The Federal EPA is rapidly moving towards the re-classification of computer equipment as "universal waste". Computer waste has become a significant polluter of our landfills. There is no single environmental issue that has created more state legislative activity over the past two years than electronic recycling.

Universal waste is a form of hazardous waste. To be a universal waste, an item must be first classified a hazardous waste and it must exist both in the private and commercial sector in the same form.
Examples of universal wastes are: batteries, thermostats containing mercury, florescent lights, and pesticides. The purpose of the universal waste designation is to promote the recycling of the particular item. The universal waste designation significantly reduces the paper work documentation versus a hazardous waste classification. (unlike hazardous waste, shipping manifests are not required to accompany the movements of universal waste) It reduces the cost of transporting the product by allowing universal waste to be transported by common carrier trucks rather than specially licensed (and expensive) hazardous waste haulers. It also exempts individuals and small business (identified as a small quantity generator) from the liabilities (but not the regulations themselves) associated to improper disposal.

Under universal waste regulations most mid size and large organizations will be designated "small quantity universal waste handlers" This designation differs from the small quantity generator exemption definition and is subject to the regulation's liabilities ($2000.00 fine per violation). The definition of this category covers an organization that accumulates more than 100 kilograms (220 pounds,about 8 monitors or CPUs) of universal waste at one time, but does not accumulate more than 5000 kilograms (11,000 pounds, about 350 monitor or CPUs) of universal waste at one time at one location. Organizations that exceed this limit are identified as "large quantity universal waste handlers" and must register with both the State DEP and Federal EPA.

State legislatures and DEPs have taken the lead on this issue. There are currently 26 States that have either adopted or are in the process of adopting regulations governing the disposal of consumer electronics. Landfill bans on CRTs are one of the most common regulations with MA, ME, MI, WI, and CA all having adopted this regulation.

Federal EPA: The Federal EPA is currently evaluating a change in CRT disposal regulations. The EPA is evaluating the removal of CRTs from the solid waste category, thus, in theory, easing the ability to recycle the product. This relaxing of EPA control over the disposal process is being criticized by environmental groups as a step backwards. Several states have submitted comments recommending that CRTs be classified as a universal waste. What ever the case, any new regulations would not be adopted before 2005. The Federal EPA currently classifies cathode ray tubes (CRTs) found in computer monitors and televisions as a hazardous waste. This classification is based upon the high concentration of lead found in all cathode ray tubes. The Federal EPA's position on the disposal of CRTs found in both computer monitors and televisions are as follows:

Households: Used computer monitors or televisions generated by households are not considered hazardous waste and are not regulated under federal regulations.

Donations or Resale: Monitors or televisions sent for continued use (i.e., resold or donated) are not considered hazardous waste.

Small Quantities Exempt: Businesses or other organizations are not regulated under most federal requirements if the facility discards less than 100 kilograms (about 220 lbs or 8 monitors) of hazardous waste per month. (this waste must still go to facilities authorized to receive solid waste.)

Ohio follows RCRA standards for electronics. Under Ohio’s provisions, computer CRTs are not regulated as hazardous wastes if the generator has them recycled. The state considers discarded integrated circuits from computer systems to be scrap metal. Scrap metal is not regulated as hazardous waste if it is reclaimed or recycled.

Ohio EPA classifies used electronic equipment exhibiting a characteristic of a hazardous waste as a characteristic by-product when it is recycled. Unused, defective computers and electronic equipment are defined as commercial products. Computers and electronic equipment may exhibit the characteristic of toxicity as defined in the Ohio Administrative Code (OAC) rule. This rule indicates that characteristic by-products and commercial products that are reclaimed are not wastes.

In Ohio, refurbished computer equipment is not considered a waste because it is still in commerce. However, any generator of discarded components must evaluate these for the characteristics of a hazardous waste according to the OAC rule.


U.S. Environmental Protection Agency

Ohio Environmental Protection Agency

Hazardous Waste Management Standards




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