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Electronics Waste Management Interim Recommendations

Waste electronic equipment, or e-waste, has started to receive much attention. With the rapidly changing environment of computer technology, many systems become obsolete within a few years.

Computer and Electronics Recycling

It has recently been suggested that some components of these consumer electronic devices may contain constituents that could make them subject to regulation as a hazardous waste. Certain components may contain small amounts of RCRA regulated heavy metals, including lead, silver, barium, cadmium, chromium and mercury. Although the Department has no specific knowledge of any brand of components or complete devices failing a TCLP characteristic for hazardous waste, the potential does exist. Massachusetts for example has recently chosen to ban CRTs (cathode ray tubes, or monitors) from disposal in landfills due to the presence of lead in the leaded glass screen.

DEQ, in conjunction with EPA Region III and the other Region III states, is studying the issue of e-waste and we are working as a group toward solutions to promote its effective recycling and safe management. Specific regulatory authorities or exclusions for e-waste do not currently exist in federal or state regulations. One future option proposes e-waste management under a Universal Waste provision of the regulations similar to that currently applicable to waste lamps, rechargeable batteries, pesticides and mercury-containing switches. Other options being explored are a universal variance based on a recycling conditional exclusion. However, because there is no class specific exemption for discarded consumer electronics at present, we must default to the basic waste determination and management provisions of the regulations. The regulations do not define e-waste as a listed hazardous waste. Therefore, it is the generator's responsibility to determine if his devices may exhibit a characteristic of a hazardous waste. The generator will bear sole responsibility to determine if his e-waste or its subcomponents are hazardous wastes and manage them accordingly.

Under Virginia's current applications, e-waste devices that are managed as commercial products for rebuilding, reuse, or remanufacture by component substitution or replacement rather than for disposal would not be considered waste under RCRA. However, if the units are broken apart or disassembled ("demanufactured") into individual components, unit subsystems, or discrete component devices (e.g. capacitors, batteries, transformers, relays, switches, CRTs, motherboards, frame components, etc.), RCRA application issues become more problematic and will have to be evaluated on a case-by-case basis. Any waste components or subassemblies subsequently generated and disposed of will require evaluation under the TCLP criteria and should be managed accordingly. RCRA conditional exemptions may apply to certain subcomponents (e.g., batteries being reclaimed, precious metals being reclaimed, or scrap metal being reclaimed). Also, any e-waste from households will maintain the existing household hazardous waste exclusion, but removed and discarded subcomponents from rebuilders/disassemblers will be a new waste stream subject to possible regulation. Management of e-waste may be subject to regulation under the Virginia Solid Waste Management Regulations under certain conditions applicable to MRFs.

This is an evolving area of the regulations and changes are to be expected during the next year. Information will be included and updated on this site as it becomes available. Please click on the Contacts link if you have any questions about RCRA hazardous waste or solid waste applications.

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Virginia Department of
Environmental Quality
P.O. Box 1105
Richmond, VA 23218
(804) 698-4000

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