Electronic Waste: Strengthening the Role of the Federal Government in Encouraging Recycling and Reuse
Published: 2005-11-10T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Advances in technology have led to rapidly increasing sales of new electronic devices. With this increase comes the dilemma of managing these products at the end of their useful lives. Some research suggests that the disposal of used electronics could cause a number of environmental problems. Research also suggests that such problems are often exacerbated by the export of used electronics to countries without protective environmental regulations. Given that millions of used electronics become obsolete each year with only a fraction of them being recycled, GAO was asked to (1) summarize information on the volumes of, and problems associated with, used electronics; (2) examine the factors affecting their recycling and reuse; and (3) examine federal efforts to encourage recycling and reuse of these products.
section_title: What GAO Found
paragraphs: Available estimates suggest that over 100 million computers, monitors, and televisions become obsolete each year, and this number is growing. If improperly managed, these used electronics can harm the environment and human health. Available data suggest that most used electronics are probably stored in garages, attics, or warehouses, with the potential to be recycled, reused, or disposed of in landfills, either in the United States or overseas. If disposed of in landfills, valuable resources, such as copper, gold, and aluminum, are lost for future use. Additionally, some research shows that toxic substances with known adverse health effects, such as lead, have the potential to leach from discarded electronics in landfills. Although one study suggests that this leaching does not occur in modern U.S. landfills, it appears that many used electronics are exported to countries without modern landfills or with regulations less protective of human health and the environment. Economic factors inhibit the recycling and reuse of used electronics. Consumers generally have to pay fees and drop off their used electronics at often inconvenient locations to have them recycled or refurbished for reuse. Recyclers and refurbishers charge these fees because their costs exceed the revenue they receive from selling recycled commodities or refurbishing units. In addition to these economic factors, federal regulatory requirements provide little incentive for environmentally preferable management of used electronics. First, the governing statute, the Resource Conservation and Recovery Act, allows individuals and households to dispose of hazardous waste, including many used electronics, in landfills. Second, federal regulations do not provide a financing system to overcome the economic factors deterring recycling and reuse. Third, federal regulations do not prevent the exportation of used electronics to countries where disassembly takes place at far lower cost, but where disassembly practices may threaten human health and the environment. In the absence of federal actions to address these concerns, an emerging patchwork of state requirements to encourage recycling and reuse may place a substantial burden on manufacturers, retailers, and recyclers, who incur additional costs and face an uncertain regulatory landscape as a result. In response to these challenges, EPA has spent about $2 million on several promising programs to encourage recycling and reuse of used electronics. Participation in one program--the Federal Electronics Challenge--has already led the Bonneville Power Administration to substantial cost savings through the procurement of environmentally friendly and energy efficient electronic products. To date, however, federal participation in this and other EPA electronics recycling programs has been minimal because--unlike other successful federal procurement programs (such as EPA's and the Department of Energy's Energy Star program)--participation is not required.

section_title: Letter
paragraphs: Rapid advances in technology have led to increasing sales of new  electronic devices, particularly televisions, computers, and computer  monitors. Approximately 62 percent of U.S. households had computers in  2003, compared with only 37 percent just 6 years earlier. With this increase  comes the dilemma of how to manage these products when they reach the  end of their useful lives. The National Safety Council forecast that in 2003  alone, about 70 million existing computers became obsolete, but it also  forecast that only 7 million were recycled.
Disposal of used electronics poses a number of potential environmental  problems. For example, concerns have been raised because toxic  substances such as lead, which have well-documented adverse health  effects, can potentially leach from these products, especially if disposed  improperly. Concerns have also been raised over used electronics that are  exported from the United States to countries with less stringent  environmental regulations because disposal in these countries can more  easily have adverse environmental and human health effects. In addition to  toxic substances, computers contain precious metals, such as gold, silver,  and platinum, which require substantial amounts of energy and land to  extract. These metals can often be extracted with less environmental  impact from used electronics than from the environment. The U.S.  Geological Survey, for instance, reports that 1 metric ton of computer scrap  contains more gold than 17 tons of ore and much lower levels of harmful  elements common to ores, such as arsenic, mercury, and sulfur.
Under the Resource Conservation and Recovery Act (RCRA), the  Environmental Protection Agency’s (EPA) Office of Solid Waste provides  regulatory oversight of the disposal of certain hazardous used electronic  products. The office tightly regulates hazardous waste from generation to  disposal; but also under RCRA, for other solid wastes, it promotes waste  reduction, recycling, and responsible disposal through national voluntary  and educational programs. Individual states must meet minimum national  standards for the management of municipal solid waste in landfills, but  they operate their own waste management programs, develop their own  recycling and reuse programs, and are free to implement more stringent  waste management policies.
Given the growing number of computers and other electronic products  becoming obsolete, you asked that we (1) summarize existing information  on the volumes of, and problems associated with, used electronics; (2)  examine the factors affecting the nation’s ability to recycle and reuse these  products; and (3) examine federal efforts to encourage recycling and reuse  of used electronics and determine what, if anything, can be done to  improve them.
To address these issues, we reviewed scientific studies and reports  conducted by government agencies, nonprofits, trade organizations, and  academics. We also interviewed federal, state, local, nonprofit, and  industry officials, as well as academic and research organization experts.  For studies that we cite in this report, we reviewed their methodology,  assumptions, limitations, and conclusions to ensure that we properly  represented the validity and reliability of their results and conclusions. To  examine the factors that affect the nation’s ability to recycle and reuse used  electronics, we examined current federal laws, regulations, and guidance  regarding solid and hazardous waste disposal as they relate to the disposal  of used electronics. We also reviewed pertinent state and local laws,  regulations, and guidance. In particular, we reviewed the electronic waste  legislation passed in California, Maine, Maryland, Massachusetts, and  Minnesota. We visited states and localities that have implemented  programs or passed legislation to responsibly manage used electronics,  including California, Maine, Massachusetts, Oregon, and Washington.  Further, we examined EPA-sponsored federal, state, and local pilot  programs that attempt to encourage recycling of electronic products. In  addition, to obtain the views of informed stakeholders regarding the  factors that affect the nation’s ability to recycle and reuse used electronics,  we conducted a survey of participants in the National Electronics Product  Stewardship Initiative (NEPSI) and other key stakeholders. We received 42  responses from our survey population of 49. For additional information on  our scope and methodology, see appendix I. Our work was conducted in  accordance with generally accepted government auditing standards, which  include an assessment of data reliability and internal controls.
subsections: section_title: Background
paragraphs: Few people are aware of recycling options for their old televisions and  personal computers. Because of the perceived value of used electronics,  some pass their used equipment to family members or friends before  eventually storing these units in their attics, basements, or garages.
Eventually, though, consumers need to dispose of these units in some  manner. By choosing to have these products recycled, consumers ensure  the recovery of resources like copper, iron, aluminum, and gold, which  would otherwise be procured through less environmentally friendly  practices such as mining. Likewise, consumers who choose to recycle also  reduce the amount of waste entering the nation’s landfills and incinerators.  Since used electronics typically contain toxic substances like lead,  mercury, and cadmium, recycling or refurbishing will prevent or delay such  toxic substances from entering landfills.
The Congress affirmed its commitment to reducing waste and encouraging  recycling, first through enactment of the Resource Conservation and  Recovery Act (RCRA) of 1976, and then again with passage of the Pollution  Prevention Act of 1990. Both RCRA and the Pollution Prevention Act  address alternatives to waste disposal. RCRA promotes the use of resource  recovery, either through facilities that convert waste to energy or through  recycling. To promote recycling, RCRA required EPA to develop guidelines  for identifying products that are or can be produced with recovered  materials. RCRA also required federal agencies to procure items that are, to  the maximum extent practicable, produced with recovered materials.
The Pollution Prevention Act provided that pollution that cannot be  prevented should be recycled or treated in a safe manner, and disposal or  other releases should be used only as a last resort. The act specified that  pollution prevention can include such practices as modifying equipment,  technology, and processes; redesigning products; and substituting less- toxic raw materials. Executive Order 13101, issued September 14, 1998,  also affirmed the federal government’s commitment to encourage recycling  by directing federal agencies to consider procuring products that, among  other things, use recovered materials, can be reused, facilitate recycling,  and include fewer toxic substances. The Federal Environmental Executive,  who is appointed by and reports to the President, is responsible for  recommending initiatives for government-wide procurement preference  programs for environmentally preferable products.
EPA’s Office of Solid Waste regulates hazardous waste and nonhazardous  waste, including discarded used electronics, under RCRA. RCRA  established explicit hazardous waste management requirements overseen  by the Office of Solid Waste, but for nonhazardous waste management, also  under RCRA, the Office’s policies rely heavily on national voluntary and  education programs for waste reduction that emphasize materials recycling  and reuse, toxic chemical reduction, and resource conservation. Several of  these voluntary programs are tailored specifically for environmentally  preferable management of used electronics. The Office of Solid Waste also  collaborates with EPA’s Office of Pollution Prevention and Toxics to  conserve valuable resources and reduce wastes—particularly toxic  wastes—before they are generated. These efforts are administered under  the Resource Conservation Challenge, which is an institutional strategy  combining the strengths of the two offices to ultimately minimize waste  and toxic substances and conserve energy and resources. According to  EPA, the overarching goal of the Resource Conservation Challenge is to  move the nation from a waste-oriented to a life-cycle management way of  thinking about resources.
section_title: Growing Volume of Used Electronics May Pose Environmental and Health Problems If Not Managed Properly
paragraphs: The information we reviewed suggests strongly that the volume of used  electronics is large and growing. For example, in a 1999 study, the National  Safety Council forecast that almost 100 million computers and monitors (70  million of which would be computers) would become obsolete in 2003—a  three-fold increase over the 33 million obsolete computers and monitors in  1997. Additionally, a 2003 International Association of Electronics  Recyclers report estimated that 20 million televisions become obsolete  each year—a number that is expected to increase as cathode ray tube  (CRT) technology is replaced by new technologies such as plasma  screens.
Thus far, it appears that relatively few used electronics have found their  way into either landfills or recycling centers. Available EPA data indicate  that less than 4 million monitors and 8 million televisions are disposed of  annually in U.S. landfills—only a fraction of the amount estimated to  become obsolete annually, according to EPA. Additionally, the 1999  National Safety Council report forecast that only 19 million computers,  monitors, and televisions would be recycled in 2005. Hence, the gap  between the enormous quantity of used electronics that are obsolete (or  becoming obsolete), and the quantity either in landfills or sent to recycling  centers, suggests that most are still in storage—such as attics, basements,  and garages, and that their ultimate fate is still uncertain—or have been  exported for recycling and reuse overseas.
Conventional disposal of used electronics in landfills raises two primary  concerns, according to research we reviewed: the loss of natural resources  and the potential release of toxic substances in the environment. By  disposing of these products in landfills or incinerators, valuable resources  are lost for future use. For example, computers typically contain precious  metals, such as gold, silver, palladium, and platinum, as well as other useful  metals like aluminum and copper. The U.S. Geological Survey reports that  one metric ton of computer circuit boards contains between 40 and 800  times the concentration of gold contained in gold ore and 30 to 40 times the  concentration of copper, while containing much lower levels of harmful  elements common to ores, such as arsenic, mercury, and sulfur. The  research we reviewed also suggests that the energy saved by recycling and  reusing used electronics is significant. The author of one report by the  United Nations University states that perhaps as much as 80 percent of the  energy used in the life cycle of a computer, which includes manufacturing,  can be saved through refurbishment and reuse instead of producing a new  unit from raw materials.
Regarding the issue of toxicity, the research we reviewed is unclear on the  extent to which toxic substances may leach from used electronics in  landfills. According to a standard regulatory test RCRA requires to  determine whether a solid waste is subject to federal hazardous waste  regulations, lead (a substance with known adverse health affects) leaches  from some used electronics under laboratory conditions. Some tests  conducted at the University of Florida indicate that lead leachate from  color computer monitors and televisions with CRTs exceeds the regulatory  limit and, as a result could, according to EPA, be considered hazardous  waste under RCRA. On the other hand, the author of this study told us that  these findings are not necessarily predictive of what could occur in a  modern landfill. A report by the Solid Waste Association of North America  also suggests that while the amount of lead from used electronics appears  to be increasing in municipal solid waste landfills, these landfills provide  safe management of used electronics without exceeding toxicity limits that  have been established to protect human health and the environment.
Nonetheless, regardless of uncertainty surrounding the environmental  risks associated with toxic substances commonly found in used  electronics, EPA has identified lead, mercury, and cadmium (which are  typically found in computers or monitors), as priority toxic chemicals for  reduction under the agency’s Resource Conservation Challenge. According  to EPA, these toxic substances do not break down when released into the  environment and can be dangerous, even in small quantities.
section_title: Cost and Regulatory Factors Deter Recycling and Reuse of Used Electronics
paragraphs: The costs associated with recycling and reuse, along with limited  regulatory requirements or incentives, discourage environmentally  preferable management of used electronics. Generally, consumers have to  pay fees and take their used electronics to locations that are often  inconvenient to have them recycled or refurbished for reuse. Recyclers and  refurbishers charge fees to cover the costs of their operations. In most  states, consumers have an easier and cheaper alternative—they can take  them to the local landfill. This easy and inexpensive alternative helps, in  part, explain why so little recycling of used electronics has thus far taken  place in the United States. Moreover, this economic reality, together with  federal regulations that do little to preclude disposal of used electronics  along with other wastes, have led a growing number of states to enact their  own laws to encourage environmentally preferable management of these  products.
subsections: section_title: Cost and Consumer Inconvenience Discourage Recycling and Reuse of Used Electronics
paragraphs: Consumers who seek to recycle or donate their used electronics for reuse  generally pay a fee and face inconvenient drop-off locations. Unlike their  efforts for other solid waste management and recycling programs, most  local governments do not provide curbside collection for recycling of used  electronics because it is too expensive. Instead, some localities offer used  electronics collection services, for a fee, at local waste transfer stations.  These localities send consumers’ used electronics to recyclers for  processing. For example, transfer stations in Snohomish County,  Washington, charge consumers between $10 and $27 per unit for collecting  and transporting used electronics to recyclers and, ultimately, paying the  recycler to responsibly handle the products.
Moreover, such transfer stations are generally not conveniently located,  and rural residents, such as those in parts of Snohomish County, may need  to drive more than an hour to get to the nearest drop-off station. Our survey  respondents recognize this challenge for the recycling infrastructure—over  70 percent believe that existing collection options for recycling used  electronics are inconvenient for households. However, in some localities,  consumers can also take their used electronics directly to a recycler, where  they are typically charged a fee. In the Portland, Oregon area, for instance,  one recycler charges consumers 50 cents per pound to recycle computers,  monitors, and televisions, which means it costs consumers about $28 to  recycle an average-sized desktop computer system.
Recyclers charge these fees to cover the costs they incur when  disassembling used electronics, processing the components, and refining  the commodities for resale. As noted in a 2003 report by the International  Association of Electronics Recyclers, most recyclers and refurbishers in  the United States cannot recoup their expenses from the resale of recycled  commodities or refurbished units. The report, which compiled data from  more than 60 recyclers in North America, stated that the costs associated  with recycling are greater than the revenue received from reselling  recycled commodities and that fees are needed to cover the difference.  Furthermore, the report states that the value of commodities recovered  from computer equipment, such as shredded plastic, copper, and  aluminum, is only between $1.50 and $2.00 per unit. This point is further  underscored by our interviews with eight electronics recyclers, who were  unanimous in emphasizing that they could not cover costs without charging  fees.
The costs associated with recycling make it unprofitable (without charging  fees) for several reasons. First, recycling used electronics is labor  intensive—the equipment must be separated into its component parts,  including the plastic housing, copper wires, metals (e.g., gold, silver, and  aluminum), and circuit boards, as well as parts that can be easily reused or  resold, like hard drives and CD-ROM drives. Officials with Noranda  Recycling Inc., which recycles used electronics for Hewlett-Packard, told  us that over 50 percent of their total costs for recycling are labor costs  involved in disassembly, even though they operate some of the most  technologically advanced equipment available. Labor costs are high, in  part, because electronic products are not always designed to facilitate  recycling at end of life. For instance, a Hewlett-Packard official told us 30  different screws must be removed to take out one lithium battery when  disassembling a Hewlett-Packard computer for recycling. According to this  official, if Hewlett-Packard spent $1 in added design costs to reduce the  number of different screws in each computer, it would save Noranda  approximately $4 in its disassembly costs. A substantial majority of  respondents to our survey agreed that the complexities of taking apart used  electronics is a major hindrance that impedes the recycling of these  products—over 60 percent said that recycling is discouraged because of  the difficulty of disassembly.
Second, to obtain sellable commodities, the resulting metal and plastic  “scrap” must be further processed to obtain shredded plastic, aluminum,  copper, gold, and other recyclable materials. Processing in this fashion  typically involves multimillion-dollar machinery. According to officials with  one international electronics recycling company, processing costs are high,  in part, because this sophisticated and expensive machinery is being used  to process the relatively limited supply of used electronics being recycled  in the United States. Company officials noted that, by contrast, in some  European countries where manufacturers are required to take financial  responsibility for recycling their products, the increased supply of  recyclable electronics has decreased the company’s per-unit processing  costs and increased the net revenue associated with recycling used  electronics.
Finally, recyclers incur additional expenses when handling and disposing of  toxic components (such as batteries) and toxic substances (such as lead),  which are commonly found in used electronics. These expenses include  removing the toxic components and substances from the product, as well  as handling and processing them as hazardous material. Once separated  from the product, these wastes may be regulated as hazardous wastes and,  thus, subject to more stringent RCRA requirements governing their  transportation, storage, and disposal. CRTs from computer monitors and  televisions are particularly expensive to dispose of because they contain  large volumes of leaded glass, which must be handled and disposed of as a  hazardous waste. Some recyclers, for example, send their CRT glass to a  lead smelter in Missouri that charges 6.5 cents per pound. A study on the  economics of recycling personal computers found that the cost associated  with disposing of CRT monitors substantially reduces a recycler’s net  revenue.
Refurbishers charge similar fees to cover the costs involved in  guaranteeing data security by “wiping” hard drives, upgrading systems,  installing software, and testing equipment. A program manager for a  nonprofit technology assistance provider told us that it generally costs  about $100 to refurbish a Pentium III computer system, plus an additional  licensing fee of about $80 for an operating system.
To help minimize the cost and inconvenience of recycling used electronics,  Office Depot and Hewlett-Packard partnered to provide free take-back of  used electronics at Office Depot retail stores in 2004. Office Depot  collected used electronics at their retail stores, and then sent them to  Hewlett-Packard facilities for recycling. Over a 3-month period, nearly  215,000 computers, monitors, and televisions were collected and recycled.  EPA officials told us that the pilot program showed the extent to which  recycling can be encouraged by making it inexpensive and convenient to  the consumer.
section_title: Federal Regulatory Framework Governing Used Electronics Provides Little Incentive for Recycling or Reuse
paragraphs: The lack of economic incentives promoting recycling and reuse of  electronics is compounded by the absence of federal provisions that either  encourage recycling, or preclude their disposal in landfills. Specifically,  current federal laws and regulations (1) allow hazardous used electronics  in municipal landfills, (2) do not provide for a financing system to support  recycling, and (3) do not preclude electronic products generated in the  United States from being exported and subsequently threatening human  health and the environment overseas.
subsections: section_title: Hazardous Used Electronics Are Allowed in Municipal Landfills
paragraphs: Regulation at the federal level of used electronics identified as hazardous  waste and disposed in landfills falls under RCRA Subtitle C, which was  established to ensure that hazardous waste is managed in a manner that is  protective of human health and the environment. Many computer monitors  and televisions are considered hazardous waste under RCRA, and some  materials from circuit boards might be hazardous waste as well. Federal  regulations bar entities that generate more than 220 pounds of hazardous  waste per month from sending hazardous waste to municipal solid waste  landfills. However, households and entities that generate more than 220  pounds of hazardous waste per month are exempt from many RCRA  regulations, thus allowing them to deposit their used electronics in  municipal solid waste landfills—even though CRTs in computer monitors  and televisions, and potentially circuit boards in computers, exhibit  characteristics of hazardous waste. EPA’s Office of Solid Waste regulates  hazardous waste under RCRA, but its regulations do not require  households and other entities that generate small quantities of hazardous  waste to recycle or reuse used electronics, nor do its regulations require  the office to establish a mandatory national approach, such as a disposal  ban.
In response to the RCRA regulatory exemption for household hazardous  waste and the growing volume of obsolete electronics within their  boundaries, four states—California, Maine, Massachusetts, and  Minnesota—recently banned some used electronics from landfills. Such  bans appear to have contributed to a higher degree of recycling than in  states where disposal in solid waste landfills is allowed. In San Ramon,  California, for instance, a 1-day collection event for television monitors  yielded 24,000 units. In contrast, in Richmond, Virginia, a metropolitan area  4 times the size of San Ramon but without a landfill ban, a similar  collection event (organized by the same electronics recycler as in San  Ramon) only yielded about 6,000 monitors. This difference in yield is  consistent with assessments of California and Massachusetts officials, who  all said that their states have seen substantial increases in used electronics  recycling. One international electronics recycler, for instance, set up  recycling facilities in the San Francisco area in 2003 because of the large  volume of used electronics that was no longer being disposed of in  landfills. In Massachusetts, an official with the Department of  Environmental Protection said that six businesses dedicated to electronics  recycling were created following the enactment of a landfill ban. Finally,  over 95 percent (all but one) of survey respondents said that a national  disposal ban should be enacted to overcome the factors that discourage  recycling and reuse of used electronics.
Recyclers we interviewed in California and Massachusetts said that a  positive side effect of a ban is increased public awareness. In  Massachusetts, for example, the Department of Environmental Protection  conducted a survey in which over 60 percent of the respondents were  aware that electronic products were banned from landfills. Of note, only 25  percent of survey respondents believe that the public is aware of recycling  options for used electronics on a national scale, and over 85 percent  believe that the overall lack of awareness of recycling options discourages  recycling of these products.
section_title: Experts Believe a National Financing System Is Needed to Support Recycling
paragraphs: Given the inherent economic disincentives to recycling used electronics in  the United States, we also found widespread agreement among our survey  respondents and others we contacted that establishing some type of  financing system is critical to making recycling and reuse sufficiently  inexpensive and convenient for consumers to attract their participation. Of  particular note, over 90 percent of survey respondents support one of the  two major proposals being discussed—an advanced recovery fee (ARF) or  extended producer responsibility (EPR)—or, a hybrid of the two. Yet  despite broad agreement in principle, participants in the EPA-sponsored  NEPSI process, particularly those in the computer and television  industries, did not reach agreement on a uniform, nationwide financing  system after several years of meetings.
In the absence of a national system, several states have enacted their own  financing systems through legislation to help ensure environmentally  preferable management of used electronics. For example, in 2005,  California implemented an ARF on all new video display devices, such as  televisions and computer monitors, sold within the state. The fee is charged  to consumers at the time and location of purchase and can range between  $6 and $10. According to an official with the California Department of  Toxic Substance Control, the revenues generated from the fee are intended  to deal with a key concern—used electronics in storage, or “legacy waste.”  The officials explained that while California’s recycling industry had  sufficient capacity to recycle large volumes of used electronics, consumers  and businesses had little incentive to take products out of their basements  or warehouses to have them recycled. The state uses revenues from the  fees to reimburse electronics recyclers at the rate of 48 cents per pound of  used electronics recycled. The recyclers, in turn, pass on to collectors 20  cents per pound of used electronics, thereby providing an incentive for  entities to make collection free and convenient for households.
The state is still in the preliminary stages of program implementation, and  state officials acknowledge that they face a number of challenges. Some of  these challenges underscore the difficulty of dealing with the electronic  waste problem on a state-by-state basis. The officials noted, for instance,  that the ARF applies only to electronics purchased in California, and that  the fees are intended only for used electronics originating in the state.  Implementing the program within the state’s boundaries, however, may  prove difficult because the payout may attract units originating in other  states. Preventing this problem, they say, requires substantial  documentation for each unit, and may require a substantial enforcement  effort.
While California’s ARF focuses on consumers of electronics, Maine’s  approach focuses on producers through an EPR-like system. In 2004, the  state passed legislation requiring computer and television manufacturers  who sell products in Maine to pay for the take back and recycling of their  products at end of life. Under this plan, consumers are to take their used  electronics to a consolidation point, such as a transfer station, where they  are sorted by original manufacturer. Each manufacturer is physically or  financially responsible for transporting and recycling its products, along  with a share of the products whose original manufacturer no longer exists.  According to one official with Maine’s State Planning Office, a key  challenge of its EPR system is the lack of a financial incentive for  consumers to take their used electronics out of storage. Additionally,  consumers will still likely have to pay a fee at consolidation points.
Several other states have implemented or are considering implementing  financing systems for used electronics. Earlier this year, Maryland passed  legislation requiring all computer manufacturers that sell computers in the  state to pay $5,000 into a fund to help implement local recycling  programs. For manufacturers that implement a computer take-back  program in the prior year, the fee is only $500. Other states, such as  Arkansas, Colorado, Florida, and Massachusetts, have allocated grants to  help pay for the recycling of used electronics, and New York, Rhode Island,  and Vermont are considering enacting EPR-like programs.
The differing financing systems of California and Maine, as well as those  being considered by other states, suggest that in the absence of a national  approach, a patchwork of potentially conflicting state requirements is  developing. Further, this patchwork may be placing a substantial burden on  manufacturers, retailers, and recyclers. A manufacturer in one state, for  example, may have an advance recovery fee placed on its products;  whereas in another state, the same manufacturer may have to take back its  products and pay for recycling. Hewlett-Packard serves as one example: in  Maine, officials estimate they will spend almost $90,000 per year paying for  the take-back and recycling of their products under the state’s EPR system.  In California, Hewlett-Packard incurred over $3 million in start-up costs  and will spend an additional $250,000 per year because the state’s ARF  system requires them to track their products that have been distributed to  various retailers, who then add a fee. A Hewlett-Packard official said  implementing one financing system on a national scale would be more  preferable than implementing numerous financing systems on a state-by- state basis that have different requirements and, thus, require additional  costs. A Hewlett-Packard official also told us that these conflicting systems  involve start-up costs, which could cost over $2 million dollars per state if a  new state system differs from those currently in place.
Similarly, a Seattle area recycler told us that because of the differing state  requirements and the lack of a national approach, recyclers find it difficult  to invest in developing a recycling infrastructure. Specifically, he noted that  without certainty about the regulatory landscape, larger recyclers will not  enter the industry and invest in technologies that can reduce costs, such as  has been done in some European countries where recycling used  electronics is more profitable. He added that until this problem is  addressed, recycling will continue to be conducted primarily by small,  niche companies.
Not surprisingly, three major computer manufacturers we contacted said  that while they have individual preferences for one financing mechanism or  another (usually an ARF or EPR system), their main preference is to  operate within a uniform national system that mandates a financing system  preempting varying state requirements. Recyclers and state and local  government officials generally agreed, noting that having a system in place  that covers costs and is national in scope is more important to them than  their preferences for a particular system. Our survey results substantiate  these views, with over 95 percent of survey respondents indicating that  national legislation should be enacted, and over 90 percent of that group  stating that one of the major proposals being discussed (or a hybrid of the  two) should be included, such as an ARF or EPR system.
Because of these challenges, EPA sponsored a major effort in this regard by  providing the initial funding for the multistakeholder National Electronic  Product Stewardship Initiative (NEPSI) process. NEPSI stakeholders met  between 2001 and 2004, in part, to develop a financing system to facilitate  recycling and reuse of used electronics. The process ultimately dissolved in  2005, however, in large part because EPA withdrew its participation and  funding.
Notwithstanding EPA’s withdrawal of its sponsorship of the NEPSI process,  the agency still generally advocates financing systems for resource  conservation that involve all stakeholders—consumers, manufacturers,  and retailers—who benefit from resource use. Under the Resource  Conservation Challenge, EPA seeks to have products designed with reuse  and recycling in mind, the costs of reuse and recycling included in the price  of the product, and improved mechanisms for collecting products for  recovery. Further, in the Resource Conservation Challenge’s strategic plan,  EPA recognizes that for some products, such as electronics, recycling is not  economically sustainable. For these products, EPA supports the  consideration of financing approaches that have been implemented in  Japan and some European nations, in which the cost of recovering  products is incorporated into the cost of buying the product; and in which  incentives are provided for environmentally preferable design.
For example, Japan enacted the Home Appliances Recycling Law in 1998,  which requires that retailers collect—and manufacturers and importers  recycle—four types of household appliances, in which televisions are  included. The law’s inclusion of televisions has encouraged the  development of a television and CRT recycling industry in Japan, where  substantial research has gone into the development of television  dismantling and recycling technologies. Since enactment of this law, Sony,  for example, has cooperated with other companies to establish 190 take- back sites and 15 recycling plants in Japan.
In Europe, the European Union (EU) enacted the Waste Electrical and  Electronic Equipment Directive, which established comprehensive take- back and recycling requirements for retailers, manufacturers, and  importers of electrical and electronic products, including televisions,  computers, and monitors. The directive requires that producers and  importers finance the separate collection of waste electronics either on  their own or through collective systems financed by themselves and other  members of the industry. Ninety-three percent of our survey respondents  believe that this directive will facilitate collection and recycling of used  electronics in the EU. The EU also addressed the issue of hazardous  substances in discarded used electronics by requiring that six hazardous  substances, including substances such as lead, mercury, and cadmium,  commonly found in used electronics, be replaced by other substances by  July 1, 2006.
section_title: Oversight of Exported Used Electronics Is Limited
paragraphs: The lack of oversight over some exported used electronics also appears to  be discouraging environmentally preferable management of such products  and inhibiting the development of a domestic recycling infrastructure.  Companies export used electronics because the largest markets for reused  computers and televisions are overseas. One EPA official told us that  consumers in developing countries are more willing to purchase older  computer and television models than consumers in developed countries.
Likewise, the largest markets are also overseas for commodities commonly  found in used electronics, such as copper, aluminum, and shredded plastic.  In many developing countries, commodities such as these can be obtained  more cheaply by disassembling whole units, such as CRT televisions and  monitors, under less stringent environmental requirements. As a result of  this demand, many businesses, schools, government agencies, and  recyclers in the United States receive e-mails from foreign brokers willing  to pay them for their obsolete computers and televisions, even if the  products cannot be reused. For example, we observed that at one e- commerce Web site, a broker sought to purchase 50,000 used monitors per  month and did not require the monitors to be tested to determine whether  they could be reused. Another broker in Pakistan sought to purchase 1  million nonworking monitors annually at a price of $2 to $3 per monitor. In  another instance, another broker specifically requested nonworking  monitors and wanted to fill at least 10 containers, which amounts to  anywhere from 6,000 to 11,000 units overall (depending on their size).
Five electronics recyclers we interviewed, including two who export  nonworking whole computers and televisions, agreed that brokers such as  these are probably not handling nonworking units responsibly once the  units reach their final overseas destination. According to these recyclers, it  costs money to disassemble and recycle used electronics in such a way that  protects human health and the environment from exposure to toxic  substances. In many importing countries, they note, labor costs are far  lower, in part because the regulatory standards needed to protect workers’  health and the environment are far more lenient. One EPA official agreed,  noting that it is safer and more protective of the environment if used  electronics are disassembled (and their materials subsequently separated)  in the United States under sound environmental standards before exporting  recycled commodities. Even so, two Seattle area recyclers told us they  regularly receive e-mails requesting these types of products, and they are  aware of many other organizations, such as school districts, that sell their  obsolete computers and televisions to foreign brokers because it costs too  much to have them disassembled in the United States in a manner  protective of human health and the environment.
As the export of nonworking whole units continues, a growing body of  evidence suggests that it is cause for concern in developing countries.  Instances have been documented recently to confirm the assertions of  some recyclers and environmental groups that human health and  environmental threats have resulted from the less-regulated disassembly  and disposal of many of these U.S.-generated used electronics overseas— products that were allegedly destined for reuse (See fig. 1.). A 2002  documentary by the Basel Action Network and Silicon Valley Toxics  Coalition videotaped egregious disassembly practices in China that  involved open burning of wire to recover copper, open acid baths for  separating precious metals, and human exposure to lead and other  hazardous materials. According to a report by these groups, most of the  used electronics being handled in this manner were of North American  origin.
Additionally, it appears that nonworking whole electronic products are  more frequently handled in an irresponsible manner. Specifically, seven  recyclers we interviewed, along with a majority of survey respondents, told  us that nonworking whole products (CRT televisions and computer  monitors in particular) are much more likely to pose environmental and  human health risks if they are not disassembled in the United States prior  to being exported. Accordingly, one survey respondent told us that the  export of such products should be regulated more closely than the export  of specific commodities, such as copper, because they still contain toxic  substances likely to be handled improperly in countries without regulations  to protect human health and the environment. Our survey respondents  generally supported these views: while more than 75 percent believe that  exports of working units should be allowed to help developing countries  advance technologically, only about 20 percent said that export of  nonworking whole products should be allowed.
Despite the additional risks posed by the export of nonworking whole CRT  televisions and monitors, few legal safeguards are in place to ensure that  these units are managed responsibly or indeed destined for reuse overseas,  and one proposed rule by EPA aims to reduce the few safeguards that  currently exist. Under U.S. law, hazardous electronic products that will be  disassembled in another country are subject to a number of export  regulations. Such products may only be exported with the consent of the  government of the receiving country, and the Department of State must  forward to that government a description of the federal regulations that  would apply to the waste if it remained in the United States. The receiving  government may specify the terms of its consent and, under U.S. law, the  exporter must comply with these terms. In addition, the exporter must  know the final destination of the wastes and must obtain verification that it  reached the destination. The exporter must also make yearly reports to  EPA detailing the type, quantity, frequency, and ultimate destination of  exported hazardous waste.
In practice, however, U.S. legal restrictions on the export of hazardous  waste have had little apparent effect on exporters of used electronics, even  if the units will be disassembled when they reach their final destination  overseas. One reason for this is that EPA has long interpreted the definition  of “waste” (and, thus, “hazardous waste”) to exclude products that will be  reused “as is” or after minor repairs. Therefore, although U.S. export  regulations on hazardous waste apply to products that will not be reused at  their destination, the regulations do not apply to products that are bound  for reuse. Moreover, nothing in RCRA or its regulations requires exporters  to demonstrate that their products will be reused. Exporters can simply  assert that their exported used electronics are bound for reuse, even if the  exports instead are completely disassembled when they reach their  destination.
Of additional concern is EPA’s June 2002 proposed rule, which would,  under most circumstances, exclude hazardous CRT televisions and  computer monitors from RCRA’s existing notification and consent  regulations for hazardous waste exports. The purpose of the rule, as  outlined in the Federal Register, is to encourage greater reuse and  recycling of these products in the United States by streamlining the  management requirements for used CRTs, while maintaining necessary  environmental protection. Many stakeholders support this rule, including  recyclers and manufacturers, because it helps reduce the costs of recycling  CRT televisions and computer monitors. However, under the proposed  rule, EPA also proposed that CRT televisions and computer monitors,  including broken units, be excluded from RCRA’s export notification and  consent laws and regulations. Thus, exporters would be excluded from  having to obtain the consent of the receiving country before exporting the  waste and from having to make yearly reports to EPA detailing the quantity  and destination of used CRT exports. This provision is in stark contrast to  recommendations developed by EPA’s Common Sense Initiative between  1994 and 1998, which recommended that entities exporting CRTs be  subject to the same export regulations as other generators of hazardous  waste.
According to one EPA official closely involved in this proposed rulemaking  effort, EPA received numerous comments from individuals and  organizations concerned that the rule would increase the export of  eventual hazardous wastes to countries ill-equipped to manage them in a  manner protective of human health and the environment. As a result, this  and another EPA official told us that EPA is making changes to the final  rule that address these stakeholders’ concerns while, at the same time,  helping the domestic recycling infrastructure. Currently, the rule—along  with language addressing oversight of hazardous exports—is being  reviewed by the Office of Management and Budget.
In addition to the added health and environmental risks posed by  nonworking whole electronic products, several recyclers who disassemble  domestically told us they cannot compete with exporters of nonworking  whole products because these exporters do not bear the costs of adherence  to U.S. environmental regulations. In support of this view, 75 percent of  survey respondents said that exports such as these reduce the viability of  the U.S. recycling infrastructure. Additionally, concerned about potential  environmental and human health risks resulting from U.S.-generated used  electronics, over 70 percent of survey respondents said the U.S.  government should place some restrictions on used electronics exports.
section_title: Federal Efforts to Increase Recycling and Reuse of Used Electronics Can Be Strengthened
paragraphs: EPA has implemented several promising voluntary programs to encourage  recycling and reuse of used electronics. Without EPA authority to require  recycling of these products or to require other federal agencies to  participate, however, these programs’ successes have been and will  continue to be limited.
subsections: section_title: Voluntary EPA Programs Show Promise
paragraphs: In 2002, EPA organized its voluntary efforts for environmentally preferable  management of used electronics under a broadly scoped program called  the Resource Conservation Challenge. This program focuses EPA resource  conservation efforts on four critical areas, two of which are directly related  to used electronics: (1) promoting environmentally preferable management  of used electronics, such as recycling, and (2) reducing toxic substances  potentially entering the waste stream. This program also challenges the  federal government to lead by example. Since 2000, EPA has spent about $2  million on voluntary pilot programs, projects, and grants related to  recycling used electronics. Three particularly promising projects under this  program include (1) the Federal Electronics Challenge (FEC); (2) the  Electronic Product Environmental Assessment Tool (EPEAT), both of  which leverage U.S. government purchasing power to promote  environmentally preferable management of electronic products from  procurement through end of life; and (3) the “Plug-In To eCycling”  campaign, which aims to minimize the economic factors that deter  recycling.
The FEC program challenges federal agencies and facilities to procure  environmentally preferable electronic products, extend the lifespan of  these products, and expand markets for recycling and recovered materials  by recycling them at end of life. The FEC provides guidance on  environmentally preferable attributes of electronic products, information  on operating and maintaining them in an energy-efficient manner, and on  options for recycling or reusing them at end of life. Currently, 12 federal  agencies and 61 individual federal facilities participate in the FEC to some  extent. Of note, the Bonneville Power Administration (BPA) recently  documented cost savings associated with its FEC participation. BPA noted,  for example, that through the program, it extended the lifespan of its  personal computers from 3 to 4 years. With over 500 computers procured  each year at an annual cost of more than $500,000, a BPA official said that  extending computer life spans could generate substantial savings.  Additionally, BPA decided to procure new flat-screen monitors instead of  CRT monitors, reducing both hazardous waste tonnage and end of life  recycling costs. According to BPA, it expects to save at least $153 per  monitor over the life of each monitor.
Relatedly, the EPEAT program promotes environmentally preferable  management of electronics by helping large purchasers, such as  government agencies, compare and select laptop computers, desktop  computers, and monitors with environmentally preferable attributes. For  example, using EPEAT, purchasers can evaluate the design of an electronic  product for energy conservation, reduced toxicity, extended lifespan, and  end of life recycling, among other things. EPEAT’s three-tier system— bronze, silver, and gold—provides purchasers with the flexibility to select  equipment that meets the minimum performance criteria, or to give  preference to products with more environmental attributes. For  manufacturers, EPEAT provides flexibility to choose which optional  criteria they would like to meet to achieve higher levels of EPEAT  qualification. EPEAT was developed along the lines of EPA and DOE’s  Energy Star program, in which the federal government rewards  manufacturers that offer businesses and consumers energy-efficient  products that ultimately save money and protect the environment by  providing them with the Energy Star label for their products. In fact,  specific EPEAT procurement criteria are drawn heavily from Energy Star  standards. EPA expects EPEAT to be instituted in 2006.
Another promising program, the Plug-In To eCycling campaign, has led to  the collection and recycling of over 45 million pounds of used consumer  electronics in the United States, including computers, monitors, and  televisions, since 2003. The “Plug-In To eCycling” campaign is partnering  with over 20 industry affiliates and 27 state and local governments to  provide the public with information about recycling and to establish pilot  projects to test innovative approaches to collect and manage used  electronics. In the pilot projects funded through Plug-In To eCycling,  partnering organizations have reduced the cost and inconvenience of  recycling used electronics. For example, manufacturers have helped pay  the cost of recycling used electronics; retailers have helped provide  collection opportunities; recyclers have helped provide lower costs for  larger quantity, longer-term contracts that meet environmentally safe  management guidelines; and consumers have taken their used electronics  from storage to designated locations. In 2004, Plug-In To eCycling  sponsored four pilot projects, which all involved holding collections events  at retailers such as Best Buy, Good Guys, Office Depot, Staples, and Target.  These pilot collection events lasted from a few weeks to a few months and  collected over 11 million pounds of used electronics.
section_title: Lack of EPA Authority for Requiring Federal Agency Participation Limits Programs’ Successes
paragraphs: While the voluntary EPA programs outlined above have produced tangible  results, their ultimate potential is constrained by the lack of EPA authority  to require broader participation. Currently, for example, only 61 out of  thousands of federal facilities are participating in the FEC. Requiring  participation by private parties and state and local governments in these  programs may be neither realistic nor desirable. However, as discussed  below, there is ample precedent for actions that would engender greater  federal participation in these types of programs. Wider federal participation  would likely benefit both the environment and the development of the  electronics recycling industry—federal agencies were expected to spend  over $60 billion on televisions, computers, monitors, and other information  technology products and services in fiscal year 2005 alone.
Perhaps the best precedent for requiring broader federal participation in  electronics recycling is the Energy Star program, co-sponsored by EPA and  the Department of Energy. According to EPA, in 2004 alone, Energy Star  products helped save approximately $10 billion in energy costs and  reduced greenhouse gas emissions by an amount equivalent to that  produced by 20 million automobiles. Also, in 2005, public awareness of  Energy Star reached over 60 percent. Because of Energy Star’s high profile,  EPA officials told us that although manufacturers do not have to design  their products to meet Energy Star criteria, many manufacturers view  Energy Star as a de facto requirement for design of their products— suggesting that if their products do not have the Energy Star label then they  are at a competitive disadvantage in the marketplace.
According to an EPA official who has worked on the Energy Star program  since its inception, part of Energy Star’s success can be attributed to two  executive orders that required federal agencies to purchase products  equipped with Energy Star features. Specifically, Executive Order 12845,  issued in 1993, required federal agencies to procure computers and  monitors that meet Energy Star requirements for energy efficiency. This  EPA official told us that the early success of Energy Star was enhanced by  this executive order. Executive Order 13123, issued in 1999, directs federal  agencies to select Energy Star products when procuring any energy-using  product. For product groups where Energy Star labels are not yet available,  agencies are directed to select products that are in the upper 25 percent of  energy efficiency, as designated by the Federal Energy Management  Program.
In contrast, the potential success of the FEC and EPEAT programs is  presently limited because, unlike the Energy Star program, federal  agencies’ participation is not required. The potential benefits from broader  federal participation were illustrated by BPA’s experience, which, as noted  earlier, demonstrated significant cost and energy savings and greater  environmental protection. They were also underscored by the results of  our survey—almost 90 percent of respondents said that federal government  procurement criteria along the lines of FEC and EPEAT should be required,  and over 95 percent said that such procurement criteria would encourage  environmentally preferable product design, and greater recycling and  reuse.
section_title: Conclusions
paragraphs: Despite the significant environmental benefits of recycling and reusing  used electronics, these environmentally preferable practices will likely  remain underutilized unless concerted actions are taken. Two overarching  factors contribute to this problem. First, consumers have the cheaper and  more convenient option of simply throwing these products away in most  states. Without a fundamental change in the incentive structure affecting  their decisions, such as through the implementation of a consistent  nationwide financing system, consumers will continue to choose disposal  as the preferable option of dealing with used electronics in the  overwhelming number of states where disposal is allowed. Also in the  absence of federal action, states are taking measures to address their  unique recycling challenges. This state-by-state approach, however, has the  unintended consequence of increasing costs for manufacturers, retailers,  and consumers, while discouraging recyclers from investing in a domestic  recycling infrastructure. It has also led to an array of legislative proposals  that take very different approaches to address the problem.
Second, rather than paying for proper disassembly in the United States,  some organizations discarding used electronics (and some recyclers) sell  these units to overseas buyers with no guarantee that they will be properly  handled. The problem is particularly serious in the case of nonworking  whole products, such as CRT televisions and computer monitors, which are  often handled in a manner that causes adverse environmental and human  health effects in receiving countries. Current RCRA regulations require  EPA to oversee the export of many used CRT televisions and computer  monitors if such products will not be reused at their final destination. In  practice, however, there has been little oversight over the export of these  products because neither RCRA nor its regulations require exporters to  demonstrate that exported electronic products will actually be reused. In  addition to posing health and environmental risks in developing countries,  this practice undermines the domestic recycling industry by providing a  cheap alternative to domestic recycling, which is more protective of human  health and the environment. Importantly, EPA’s proposed CRT rule would  further exacerbate the problem if adopted as presently worded because it  would restrict EPA’s regulatory authority to oversee the exportation of  most used CRT televisions and computer monitors.
These factors have prevented much recycling from occurring to date and, if  not addressed, will continue to stymie recycling and reuse efforts. EPA has  implemented several promising voluntary programs to encourage recycling  and reuse of used electronics, but without the authority to require recycling  of these products or to require other federal agencies to participate, the  success of these programs is and will continue to be limited. In the past, the  federal government has taken steps to encourage environmentally  preferable choices by leveraging its substantial market power, but these  actions required the participation of all federal agencies. Using the success  of the Energy Star program as a precedent, the federal government has the  opportunity to lead by example by building on existing EPA programs to (1)  enhance the domestic recycling infrastructure for used electronics by  ensuring a steady and substantial supply of used electronics; (2) stimulate  markets for environmentally preferable electronic products by purchasing  energy efficient, easily recyclable products with high recycled content and  less toxic substances; and (3) save energy by extending the lifespan of used  electronics.
section_title: Recommendations
paragraphs: Given the numerous and varying legislative proposals for nationwide  financing systems, we recommend that the Administrator, EPA, direct the  Offices of Solid Waste and Pollution Prevention and Toxics to bring its  expertise to bear on the issue by drafting a legislative proposal including,  but not limited to, recommendations for a consistent, nationwide financing  system that addresses the barriers to recycling and reuse.
As EPA finalizes its proposed rule regarding CRTs, we also recommend that  the Administrator ensure that the final rule reflects the concerns of  numerous commenters that it will not constrict EPA’s regulatory authority  to oversee the exportation of CRT televisions and monitors (many of which  exhibit the traits of hazardous wastes currently regulated by EPA) to  countries that do not have the environmental protections in place to ensure  their safe disassembly.
In addition, to establish a national recycling infrastructure and encourage  environmentally preferable management of used electronics throughout  their life-cycle, we also recommend that the Administrator direct the Office  of Solid Waste to take necessary action (in collaboration with the Office of  the Federal Environmental Executive) to require federal agencies to  participate in the Federal Electronics Challenge and to procure electronic  products that meet or exceed the minimum performance criteria set by the  Electronic Product Environmental Assessment Tool.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Administrator of the  Environmental Protection Agency for review and comment. In its October  14, 2005 letter, EPA expressed agreement with most of the report’s findings,  noting further that agency reviewers found the report “to be very well  written, carefully researched, and clearly argued.” EPA disagreed, however,  with our recommendations that the agency play a more active role in  promoting electronic waste recycling and reuse by (1) developing a  legislative proposal that would address key barriers to recycling and reuse  and (2) taking additional steps to ensure broader implementation by  federal agencies of EPA’s initiatives to promote wider use of electronics  recycling and reuse across the federal government.
EPA commented that it does not believe it is appropriate for the agency to  develop a proposal for establishing a nationwide financing system that  addresses the barriers to recycling and reusing used electronics. EPA  explained that since there is no consensus among manufacturers regarding  the optimal financing solution to meet these ends, the agency is “not in the  best position to choose between competing financing solutions, given that  this decision is one that is fundamentally a business and economic issue,  rather than an environmental issue.” We acknowledge the lack of  consensus among manufacturers cited by EPA, but disagree that this lack  of consensus provides a compelling reason for EPA to abstain from acting  on this recommendation.
First, for the reasons cited in this report and those of other organizations,  electronic waste is becoming an increasingly important environmental  issue. As such, the fact that a key barrier involves disagreement over  competing financing solutions should not preclude EPA from helping to  resolve the problem. There are also ample precedents for EPA’s active  involvement in addressing complex financial issues affecting solutions to  key environmental problems. EPA played a central role, for example, in  developing the Clean Water State Revolving Fund and Drinking Water State  Revolving Fund programs. These programs have become instrumental in  helping communities address their water infrastructure needs efficiently  and at lower cost to the federal government.
Second, our survey results show that while there is disagreement on  precisely what financing mechanism should be used to resolve the  problem, there is an overwhelming consensus that (1) legislation will be  needed to deal with the problem and (2) a uniform nationwide financing  solution would be preferable to none at all. As we noted above, the  manufacturers we contacted said that while they have individual  preferences for one financing mechanism or another, their overriding goal  is to operate within a uniform national system that mandates a financing  system preempting varying state requirements. Our survey results  substantiated these views, with over 95 percent of survey respondents  indicating that some type of national legislation is needed to move  electronics recycling forward. Additionally, over 90 percent of these  respondents believe that a financing system should be included in national  legislation. In essence, inaction itself is the choice that has the least  support among stakeholders in dealing with electronics waste at the  national level.
Third, an active EPA role in proposing options to Congress for a nationwide  financing system is consistent with the goals EPA has set forth in its own  strategic plan for electronics recycling. In this plan, EPA commits to  removing barriers to recycling and identifying opportunities to reduce  wastes. The plan also says that sustainable funding systems must be  available for recycling, particularly for products in which recycling is not  economically viable. As noted earlier in our report, such is the case for  used electronics. Finally, EPA’s plan notes that within 5 years, the agency  aims for “it to be as easy for consumers to recycle or find a re-user for their  television or computer as it is for them to buy one.”
EPA’s letter also disagreed with our recommendation that EPA take steps  aimed at requiring federal agencies to participate in the Federal Electronics  Challenge and Electronic Product Environmental Assessment Tool  program. In particular, citing its specific technical comments provided to  us under separate cover, EPA disagreed with our view that participation in  the FEC is limited. Among other things, EPA’s technical comments echoed  often-cited data showing that the 12 federal agencies participating in the  program to date “represent over 80 percent of the Information Technology  purchasing in the government.” The figure, however, overstates federal  agency adherence to the goals of the FEC. Participation by these 12  agencies, for example, does not mean that 80 percent of all Information  Technology products are procured, operated, and recycled or reused at end  of life in an environmentally preferable fashion. Instead, participation  simply means these agencies have identified their current practices for  managing electronic products and set goals to improve them. However,  participating agencies and facilities are not required to meet these goals. As  a practical matter, 61 out of thousands of federal facilities participate in the  Federal Electronics Challenge, and only 5 are meeting electronic product  management criteria that the Federal Electronics Challenge steering  committee has asked them to attain.
We believe this track record falls short of the goals of EPA’s Resource  Conservation Challenge, which asks the federal government to “lead by  example” in promoting recycling, reducing the use of toxic chemicals, and  conserving energy and materials in its life-cycle management of electronic  products. Past experience with similar programs (such as the Energy Star  program), together with EPA’s experience to date with the FEC, suggests  that merely encouraging participation in these programs will not meet  these goals. Because the federal government will spend about $65 billion  on information technology in fiscal year 2006 while discarding  approximately 10,000 computers per week, we continue to believe that our  recommendation on this matter is both practical and appropriate.  Specifically, either through an executive order, changes to the Federal  Acquisition Regulations, or through some other means, federal  participation in the FEC and EPEAT programs should be required to help  ensure environmentally preferable management of used electronics by the  federal government.
EPA also provided technical clarifications on the text of our draft report,  which we have incorporated into the final report as appropriate.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution of this report until 30  days from the date of this letter. At that time, we will send copies of this  report to interested congressional committees; the Administrator of the  Environmental Protection Agency; and other interested parties. We will  make copies available to others upon request. In addition, the report will be  available at no charge on the GAO Web site at http://www.gao.gov.
If you or your staff have any questions about this report, please contact me  at (202) 512-3841 or stephensonj@gao.gov. Contact points for our Office of  Congressional Relations and Public Affairs may be found on the last page  of this report. Key contributors to this report are listed in appendix IV.
section_title: Scope and Methodology
paragraphs: To summarize existing research on the quantity of end-of-life electronics  and the problems they may pose, we reviewed scientific studies and  reports conducted by government agencies, nonprofits, trade  organizations, and academics. We also consulted with federal, state, local,  nonprofit, and industry officials, as well as academic and research  organization experts. For studies estimating the volume of used  electronics, we focused on those that generated original data analyses  rather than summaries of existing literature. In addition, we limited our  review to studies that provided nationwide estimates.  For studies that we  cited in this report, we reviewed their methodology, assumptions,  limitations, and conclusions to ensure that we properly represented the  validity and reliability of their results and conclusions. We also interviewed  experts and study authors from government, industry, and academia to  obtain their views on the quantity of used electronics and problems they  may pose.
To examine the factors that affect the nation’s ability to recycle and reuse  electronics, we examined current federal laws, regulations, and guidance  regarding solid and hazardous waste disposal as they relate to the disposal  of used electronics. We also reviewed pertinent state and local laws,  regulations, and guidance. In particular, we reviewed the electronic waste  legislation passed in Massachusetts, California, Maine, Minnesota, and  Maryland. We visited states and localities that have implemented programs  or passed legislation to responsibly manage used electronics, including  California, Maine, Massachusetts, Oregon, and Washington. In addition we  interviewed federal, state, local, government officials. We also interviewed  officials from original equipment manufacturers, recyclers, trade  organizations, nonprofit organizations, and environmental advocacy  groups, as well as academic and research organization experts. Further, we  examined EPA-sponsored federal, state, and local pilot programs that  attempt to encourage recycling of electronic products. Finally, we also  examined regulations that manage used electronics in Japan and the  European Union.
In addition, to obtain the views of informed stakeholders regarding the  factors that affect the nation’s ability to recycle and reuse used electronics,  we conducted a survey of a nonprobability sample of participants in the  National Electronics Product Stewardship Initiative (NEPSI) and other key  stakeholders.  The NEPSI stakeholders met in a series of meetings  between 2001 and 2004 in an attempt to develop solutions to the issue of  managing used electronics. NEPSI was comprised of 48 stakeholders, with  15 representing federal, state, and local governments; 16 representing  equipment manufacturers; and 17 other stakeholders from environmental  organizations, recyclers, retailers, and academics. We attempted to contact  all the NEPSI stakeholders listed on NEPSI’s Web site, but we could not  obtain current contact information for 4 of the 48 stakeholders or their  alternates. We also sent surveys to 3 alternate NEPSI stakeholders because  we were told by other stakeholders that they were active participants in  NEPSI deliberations and did not work in the same agency as the primary  stakeholder. We sent another 7 surveys to non-NEPSI participants to  provide more balance in our survey population. These 7 stakeholders  included two retailers, two recyclers (one for profit and one nonprofit), a  recycling trade organization, a retail trade organization, and an EPA  consultant who is an expert on recycling issues. Finally, we excluded from  our survey population 4 stakeholders that did not respond to our survey  who the coordinator of NEPSI characterized as “inactive” during the NEPSI  deliberations, and 1 stakeholder who now works for the same organization  as another stakeholder. In total, our survey population comprised of 49  individuals, 42 of which completed surveys and submitted them to us,  yielding an 86 percent response rate.
To develop the questions for our survey, we identified key information to  gain a general understanding of recycling and reuse issues for used  electronics. In particular, the survey focused on areas such as public  awareness, collections, exports, costs, historic and orphan waste, and  hypothetical provisions in potential federal legislation. After initially  developing, reviewing, and modifying the survey questions, we conducted a  total of six pretests, two with GAO employees who were not associated  with this review, and four non-GAO employees who were chosen on the  basis of having characteristics similar to the NEPSI stakeholders. The final  changes to the survey were made on the basis of the combined  observations from the six pretests.
We conducted our review from October 2004 to September 2005 in  accordance with generally accepted government auditing standards, which  include an assessment of data reliability and internal controls.
section_title: Survey of Selected Stakeholders on Recycling Used Electronics
paragraphs: The U.S. Government Accountability Office (GAO) is an agency that assists the U.S. Congress in  evaluating federal programs.  GAO has been asked by members of the U.S. Senate to identify (1) the  amount of used electronics and the problems they may pose, (2) practices that encourage recycling of  used electronics, and (3) factors that discourage the recycling of these products. The electronic products  in the scope of our analysis include televisions, computer monitors, and computer central processing units  (CPUs), including laptops.
To obtain stakeholder perspectives on recycling used electronics, we are sending this survey to  participants in the NEPSI dialogue.  Please note that we will not publish individual responses to this  survey.  We intend to use the information gained through this survey in a report that we will ultimately provide to the Congress.
This questionnaire can be filled out using MS-Word and returned via e-mail to EWasteSurvey@gao.gov.
If you prefer, you may print copies of the questionnaire and complete them by hand.  If you complete the  survey by hand, fax your completed questionnaire to GAO at (202) 512-2514 or (202) 512-2502.
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If you have any questions about the content of this questionnaire, please e-mail or call Nathan Anderson at AndersonN@gao.gov or (206) 287-4804 or Arvin Wu at WuA@gao.gov or (206) 287-4793.  If you experience any technical difficulties with the questionnaire, please call Jenny Chanley at  ChanleyV@gao.gov or (202) 512-4801 or Monica Wolford at WolfordM@gao.gov or (202) 512-2625.
We recommend reading through the survey once before answering the questions so you have a  clear idea of the broad range of questions you will be asked.
Thank you for your cooperation.
Please provide the following contact information in the event we need to clarify a response.
Preferred means of contact: 1. Which of the following type of organization are you primarily affiliated with? (Select one.)
Federal government  ......................................
State government  ..........................................
Local government .........................................
Trade organization ........................................
Environmental organization  .........................
Electronics recycler ......................................
Retailer  .........................................................
Original equipment manufacturer .................
Other .............................................................  Please specify: 2. Briefly, what is your organization’s interest and role in managing used electronics?
Factors that may affect recycling We would like to know, in your professional opinion, the extent to which the following factors may affect  domestic recycling of used electronics. 3.
In general, how aware do you feel the public is of recycling options for used electronics (such as  whether a product is recyclable or how to get it to a recycler)?
Extremely aware  ............................
Very aware  .....................................
Moderately aware ...........................
Slightly aware  ................................
Not at all aware  .............................. --------------- Don’t know  .................................... 4. To what extent, if at all, does the current level of public awareness of recycling options for used  electronics discourage recycling?
Very great extent  ............................
Great extent  ....................................
Moderate extent ..............................
Little extent  ....................................
No extent  ........................................ --------------- Don’t know or no opinion ..............
5.
In general, for households across the nation, do you feel that the existing waste collection  infrastructure, such as municipal curbside collection programs, is adequate to facilitate recycling of  used electronics?
Yes  .................................................
No ................................................... --------------- Don’t know  ....................................
6.
In your professional opinion, to what extent, if at all, are existing collection options for recycling used  electronics convenient for households?
Very great extent  ............................
Great extent  ....................................
Moderate extent ..............................
Little extent  ....................................
No extent  ........................................ --------------- Don’t know or no opinion .............. 7. What are the most important challenges to facilitating the recycling of used electronics facing the  existing waste collections infrastructure?
8.
In your professional opinion, to what extent, if at all, does the option to export used electronics reduce  the viability of the private domestic recycling infrastructure?
Very great extent  .........................................
Great extent  .................................................
Moderate extent ...........................................
Little extent  .................................................
No extent  ..................................................... --------------- Don’t know or no opinion ...........................
9.
In your professional opinion, would restricting exports of used electronics to certified processors  overseas encourage greater recycling in the U.S.?
Yes  ..............................................................
No ................................................................ --------------- Don’t know or no opinion ...........................
If you wish, describe the basis for your answer: 10. What types of used electronics should be allowed to be exported to non-OECD developing nations?
Working units ................................................................................
Non-working whole units ..............................................................
Circuit boards  ................................................................................
CRT glass cullet ............................................................................
Hazardous commodities (e.g., hazardous metals) .........................
Non hazardous commodities (e.g., non hazardous plastics) ..........
None at all  ..................................................................................... --------------- Don’t know or no opinion .............................................................
11. To what extent, if at all, does the option to use prison labor diminish the viability of the private domestic recycling infrastructure?
Very great extent  ............................
Great extent  ....................................
Moderate extent ..............................
Little extent  ....................................
No extent  ........................................ --------------- Don’t know or no opinion ..............
If you wish, describe the basis for your answer: 12. Should prison industries, as currently operated, be allowed to compete with the private sector for non- government business in the area of used electronics recycling?
Yes  .................................................
No ................................................... --------------- Don’t know or no opinion ..............
If you wish, describe the basis for your answer: 13. Are there any other issues regarding exports and prison labor that diminish the viability of the domestic recycling infrastructure?
Please describe these other issues : ...............................
No .........................
14. To what extent, if at all, does the way in which electronic products are currently designed discourage recycling?
Very great extent  ............................
Great extent  ....................................
Moderate extent ..............................
Little extent  ....................................
No extent  ........................................ ------------- Don’t know  .................................... 15. Some electronic products contain toxic materials that require special handling and processing when  recycled.  Does this discourage recycling of used electronics?
Yes  .................................................
No ................................................... ------------- Don’t know or no opinion .............. 16. We have been told that some used electronics are difficult to manually disassemble.  Does this discourage recycling?
Yes ..................................................
No ................................................... ------------- Don’t know or no opinion ..............
If you wish, describe the basis for your answer: 17. Are there other issues regarding product design that discourage recycling?
Please describe these other issues : ...............................
No .........................
18. In your professional opinion, to what extent, if at all, do unacceptable or potentially illegal activities occur in the recycling industry?  (By unacceptable or potentially illegal activities, we mean activities such as recyclers “dumping” the used electronics they collect or “disposing” of them in ways other than advertised.)
Very great extent  ............................
Great extent  ....................................
Moderate extent ..............................
Little extent  ....................................
No extent  ........................................ ------------- Don’t know  .................................... 19. Other than the issues discussed above (i.e., product design, exporting and prison labor options, collection, and public awareness), are you aware of any other factors that affect the recycling of used  electronics domestically?
Please describe these other issues : ............................... ...............................
Historic, Orphan, and Future Waste 20. In your professional opinion, who should pay for recycling historic waste? (By historic waste, we  mean used electronics that are in storage and have not yet been disposed of or recycled.) (Select one.)
Producers ........................................
Users/consumers  ............................
Taxpayers  ....................................... Other ...............................................   Please identify: --------------- Don’t know or no opinion ..............
If you wish, describe the basis for your answer: 21. In your professional opinion, who should pay for recycling orphan waste? (By orphan waste, we  mean used electronics whose manufacturers no longer exist.) (Select one.)
Producers ........................................
Users/consumers  ............................
Taxpayers  ....................................... Other ...............................................   Please identify: --------------- Don’t know or no opinion ..............
22. In your professional opinion, which financing system will be most effective at recycling historic and  orphan waste?  (By ARF, we mean a fee imposed on consumers when they purchase a product that is  used to recycle other used electronics.  By extended producer responsibility, we mean that a  manufacturer charges an invisible fee, and the price of the product covers all the costs involved in taking back and recycling their product at its end-of-life.)
Advanced recovery fee (ARF)  .......
Extended producer responsibility ...
General tax base funding ................ Other ...............................................   Please identify: --------------- Don’t know or no opinion ..............
If you wish, describe the basis for your answer: 23. In your opinion, what financing system would be most effective at recycling future wastes? (By future wastes, we mean products that are being sold, or will be sold, but will someday become wastes.)
Advanced recovery fee (ARF)  .......
Extended producer responsibility ...
General tax base funding ................ Other ...............................................   Please identify: --------------- Don’t know or no opinion ..............
24. Should national legislation be enacted to overcome the factors that discourage recycling?
Yes  .................................................
No ................................................... --------------- Don’t know  .................................... 25. In the absence of national legislation, which sector(s) should take the lead in the voluntary efforts to  encourage recycling of used electronics?  (Select all that apply.)
Private sector/industry ..............................................
Public sector/government .........................................
Non-profit sector/environmental organizations  .......
Other sector(s) ..........................................................   Please specify: None of the above  ....................................................
If you wish, describe the basis for your answer: 26. If enacted, which of the following provisions should national legislation include? (Select one in each  row.) a. Disposal bans............................................................................................................. b. Export restrictions ..................................................................................................... c. Toxic constituent restrictions .................................................................................... d. Universal waste designation under RCRA for used electronics (to aid in collection  and transportation)..................................................................................................... e. Tax credits or subsidies for recyclers/processors ..................................................... f. Tax credits or subsidies for manufacturers who used recycled materials.................. g. Certification requirements for recyclers/processors .................................................. h. Requirement that federal agencies purchase environmentally friendly electronics... i. Consumer education programs .................................................................................. j. Other – Specify:     .............................................................................................. 27. If enacted, which, if any, of the following financing mechanisms should national legislation include? (Select one)
Advanced recycling fee (ARF) .................................
Extended producer responsibility (EPR)...................
ARF/EPR hybrid .......................................................
End-of-life fees .........................................................
General tax base funding........................................... 28. How effective would the following implementation scenarios be for funding recycling of historic and  orphan used electronics and future used electronics?(Select one answer in each row.) a. ARF collected at retail level and managed by the federal government (covering collection, transportation, and recycling)  ....... b. ARF collected at retail level and managed by a third-party organization (covering collection, transportation, and recycling) ........ c. ARF/EPR hybrid:  ARF for historic waste with a transition to EPR after “X” years.......... d. ARF for collection/transportation of used electronics, and EPR for  recycling/processing ........................................ e. EPR with market share divisions for orphan waste................................................................ f. EPR with retroactive liability for historic waste................................................................ g. End of life fees ................................................ h. Local tax base funding for  collection/transportation, and EPR for recycling/processing ........................................ i. Deposit/refund for collection/transportation, and EPR for recycling ..................................... j. Deposit/refund ................................................. k. Other – Specify: ....................................
29. How willing would you (the organization or entity you represent) be to operate within the various financing scenarios? (Select one answer in each row.) a. ARF collected at retail level and managed by the federal government (covering collection, transportation, and recycling)....... b. ARF collected at retail level and managed by a third-party organization (covering collection, transportation, and recycling)....... c. ARF/EPR hybrid:  ARF for historic waste with a transition to EPR after “X” years ........ d. ARF for collection/transportation of used electronics, and EPR for  recycling/processing ...................................... e. EPR with market share divisions for  orphan waste .................................................. f. EPR with retroactive liability for historic waste .............................................................. g. End of life fees............................................... h. Local tax base funding for collection/transportation, and EPR for recycling/processing ...................................... transportation, and EPR for recycling............ j. Deposit/refund ............................................... k. Other – Specify: ..................................
EPA’s management of used electronics The Environmental Protection Agency’s Office of Solid Waste (OSW) developed shared responsibility pilots, for example, under the “Plug-In to eCycling” campaign to help demonstrate the kinds of voluntary partnerships that can significantly increase recycling of used electronics in the United States.
Additionally, EPA sponsored the Federal Electronics Challenge (FEC), which encourages federal  agencies to procure environmentally responsible electronic products.  The FEC aims to promote energy star features, extend the life span of electronic equipment, expand the recycling infrastructure for  electronics, and reduce the volume and toxicity of used electronics. 30. In your opinion, to what extent, if at all, have EPA efforts (such as Plug-In to eCycling and its pilots)  encouraged recycling of used electronics?
Very great extent  ............................
Great extent  ....................................
Moderate extent ..............................
Little extent  ....................................
No extent  ........................................ --------------- Don’t know or no opinion .............. 31. Given that the federal government purchases nearly $60 billion worth of electronics equipment  annually, to what extent, if at all, would practices such as “green” product design and the recycling of  used electronics be encouraged if federal agencies were required to procure electronic products that  meet the goals of the Federal Electronics Challenge?
Very great extent  ............................
Great extent  ....................................
Moderate extent ..............................
Little extent  ....................................
No extent  ........................................ --------------- Don’t know or no opinion .............. 32. In your opinion, to what extent, if at all, have the following factors hindered EPA’s ability to encourage recycling of used electronics? (Select one answer in each row.) a. Lack of program goals.................................. b. Lack of performance measures for pilot  programs....................................................... c. Lack of data on quantity of used electronics .................................................... d. Lack of legislative authority......................... e. Other – Please identify:    ....................
If you wish, describe the basis for your answer: 33. In your opinion, how can EPA improve its effectiveness in encouraging recycling of used electronics? 34. In your opinion, to what extent, if at all, will the Waste Electrical and Electronic Equipment (WEEE)
Directive facilitate collection, transportation, and processing of used electronics in the E.U.?
Very great extent ..............................
Great extent ......................................
Moderate extent  ...............................
Little extent ......................................
No extent  ......................................... --------------- Don’t know or no opinion ................
35. In your opinion, to what extent, if at all, will the Restriction of Hazardous Substances in Electrical and Electronic Equipment (RoHS) Directive encourage “green” product design in the E.U.?
Very great extent  ............................
Great extent  ....................................
Moderate extent ..............................
Little extent  ....................................
No extent  ........................................ --------------- Don’t know or no opinion ..............
If you wish, describe the basis for your answer: 36. In your opinion, to what extent, if at all, are the following health and/or environmental problems  associated with the disposal of used electronics in the U.S.? (Select one answer in each row.)  a. Leaching of toxic substances from a municipal landfill into groundwater or surface water................ b. Toxic emissions from incinerators............................ c. Worker exposure to toxic substances at  electronics disassembly facilities.............................. d. Volume of wastes in municipal landfills .................. e. Loss of natural resources .......................................... f. Other – Identify: ............................................
37. Please indicate which problem from the prior question you think is the most significant problem associated with the disposal of used electronics in the U.S., and if you wish, describe why.  38. If you have any other comments that you would like to share with us concerning any issue related to  the recycling of used electronics, please use the space below.
Thank you very much for your help.
Please save this file now and send an e-mail with your saved questionnaire file as an  attachment to EWasteSurvey@gao.gov.
section_title: Comments from the Environmental Protection Agency
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: Individuals making key contributions to this report included Nathan  Anderson, Charles Bausell, Virginia Chanley, Bernice Dawson, Steve  Elstein, Omari Norman, Alison O’Neill, Judy Pagano, Carol Herrnstadt  Shulman, Monica Wolford, and Arvin Wu.