EPA considering new rules for CRT glass recycling

The U.S. Environmental Protection Agency is considering a new rule it says will help it better track of cathode ray tube (CRT) monitors and televisions exported for recycling and reuse.

“When used CRTs are exported for recycling or reuse, there may be several persons involved from the time that a decision is made to export these materials up to the time that the actual export occurs. The trade in used electronics can take place along a chain of businesses that collect, refurbish, dismantle, recycle, and reprocess used electronic products and their components,” the EPA states in its proposed change of regulations, available here.

James Levine, President of Regency Technologies in Cleveland, says the new law aims to make recyclers throughout the export chain more accountable for the handling of these materials, not just the primary exporter as is currently the case.

“The EPA is trying to make people more accountable a few more levels down the line,” Levine says.

The proposal defines exporters of CRTs as “any person in the United States who initiates a transaction to send used CRTs outside the United States or its territories for recycling or reuse, or any intermediary in the United States arranging for such export.’’

Under current law, exporters of CRTs must notify the EPA of an intended shipment 60 days before the shipment occurs. Notifications may cover exports extending over a 12-month or shorter period. This notification includes information about the exporting recycler, the importing recycler and the frequency and estimated quantity to be shipped, and which countries the material will pass through on its way to its final destination.

The EPA then it notifies the receiving country and any transit countries. When the receiving country consents in writing to receive the CRTs, EPA forwards an Acknowledgement of Consent (AOC) to the exporter. The exporter may not ship the CRTs until he receives the AOC. Under these rules, exporters are not required to tell the EPA how much was actually exported in a given year.

The new rules proposed would require annual reports from all parties defined as exporters. These reports must provide basic information abot the business and the total quantities actually shipped for recycling, the frequency of shipment and the ultimate destination of the exported materials. This, the EPA says, will help determine that the CRTs are handled as commodities and not waste.

A new rule will also subject CRTs sent for reuse will be to similar notifications and requirements.

“The Agency has become aware that some CRTs allegedly exported for reuse are actually recycled in the receiving country, sometimes under unsafe conditions. Failure to file the notice required for CRTs sent for recycling deprives the Agency of its ability to notify the receiving country about the CRTs to be imported,” according to the EPA.

This new requirement for reporting would help prevent that, the EPA says.

EPA’s proposal to impose additional notification requirements on exporters handling used, intact CRTs intended for re-use raises jurisdictional issues, according to the Institute of Scrap Recycling Industries.  Despite RCRA (Resource Conservation and Recovery Act) jurisdiction being limited to materials that have been “discarded,” the proposal intends to expand EPA’s reach to also cover used, functioning CRTs exported for reuse.  The rationale is based on the grounds that the export of such used products might actually be intended for some purpose other than re-use and therefore raising a concern that the CRT’s might be improperly discarded at a future date and place.  This assertion is contrary to US law as RCRA’s jurisdiction does not extend to reusable CRTs, especially functional units.

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