that discarded electronics have on health and the 

environment, in the US and abroad. The Task Force also recognizes that global markets 

play an important role in reuse, remanufacturing, and recycling of used electronics, 

creating environmental, economic, and social benefits, including bridging the digital divide 

by providing access to information technology products to many people in developing 

countries who would otherwise be unable to afford them. The proximity to markets where 

electronics are manufactured and where raw materials are available affects where 

recycling and other processing of used electronics takes place, as do available technologies, 

environmental standards, and labor rates. For example, there is high demand in Asia for 

used electronic components for remanufacturing electronics.

However, the Task Force has serious concerns about unsafe handling of used electronics, 

especially discarded electronics or e-waste, in developing countries, that results in harm to 

human health and the environment. For example, there are problems with open-air 

burning and acid baths being used to recover valuable materials from electronic 

components, which expose workers to harmful substances. There are also problems with 

toxic materials leaching into the environment due to improper disposal of e-waste in 

developing countries.

The following Federal agency efforts will complement the domestic efforts described in the 

preceding sections to improve US electronics stewardship in the international context:

 Improve information on trade flows and handling of used electronics, and share

data with Federal and international agencies, within the limits of Federal 

authorities.

Better understanding of the electronics lifecycle is critical to effective electronics 

stewardship. Used electronics are exported from the United States to both developed 

and developing countries. Countries’ environmental, health and safety legal and 

regulatory regimes affect how used electronics are handled. There are significant 

differences in capacity to safely manage used electronics among facilities, and specific 

processes (e.g., refurbishment or remanufacturing versus recycling) may pose different 

levels of risk to the environment and health. A more comprehensive and detailed 

understanding of the “fates” of used electronics exports in this complex landscape will 

enable agencies to prioritize their actions on limiting specific activities that lead to 

harm to health and the environment (e.g., “backyard” operations, shipments to “sham” 

recyclers).
July 2011

National Strategy for Electronics Stewardship 26

There is very little verifiable information about the trade flows of used electronics, 

including amounts exported or imported. Better data are needed to create a more 

comprehensive picture of the overall trade flows; countries could use such data to assist 

in managing their used electronics in accordance with their relevant domestic policies. 

Accurate information about the amounts, types of materials and destinations of used 

electronics exported will provide valuable information for the Federal Government, 

private industry, and other stakeholders. It is possible to improve the limited 

information currently available through Harmonized Tariff Schedule37

Automated Export System

and the

38

Harmonized Tariff Schedule

(see text box below) on trade flows of used electronics.

The Harmonized Tariff Schedule is a system of numerical codes that importers and 

exporters are legally required to use to classify their products prior to export or import. 

These HTS classification numbers are reported to US Customs & Border Protection (CBP) 

through the Automated Export System (AES) or, if the shipment is exempted from filing 

through the AES, are provided to CBP prior to export. The United States uses the HTS 

system as a foundation for determining both Schedule B numbers, which are used to 

generate export statistics, and the Harmonized Tariff Schedule of the United States 

(HTSUS), which is used in the import process. The HTSUS and Schedule B numbers 

capture categories of electronics, but do not distinguish between new or used products, 

nor do they have a single, separate category for electronics.

USTR will work with other federal agencies to explore ways to gather better, more 

detailed, trade data, including a study on US exports of used electronics to improve 

understanding of trade flows as well as provide information that could be used to help 

propose new Schedule B numbers to distinguish between new and used electronics in 

US export data.

EPA, DOC, USTR, and other relevant agencies will discuss ways in which to gather and 

share accurate data on used electronics exports. There are two ongoing projects that 

are already working to improve information on trade flows of used electronics from 

North America – one led by UN University’s Solving the E-waste Problem (StEP) 

Initiative39 Commission for Environmental Cooperation of North 

America

and the other by the 

(CEC),40

 37 Harmonized Tariff Schedule, 

a trilateral partnership among the US, Canada and Mexico.

http://hts.usitc.gov/; it is maintained by the United States International Trade 

Commission, an “independent, quasijudicial Federal agency” (www.usitc.gov/press_room/about_usitc.htm). 38 Automated Export System, http://www.cbp.gov/xp/cgov/trade/automated/aes/. 39 Solving the E-waste Problem, (StEP) Initiative, www.step-initiative.org. 40 Commission for Environmental Cooperation of North America, www.cec.org.
July 2011

National Strategy for Electronics Stewardship 27

EPA will work with other relevant agencies to develop an agreement for sharing export 

data on electronics across Federal agencies. This will help provide valuable information 

that EPA can use to enforce the rule that establishes conditions for the export of 

computer monitors and television sets containing cathode ray tubes (CRTs), which are 

often hazardous when disposed because of the presence of substantial amounts of lead.

EPA, DOC, and other relevant agencies will develop and implement a system for making 

information on used electronics flows available to the public.

 Provide technical assistance and establish partnerships with developing 

countries to better manage used electronics.

Many developing countries are confronting the dual challenge of managing the flow of 

used electronics exports from developed countries, as well as managing their own 

volumes of consumer-discarded electronics. The 2010 UNEP Report cited above 

predicts that by 2020, e-waste from old computers in South Africa and China will grow 

by 200 to 400% of 2007 levels, and in India by 500%.41

EPA and other relevant agencies will initiate a partnership with international 

organizations and others to share best practices for recycling with developing 

countries. Federal agencies will build on and enhance coordination among different 

bilateral and multilateral initiatives and organizations, including the 

As the US works to minimize 

the negative effects of used electronics at home and abroad and as other countries 

increasingly confront similar challenges in electronics stewardship, the United States 

has an opportunity to work with other countries to address the environmental and 

health impacts of unsafe handling of used electronics as a shared concern. The Federal 

Government can share best practices, and promote sharing by others, with developing 

nations on how to efficiently and effectively manage used electronics.

Partnership for 

Action on Computing Equipment42 Organisation for Economic Co-operation 

and Development

(PACE), the 

43 (OECD), the CEC,44

 41 UNEP. Recycling – From E-waste to Resources. 2010; 

, implementation of EPA’s bilateral agreements 

http://www.unep.org/PDF/PressReleases/EWaste_publication_screen_FINALVERSION-sml.pdf, pp. 49-50. 42 PACE, a multi-stakeholder public-private partnership established under the Basel Convention on the 

Control of Transboundary Movements of Hazardous Wastes and their Disposal (www.basel.int), is a forum for 

governments, industry leaders, non-governmental organizations and academia to tackle the environmentally 

sound management, refurbishment, recycling and disposal of used and end-of-life computing equipment. 

www.basel.int/industry/compartnership/documents.html. PACE was established by Basel Convention 

Decision IX/9 (www.basel.int/meetings/cop/cop9/docs/39e-rep.pdf). 43 The State Department describes (at http://usoecd.usmission.gov/mission/overview.html) the OECD 

(www.oecd.org) as a “forum where the governments of 34 democracies with market economies work with 

each other, as well as with more than 70 non-member economies to promote economic growth, prosperity, 

and sustainable development. [It] provides a setting where governments can compare policy experiences, 

seek answers to common problems, identify good practice and coordinate domestic and international 
July 2011

National Strategy for Electronics Stewardship 28

with China and India, the US-China Joint Commission on Commerce and Trade45

StEP Initiative

(JCCT) 

Environment Working Group, and the .

USTR will pursue opportunities to discuss concerns about unsafe handling of used 

electronics in its bilateral and regional dialogues with countries (e.g., Trade and 

Investment Framework Agreements). Discussions could cover the industries and 

markets involved in trade in used electronics as well as trade flows; the environmental, 

economic, and social impacts of that trade; and possible ways to ensure transparency in 

markets and that traded used electronics will be managed safely.

 Work with exporters to explore how to incentivize and promote the safe handling 

of remanufactured, recycled, and used electronics at home and abroad.

Consistent with the President’s Export Council and activities conducted under the 

National Export Initiative, the US will seek opportunities to promote environmentally 

sound exports of recycled and remanufactured electronics. The Federal Government 

will also explore how to incentivize 

and promote the safe handling of 

used electronics, especially e-waste, 

at home and abroad.

Agencies will engage with exporters 

to help ensure shipments of used 

electronics are handled safely abroad. 

Some companies are already taking a 

range and combination of steps, 

including certifying their facilities or 

sending used electronics only to recyclers that are certified; confirming that facilities 

receiving their shipments are properly licensed; requiring a verifiable environmental, 

health and safety management system at these facilities; limiting exports to items they 

believe pose less risk to the environment and health when handled abroad (e.g., 

functional devices); and exporting only to countries where they have confidence with 

respect to facilities’ practices and the environmental, health and safety legal and 

regulatory regime (e.g., developed countries). The Task Force recognizes that there is 

no “silver bullet.” It does believe that companies should seek transparency in their 

“supply” chains and take steps to avoid harm to the environment and health.

 

policies.”

44 Commission for Environmental Cooperation of North America, www.cec.org. 45 US-China Joint Commission on Commerce and Trade, www.commerce.gov/node/12467.
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National Strategy for Electronics Stewardship 29

EPA, USTR and other Federal agencies will seek opportunities to share with exporters 

concerns and information about unsafe handling of used electronics exports abroad. 

They will engage with exporters on the importance of knowledge and transparency 

concerning the practices of such companies as exporters, brokers and recyclers, and 

environmental, health and safety legal and regulatory regimes downstream.

 Propose regulatory changes to improve compliance with the existing regulation 

that governs the export of cathode ray tubes from used computer monitors and 

televisions that are destined for reuse and recycling.

The principal RCRA regulation affecting the export of used electronics from the US is the 

cathode ray tube (CRT) regulation, commonly known as the CRT Rule.46

Since the CRT rule was issued, the production of CRTs has decreased because they have 

been replaced by flat screen computers and televisions. Therefore, they are a 

diminishing fraction of the e-waste stream.

 CRTs are the 

conical or pyramidal video display components of computer and television monitors. 

They are generally considered a hazardous waste under RCRA when disposed of

because of the presence of substantial amounts of lead in their glass. In 2006, EPA 

modified its hazardous waste program to encourage recycling and reuse of CRTs. If 

CRTs are exported for recycling, the exporter must notify EPA and obtain consent from 

the receiving country before shipment. If CRTs are exported for reuse, the exporter 

must only provide a one-time notification to EPA with minimal information.

47 For this reason, many US glass furnaces 

that previously melted CRT glass to make new CRTs no longer accept this glass. 

Nevertheless, there are a substantial number of CRTs in storage,48

EPA will propose changes to the CRT Rule to better track exports of CRTs for reuse and 

recycling. The proposed regulatory changes would clarify who is subject to the rule, 

which may improve compliance throughout the regulated community. Additionally, 

EPA would gather more information on shipments of CRTs that are sent for reuse.

many are still 

exported for recycling or reuse, and some CRTs that are exported for reuse continue to 

be disassembled and recycled under unsafe conditions.

 Support ratification of the Basel Convention on the Control of Transboundary 

Movements of Hazardous Wastes and their Disposal.

 46 See 71 Federal Register 42927-42949, July 28, 2006; and www.epa.gov/osw/hazard/recycling/electron/.

47 EPA, Electronic Waste Management in the United States through 2009. EPA 530-R-11-002. May 2011. 

www.epa.gov/epawaste/conserve/materials/ecycling/docs/FullBaselineReport2011.pdf. Figures 4 and 5.

48 EPA, Electronic Waste Management in the United States through 2009. EPA 530-R-11-002. May 2011. 

www.epa.gov/epawaste/conserve/materials/ecycling/docs/FullBaselineReport2011.pdf. Figure 6, Table 14.
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National Strategy for Electronics Stewardship 30

In 1990, the US signed the Basel Convention on the Control of Transboundary 

Movements of Hazardous Wastes and their Disposal (Basel Convention49

The 

), which is an 

agreement among countries to control imports and exports of hazardous wastes. The 

Senate provided its advice and consent for ratification, but implementing legislation has

not been passed.

Partnership for Action on Computing Equipment50

There are ongoing discussions about whether and how used electronics generally fall 

within the scope of the Basel Convention. Ratification of the Basel Convention would 

enable the US Federal Government to fully participate as a Party (instead of an 

observer) in how the Convention is applied to used electronics and e-waste and 

promotes their safe handling. Ratification would also provide the US with a stronger 

voice in the PACE workgroup.

(PACE) is developing guidance 

on the environmentally sound management of used and end-of-life computing 

equipment with an emphasis on reuse and recycling.

The Department of State and EPA will work together to explore options for 

strengthening US participation in the Basel Convention, including options that would 

enable ratification.

 49 Basel Convention, www.basel.int/text/17Jun2010-conv-e.pdf. 50 PACE, www.basel.int/industry/compartnership/documents.html.
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National Strategy for Electronics Stewardship 31

CONCLUSION

The National Strategy for Electronic Stewardship identifies steps America will take 

together to handle our electronics resources more sustainably from the moment American 

technology pioneers dream of them to the time we entrust them for collection, reuse, 

recycling and disposal. The recommendations outlined here span the entire Federal 

Government, draw on the ingenuity of its employees and programs, provide opportunities 

for the private sector to create green jobs, and coordinate the Government’s leadership role 

in making electronics procurement and disposition choices beneficial for public health, the 

environment, and the economy. Reflecting the valuable input from public comments and 

stakeholder meetings, the strategy also sets in motion a continuing dialogue on how best to 

craft the individual recommendations and actions necessary to seizing the opportunity 

presented by used electronics.

This strategy carries out the intentions of President Obama to address the challenge of 

protecting human health and the environment from potentially harmful effects of the 

improper handling and disposal of these products. In doing so, it represents consistent and 

comprehensive steps forward that will engage government, industry, non-profit, and 

international partners and will call on every American to recognize the value of the 

electronic products integral to our lives and to handle them safely and responsibly.
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National Strategy for Electronics Stewardship 32

ABBREVIATIONS

CBP Customs and Border Protection, within DHS

CEC Commission for Environmental Cooperation of North America

CEQ White House Council on Environmental Quality

CRT Cathode ray tube

DHS Department of Homeland Security

DOC Department of Commerce

DoD Department of Defense

DOE Department of Energy

DOL Department of Labor

EO Executive Order

EPA Environmental Protection Agency

EPEAT Electronic Product Environmental Assessment Tool

FCC Federal Communications Commission

FEMP Federal Energy Management Program

GSA General Services Administration

HTS Harmonized Tariff Schedule

OECD Organisation of Economic Cooperation and Development

OMB Office of Management and Budget

OSHA Occupational Safety and Health Administration, within DOL

OSTP Office of Science and Technology Policy

PACE Partnership for Action on Computing Equipment

R2 Responsible Recycling Practices for Use in Accredited Certification Programs 

for Electronics Recyclers, one of the industry’s practice standards; 

e-Stewards is the other industry practice standard

RCRA Resource Conservation and Recovery Act

UN United Nations

UNEP UN Environmental Programme

US United States of America

USPS US Postal Service