Electronic Waste
Observations on the Role of the Federal Government in Encouraging Recycling and Reuse Gao ID: GAO-05-937T July 26, 2005Advances in technology have led to rapidly increasing sales of new electronic devices, particularly televisions, computers, and computer monitors. With this increase comes the dilemma of how to manage these products when they come to the end of their useful lives. Concerns have been increasingly expressed that while millions of existing computers become obsolete each year, only a fraction of them are being recycled. Some have alleged that the disposal of used electronics causes a number of environmental problems. They note, for example, that toxic substances such as lead can leach from used electronics. They have also noted that computers and other electronic equipment contain precious metals that require substantial amounts of energy and land to extract. These metals, they say, can often be extracted with less environmental impact from used electronics than from the environment. In this testimony, GAO summarizes existing information on the amounts of, and problems associated with, used electronics. GAO also examines the factors affecting the nation's ability to recycle and reuse electronics when such products have reached the end of their useful lives. This testimony discusses preliminary results of GAO's work. GAO will report in full at a later date.
Available estimates suggest that the amount of used electronics is large and growing, and that if improperly managed can harm the environment and human health. While data and research are limited, some data suggest that over 100 million computers, monitors, and televisions become obsolete each year, and that this amount is growing. These obsolete products are either recycled, reused, disposed of in landfills, or stored by users in places such as basements, garages, and company warehouses. Available data suggest that most used electronics are probably stored. The units still in storage have the potential to be recycled and reused, or disposed in landfills; or, they may be exported for recycling or reuse overseas. If disposed of in landfills, valuable resources, such as copper, gold, and aluminum, are lost for future use. Additionally, standard regulatory tests show that some toxic substances with known adverse health effects, such as lead, have the potential to leach from discarded electronics into landfills. Although one study suggests that this leaching does not occur in modern U.S. landfills, it appears that many used electronics end up in countries without either modern landfills or with considerably less protective environmental regulations. Economic factors, such as cost, 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 their used electronics recycled or refurbished for reuse. Consumers in Snohomish County, Washington, for instance, may have to travel more than an hour to the nearest drop-off location, which then charges between $10 and $27 per unit, depending on the type and size of the product. Recyclers and refurbishers charge these fees because costs associated with their processes outweigh the revenue received from recycled commodities or refurbished units. In addition to the challenges posed by these economic factors, federal regulatory requirements provide little incentive for environmentally preferable management of used electronics. The governing statute, the Resource Conservation and Recovery Act, regulates the disposal practices of large generators of hazardous waste (including electronic waste) but exempts individuals and households from these requirements. In the absence of a national framework for dealing with the problem, a patchwork of potentially conflicting state requirements appears to be emerging. Manufacturers in one state, for instance, may have an advance recovery fee placed on their products, but the same manufacturers may have to take back their products and pay for recycling in another. This patchwork may be placing a substantial burden on recyclers, refurbishers, and other stakeholders. As GAO concludes its work, it will examine the implications of these findings for the ongoing efforts among the states to deal with this growing problem, for the various legislative solutions that have been proposed to create a uniform national approach, and for options the federal government can pursue to encourage recycling and reuse of electronics.
GAO-05-937T, Electronic Waste: Observation on the Role of the Federal Government in Encouraging Recycling and Reuse
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Testimony:
Before the Subcommittee on Superfund and Waste Management, Committee on
Environment and Public Works, U.S. Senate:
United States Government Accountability Office:
GAO:
For Release on Delivery Expected at 2:30 p.m. EDT:
Tuesday, July 26, 2005:
Electronic Waste:
Observation on the Role of the Federal Government in Encouraging
Recycling and Reuse:
Statement of John B. Stephenson,
Director:
Natural Resources and Environment:
GAO-05-937T:
GAO Highlights:
Highlights of GAO-05-937T, a testimony before the Subcommittee on
Superfund and Waste Management, Committee on Environment and Public
Works, United States Senate:
Why GAO Did This Study:
Advances in technology have led to rapidly increasing sales of new
electronic devices, particularly televisions, computers, and computer
monitors. With this increase comes the dilemma of how to manage these
products when they come to the end of their useful lives. Concerns have
been increasingly expressed that while millions of existing computers
become obsolete each year, only a fraction of them are being recycled.
Some have alleged that the disposal of used electronics causes a number
of environmental problems. They note, for example, that toxic
substances such as lead can leach from used electronics. They have also
noted that computers and other electronic equipment contain precious
metals that require substantial amounts of energy and land to extract.
These metals, they say, can often be extracted with less environmental
impact from used electronics than from the environment.
In this testimony, GAO summarizes existing information on the amounts
of, and problems associated with, used electronics. GAO also examines
the factors affecting the nation‘s ability to recycle and reuse
electronics when such products have reached the end of their useful
lives.
This testimony discusses preliminary results of GAO‘s work. GAO will
report in full at a later date.
What GAO Found:
Available estimates suggest that the amount of used electronics is
large and growing, and that if improperly managed can harm the
environment and human health. While data and research are limited, some
data suggest that over 100 million computers, monitors, and televisions
become obsolete each year, and that this amount is growing. These
obsolete products are either recycled, reused, disposed of in
landfills, or stored by users in places such as basements, garages, and
company warehouses. Available data suggest that most used electronics
are probably stored. The units still in storage have the potential to
be recycled and reused, or disposed in landfills; or, they may be
exported for recycling or reuse overseas. If disposed of in landfills,
valuable resources, such as copper, gold, and aluminum, are lost for
future use. Additionally, standard regulatory tests show that some
toxic substances with known adverse health effects, such as lead, have
the potential to leach from discarded electronics into landfills.
Although one study suggests that this leaching does not occur in modern
U.S. landfills, it appears that many used electronics end up in
countries without either modern landfills or with considerably less
protective environmental regulations.
Economic factors, such as cost, 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 their used
electronics recycled or refurbished for reuse. Consumers in Snohomish
County, Washington, for instance, may have to travel more than an hour
to the nearest drop-off location, which then charges between $10 and
$27 per unit, depending on the type and size of the product. Recyclers
and refurbishers charge these fees because costs associated with their
processes outweigh the revenue received from recycled commodities or
refurbished units. In addition to the challenges posed by these
economic factors, federal regulatory requirements provide little
incentive for environmentally preferable management of used
electronics. The governing statute, the Resource Conservation and
Recovery Act, regulates the disposal practices of large generators of
hazardous waste (including electronic waste) but exempts individuals
and households from these requirements.
In the absence of a national framework for dealing with the problem, a
patchwork of potentially conflicting state requirements appears to be
emerging. Manufacturers in one state, for instance, may have an advance
recovery fee placed on their products, but the same manufacturers may
have to take back their products and pay for recycling in another. This
patchwork may be placing a substantial burden on recyclers,
refurbishers, and other stakeholders. As GAO concludes its work, it
will examine the implications of these findings for the ongoing efforts
among the states to deal with this growing problem, for the various
legislative solutions that have been proposed to create a uniform
national approach, and for options the federal government can pursue to
encourage recycling and reuse of electronics.
www.gao.gov/cgi-bin/getrpt?GAO-05-937T.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact John Stephenson at (202)
512-3841 or Stephensonj@gao.gov.
[End of section]
Mr. Chairman and Members of the Subcommittee:
Thank you for the opportunity to discuss our work to date on the issues
surrounding the growing volume of used electronics accumulating in the
nation's basements, attics, and landfills. Rapid advancements 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 come to the
end of their useful lives. The Environmental Protection Agency (EPA)
has estimated that in 2003 alone, about 50 million existing computers
became obsolete, but one estimate forecast that less than 6 million
were recycled.
Disposal of used electronics creates potential problems that can be
averted through recycling or reuse. For example, concerns have been
raised because toxic substances such as lead, which have well-
documented adverse health effects, can potentially leach from used
electronics. Concerns have also been raised over used electronics that
are exported from the United States to countries with less stringent
environmental regulations. In addition, computers contain precious
metals, such as gold, silver, and platinum, that 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.
In this context, you and several other Members of the Congress asked
that we address a number of issues surrounding this problem.
Specifically, we were asked to (1) summarize existing information on
the volumes of, and problems associated with, used electronics and (2)
examine the factors affecting the nation's ability to recycle and reuse
electronics when such products have reached the end of their useful
lives.
To address these issues, we are examining studies that provide
nationwide estimates on the amount of used electronics,[Footnote 1] as
well as federal and state government studies (including those by EPA
and task forces in Oregon and Washington), industry and interest group
studies, and local studies (including municipal solid waste
characterization studies) that discuss the problems associated with
used electronics. We are also visiting states and localities that have
implemented programs or passed legislation to responsibly manage used
electronics, including California, Maine, Maryland, Massachusetts,
Oregon, and Washington. In addition, we are surveying participants in
the National Electronics Product Stewardship Initiative and other key
stakeholders, which include key stakeholders from federal, state, and
local governments, environmental organizations, recyclers, retailers,
equipment manufacturers, and academicians. To date, we have received
responses from 41 of the 53 survey participants. We are also comparing
current government and industry practices with existing practices for
promoting recycling in other industries, such as bottle-and can-
recycling programs and the Rechargeable Battery Recycling Corporation
program. Further, we are examining EPA-sponsored federal, state, and
local pilot programs that attempt to encourage recycling of electronic
products. Our work is being done in accordance with generally accepted
government auditing standards, which include an assessment of data
reliability and internal controls.
We are here to present our preliminary observations on these issues. We
will report the final results of our study and any recommendations we
may develop at a later date. In summary:
* Available estimates suggest that the volume of used electronics is
large and growing and that if improperly managed can harm the
environment and human health. While data and research are limited, some
data suggest that over 100 million computers, monitors, and televisions
become obsolete each year and that this amount is growing. These
obsolete products can be either recycled, reused, disposed of in
landfills, or stored by users in places such as basements, garages, and
company warehouses. Available data suggest that most used electronics
are probably stored. These units have the potential to be recycled and
reused, disposed of in landfills, or exported for recycling and reuse
overseas. If ultimately disposed in landfills, either in the United
States or overseas, valuable resources, such as copper, gold, and
aluminum, are lost for future use. Additionally, standard regulatory
tests show that some toxic substances with known adverse health
effects, such as lead, have the potential to leach into landfills.
Although one study suggests that leaching is not a concern in modern
U.S. landfills, it appears that many of these products end up in
countries without modern landfills or the environmental regulations
comparable to the U.S.
* Both economic and regulatory factors discourage recycling and reuse
of used electronics:
* 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. Consumers in Snohomish County, Washington, for
instance, may have to travel more than an hour to the nearest drop-off
location, which then charges between $10 and $27 per unit depending on
the type and size of the product. Consumers in the Portland, Oregon
area, pay one local recycler 50 cents per pound to have their used
computers recycled, which is about $28 for an average-sized desktop
computer. Recyclers and refurbishers charge these fees because costs
associated with recycling and refurbishing outweigh the revenue
received from recycled commodities or refurbished units. This point was
underscored by the International Association of Electronics Recyclers,
which reported 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. It was further underscored by our
interviews with eight electronics recyclers, who were unanimous in
emphasizing that they could not cover costs without charging fees.
* Federal regulatory requirements provide little incentive for
environmentally preferable management of used electronics. The
governing statute, the Resource Conservation and Recovery Act, bars
entities that dispose of more than 220 pounds of hazardous waste per
month from depositing hazardous waste (including some used electronics)
in landfills. However, RCRA does not prohibit households and entities
that generate less than 220 pounds of hazardous waste per month from
sending hazardous waste to municipal landfills. Consequently, since
only four states currently ban disposal of used electronics in their
trash or local landfill, most consumers in the remaining 46 states (and
the District of Columbia) are allowed to do so--and have little
incentive to do otherwise. Not surprisingly, available data suggest
that states and localities that do not have landfill bans have
dramatically lower levels of recycling than the four states that have
enacted landfill bans. In addition, federal regulations provide for
neither a financing system for responsible management of used
electronics, nor oversight of these products when exported--a
particular problem in the case of some developing countries, where
risks to the environment and human health may be more likely because of
less stringent environmental regulations.
In the absence of a national approach, a patchwork of potentially
conflicting state requirements is developing. This patchwork may be
placing a substantial burden on recyclers, refurbishers, and other
stakeholders. As we conclude our work, we will be examining the
implications of our findings for the ongoing efforts among the states
to deal with the problem, for the various legislative solutions that
have been proposed to create a uniform national approach, and for
options the federal government can pursue to encourage recycling and
reuse of used electronics.
Background:
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 requires federal
agencies to procure items that are, to the maximum extent practicable,
produced with recovered materials. The Pollution Prevention Act
provides 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. It 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 on 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.
Nonetheless, while large-quantity generators, such as businesses,
schools, and government agencies, must treat some used electronics as
hazardous waste due to the relatively high level of toxic substances,
it is not illegal for households or for small quantity generators--non-
household entities disposing of less than 220 pounds per month--to
dispose of used electronics in landfills in most states. Under RCRA,
household hazardous wastes, including used electronics, may be disposed
of at municipal solid waste landfills. However, some states have begun
imposing more stringent disposal requirements for used electronics. For
example, because of concerns regarding the potential environmental and
health effects of leaded glass in cathode ray tubes (CRTs), California,
Maine, Massachusetts, and Minnesota recently banned them from disposal
in municipal landfills.
As national awareness of potential problems associated with the
disposal of used electronics has grown, EPA has taken steps to
encourage recycling of used electronics. For instance, EPA, together
with electronics manufacturers, retailers, and recyclers, sponsored
several pilot programs in 2004 to measure the success of convenient
collection options for used electronics. Other recent EPA efforts, such
as the Federal Electronics Challenge and the Electronic Product
Environmental Assessment Tool (EPEAT) program, attempt to leverage U.S.
government procurement power to drive environmentally preferable design
for electronic products. Finally, through the establishment of the
National Electronic Product Stewardship Initiative (NEPSI) in 2001, EPA
established a voluntary, multi-stakeholder initiative to reach
consensus on a national approach to encourage recycling of used
electronics. This voluntary effort ultimately dissolved in 2005 without
agreement, however, because stakeholders could not reach consensus on a
nationwide financing system.
Volume of Used Electronics and the Problems They Pose:
The information we have reviewed to date 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 would become obsolete in 2003--a three-fold
increase over the 33 million obsolete computers and monitors in
1997.[Footnote 2] 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 CRT
technology is replaced by new technologies such as plasma
screens.[Footnote 3]
Thus far, it appears that relatively few units 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 units that are obsolete (or
becoming obsolete), and the quantity either in landfills or sent to
recycling centers, suggests that most used electronics are still in
storage--such as attics, basements, and garages--and that their
ultimate fate is still not certain, 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. Further, 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.[Footnote
4] The research we have thus far 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 a computer's life
can be saved through reuse instead of producing a new unit from raw
materials.[Footnote 5]
Regarding the issue of toxicity, the research we have reviewed to date
is unclear on the extent to which toxic substances may leach from used
electronics in landfills. On one hand, according to a standard
regulatory test RCRA requires to determine whether a solid waste is
hazardous and subject to federal regulation, lead (a substance with
known adverse health affects) leaches from some used electronics under
laboratory conditions. Tests conducted at the University of Florida
indicate that lead leachate from computer monitors and televisions with
cathode ray tubes exceeds the regulatory limit and, as a result, could
be considered hazardous waste under RCRA.[Footnote 6] On the other
hand, the study's author told us that these findings are not
necessarily predictive of what could occur in a modern landfill.
Furthermore, a report by the Solid Waste Association of North America
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.[Footnote 7]
Economic and Regulatory Factors Deter Recycling and Reuse of Used
Electronics:
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 often inconvenient
locations 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. These easy and inexpensive
alternatives help explain why so little recycling of used electronics
has thus far taken place in the United States. 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.
Cost and Consumer Inconvenience Discourage Recycling and Reuse of Used
Electronics:
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 used electronics and transporting them to
recyclers. Moreover, such transfer stations are generally not
conveniently located, and rural residents, such as those in Snohomish
County, may need to drive more than an hour to get to the nearest drop-
off station.[Footnote 8] 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 the consumer 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.[Footnote 9]
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 their 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.
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
machinery is being used to process the relatively limited supply of
used electronics being recycled in the United States. The firm's
officials noted that in Europe, by contrast, where manufacturers are
required to take financial responsibility for the disposal of their
products, the increased supply of recyclable electronics has decreased
the firm's per-unit processing costs and increased the profitability of
recycling used electronics.
Finally, recyclers incur additional expenses when handling and
disposing of toxic components (such as batteries) and toxic
constituents (such as lead), which are all commonly found in used
electronics. These expenses include removing the toxic components and
constituents from the product, as well as handling and processing them
as hazardous material. Once separated from the product, these wastes
are considered hazardous wastes and are 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. Since CRT
manufacturing is declining in the United States, some recyclers send
their CRT glass to a lead smelter in Missouri that charges recyclers
for their CRT glass. 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.[Footnote 10]
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 encourage used electronics recycling, EPA sponsored pilot programs
that addressed the cost and inconvenience issues. Office Depot and
Hewlett-Packard, for example, partnered to provide free take-back of
used electronics at Office Depot retail stores. Collected used
electronics were sent 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.
Federal Regulatory Framework Governing Used Electronics Provides Little
Incentive for Recycling or Reuse:
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 little to preclude
electronic products generated in the United States from being exported
and subsequently threatening human health and the environment overseas.
While several promising federal initiatives supporting electronics
recycling have been launched, their voluntary nature makes their
success uncertain.
Hazardous Used Electronics Are Allowed in Municipal Landfills:
Regulation of used electronics at the federal level 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. However, households and small quantity generators are
exempt from many RCRA regulations, thus allowing them to deposit their
used electronics in municipal solid waste landfills--even though
cathode ray tubes 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 it lacks the authority to require environmentally preferable
management of used electronics through recycling and reuse or to
establish a mandatory national approach, such as a disposal ban. As a
result, all of the office's efforts with regard to the recycling of
used electronics are voluntary.
In response to RCRA's exemption for household hazardous waste and the
growing volume of obsolete electronics within their boundaries, four
states--California, Maine, Massachusetts, and Minnesota--recently
banned from landfills some used electronics.[Footnote 11] Our
preliminary work suggests that such bans 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
told us 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 were no longer
being disposed of in landfills. In Massachusetts, an official with the
Department of Environmental Protection told us that six businesses
dedicated to electronics recycling were created following the enactment
of a landfill ban. Finally, about 75 percent of the survey respondents
to date said that a national disposal ban should be enacted to overcome
the economic and regulatory factors that discourage recycling and reuse
of used electronics.
Experts Believe a National Financing System is Needed to Support
Recycling:
Given the inherent economic disincentives to recycle used electronics,
we found widespread agreement among our survey respondents and others
we contacted that the establishment of some type of financing system is
critical to making recycling and reuse sufficiently inexpensive and
convenient to attract the participation of consumers. For instance,
almost 90 percent of survey respondents believe that either an advanced
recycling fee (ARF), extended producer responsibility (EPR), or a
hybrid of the two should be implemented if national solution is
instituted. Yet despite broad agreement in principle, participants in
the recent multi-stakeholder 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 for used electronics had
sufficient capacity to recycle large volumes, consumers and large-
quantity generators 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 20 cents per pound to collectors 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
boundary, however, may prove difficult because the payout for used
electronics 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. 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 their
end of life--a strategy referred to as EPR. 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 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: they must still take their products to a consolidation
point, and will still likely have to pay a fee.
Several other states, as well as some countries, 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.[Footnote 12] 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
manufacturer take-back programs. In Europe, the European Union
implemented the Waste Electrical and Electronic Equipment Management
Regulations in July 2004, which requires producers of electronic
products to be financially responsible for the recycling or reuse of
their products at end of life. In our final report, we will provide a
more complete examination of various strategies for financing
environmentally preferable management of used electronics.
Oversight of Exported Used Electronics Is Limited:
The lack of oversight over exports of used electronics could also
discourage environmentally preferable management of used electronics.
In the United States, businesses, schools, government agencies, and
other organizations, as well as households, face multiple options for
their used electronics. In some instances, organizations and recyclers
receive e-mails from brokers, who typically have partners in Asia,
willing to pay them for their used electronics, regardless of whether
they can be reused. For example, one broker requests up to 50,000 used
monitors per month and does not require the monitors to be tested.
Another broker specifically requests nonworking monitors and wanted to
fill at least 10 containers, which equals anywhere from 6,000 to 11,000
units, depending on their size. One Seattle area recycler said that
brokers such as these are probably not handling the units in
environmentally preferable ways once the units are exported. Even so,
one business we contacted said it regularly receives e-mail requests
such as these.
Companies export used electronics because the largest markets for
reused computers and computer parts are overseas, according to an EPA
official. Likewise, demand is high for recycled commodities, which can
be processed more cheaply due, in part, to lower wages and less
stringent environmental requirements. Also, unlike their counterparts
in some other developed countries, the United States officials have
permitted the export of hazardous used electronics, such as CRT
monitors and televisions, if the exporter asserts that the equipment is
destined for reuse. While some environmental groups have called for a
ban on exports of used electronics, the Congressional Research Service
noted that such a ban would cut recyclers off from many of the markets
able to reuse the materials.[Footnote 13]
However, few safeguards are in place to ensure that exported used
electronics are indeed destined for reuse.[Footnote 14] Used
electronics that are destined for reuse are not considered to be waste
subject to RCRA export regulations. Instead, such electronics are
considered to be commodities, which means that they can be exported
with little or no documentation, notification, and oversight.
Nonetheless, instances have been recently documented in which
environmental and human health threats have resulted from the less-
regulated disassembly and disposal of U.S.-generated used electronics
overseas. For example, 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.[Footnote 15] Without
the ability to track the exported units to importing countries, or to
audit companies exporting used electronics, it is difficult to verify
that exported used electronics are actually destined for reuse, or that
they are ultimately managed responsibly once they leave U.S. shores. As
our work continues, we will further examine the extent of the problems
associated with irresponsible management of used electronics overseas.
Opportunities Exist for Federal Initiatives to Enhance Electronics
Recycling:
The federal government has taken some steps to affirm its commitment to
encourage recycling of used electronics through the implementation of
two voluntary programs sponsored by EPA. The Federal Electronics
Challenge (FEC) and the Electronic Product Environmental Assessment
Tool (EPEAT) both leverage U.S. government purchasing power to promote
environmentally preferable management of electronic products from
procurement through end of life. For example:
* 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 their 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 the
end of their useful lives. To date, 11 federal agencies and 26
individual federal facilities participate in the FEC to some extent.
The Bonneville Power Administration (BPA) recently documented cost
savings associated with its FEC participation. BPA noted, for example,
that the program 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 told us 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
each monitor's life.
* The EPEAT program promotes environmentally preferable management of
electronics by allowing large purchasers, such as government agencies,
to compare and select laptop computers, desktop computers, and monitors
with environmentally preferable attributes. For example, EPEAT
evaluates an electronic product's design 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. EPA expects EPEAT to
be instituted in 2006, and products with higher environmental ratings
could receive preferred consideration in federal procurement decisions.
While we will continue to examine the FEC and EPEAT programs in greater
detail, including how stakeholders say they might be improved, our
preliminary work suggests that the federal government can build on
these initiatives by using its purchasing power to lead markets for
electronic products in environmentally friendly directions. In fact,
there is ample precedent for such a strategy, perhaps most notably in
EPA's and the Department of Energy's Energy Star program. In that
program, the federal government partners with industry to offer
businesses and consumers energy-efficient products that ultimately save
money and protect the environment. 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. Part of Energy Star's success
can be attributed to federal actions, particularly those outlined in
two executive orders that required federal agencies to purchase
products equipped with Energy Star features. Since the federal
government will spend over $60 billion on information technology
products in fiscal year 2005, including televisions, computers, and
computer monitors, it could go beyond the voluntary and limited FEC and
EPEAT programs by broadening the programs' scope and requiring agency
participation in, or adherence to, some of the programs' key practices.
As with the Energy Star program, such actions may lead to cost savings
and greater environmental protection. Of particular note, over 80
percent of the survey respondents to date said that federal government
procurement criteria along the lines of FEC and EPEAT should be
required, and about 95 percent of the survey respondents to date said
that such procurement criteria would encourage environmentally
preferable product design, as well as recycling and reuse.
Observations on Federal Actions to Encourage Recycling and Reuse of
Used Electronics:
In our future work, we will continue to examine factors affecting
recycling in greater detail, and the diverse efforts by individual
states and others to deal with these issues. It is becoming clear,
though, that in the absence of a national approach, a patchwork of
potentially conflicting state requirements is developing, and that this
patchwork may be placing a substantial burden on recyclers,
refurbishers, and other stakeholders. 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. Further, a retailer may have to set
up a system in one state to collect fees on specific products and, at
the same time, set up a different system in another state to take back
a particular manufacturer's product. Hence, manufacturers we contacted
said that while they had their preferences regarding, for instance, an
ARF or EPR system, their main preference is to operate within a uniform
national system that mandates a financing mechanism that preempts
varying state requirements. Our preliminary survey results substantiate
these views, with over 90 percent of survey respondents indicating that
national legislation should be enacted and, if so, almost 90 percent
believe a financing mechanism should be included.
Our future work will also discuss some of the options--both legislative
and administrative--being considered to encourage environmentally
preferable management of used electronics at a national level.
Frequently cited options include disposal bans, consumer education
programs, a variety of financing systems, export restrictions, and
federal government procurement requirements. These options may offer
suggestions for a uniform national approach and what aspects should be
considered. Additionally, an examination of EPA's voluntary programs--
the FEC and EPEAT--may shed light on other, more effective options
available to the federal government that can save money over electronic
products' life cycle; enhance environmental protection; drive markets
for environmentally preferable product design; and establish a
recycling infrastructure and markets for recycled commodities.
Finally, with rapid advances in technology, particularly in consumer
electronics, new products are reaching the marketplace with remarkable
speed. Consequently, our future work will also examine the implications
of these newer generations of electronics entering the nation's waste
stream.
Mr. Chairman, this completes my prepared statement. I would be happy to
respond to any questions you or other Members of this Subcommittee may
have at this time.
Contact and Acknowledgments:
For further information, please contact John B. Stephenson at (202) 512-
3841 or stephensonj@gao.gov. 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, and Arvin Wu.
FOOTNOTES
[1] For the purposes of our study, used electronics includes computers,
computer monitors, and televisions that have reached the end of their
original useful life.
[2] National Safety Council, Electronic Product Recovery and Recycling
Baseline Report, May 1999. These estimates are based on major
assumptions, as well as responses from only 38 percent of sampled
companies. Although the study supports the existence of a large and
growing problem, the precise estimates should be used with caution.
[3] International Association of Electronics Recyclers, IAER
Electronics Recycling Industry Report, 2003. These estimates are based
on major assumptions, as well as responses from only 20 percent of
sampled companies. Although the study supports the existence of a large
and growing problem, the precise estimates should be used with caution.
[4] Bleiwas, Donald and Kelly, Thomas, Obsolete Computers, "Gold
Mines," or High-Tech Trash? Resource Recovery From Recycling
(Washington, D.C.: U.S. Geological Survey, 2001). Because we have not
yet reviewed this study, this data should be used with caution.
[5] The United Nations University is a think tank for the United
Nations and is not a degree granting university.
[6] Townsend, Timothy, et al, Characterization of Lead Leachability
from Cathode Ray Tubes Using the Toxicity Characteristic Leaching
Procedure. (University of Florida, Department of Environmental
Engineering Sciences: 2000). Because we have not yet reviewed this
study, these estimates should be used with caution.
[7] Solid Waste Association of North America, The Effectiveness of
Municipal Solid Waste Landfills in Controlling Releases of Heavy Metals
to the Environment (2004). Because we have not yet reviewed this study,
this data should be used with caution.
[8] Over 70 percent of the survey respondents felt that existing
collection options for recycling used electronics were inconvenient for
households.
[9] This point is further underscored by our interviews with 8
electronics recyclers, who were unanimous in emphasizing that they
could not cover costs without charging fees.
[10] Boon, J.E., Isaacs, J.A., and Gupta, S.M. "Economic Sensitivity
for End of Life Planning and Processing of Personal Computers." Journal
of Electronics Manufacturing (Vol. 11, 81-93, 2002). Because we have
not yet reviewed this study, this data should be used with caution.
[11] The landfill bans in Maine and Minnesota take full effect in 2006.
[12] An official with the Maryland Department of Environment estimated
that anywhere from 40 to 200 computer manufacturers might be required
to pay the fee. He cited one estimate that the fee will provide the
state with about $400,000 to use toward recycling used electronics.
[13] Congressional Research Service, Recycling Computers and Electronic
Equipment: Legislative and Regulatory Approaches for "E-Waste,"
(Washington, D.C.: 2003).
[14] The following are generally not classified as solid wastes under
RCRA: Used electronics for reuse, whole circuit boards, shredded
circuit boards, if free of certain hazardous materials, metal from used
electronics, and scrap metal.
[15] The Basel Action Network is an environmental group that works to
prevent the trade of toxic wastes from developed countries to
developing countries. The Silicon Valley Toxics Coalition is an
environmental group that works to prevent environmental and human
health problems caused by the electronics industry.
