ISRI: Federal Export Ban Legislation Unnecessary for Maturing E-Scrap Industry

The 2013 E-Scrap Conference in Orlando concluded yesterday with a debate between ISRI’s Eric Harris and Neil Peters-Michaud of CAER over the legitimacy of HR 2791 (RERA), introduced in the House of Representatives recently by Congressman Gene Green of Texas.

Harris made a compelling case against the legislation arguing that the market conditions don’t support the need for such extreme trade restrictions.  He cited a March 2013 report on the export of UEPs by the U.S. International Trade Commission (ITC), the International Data Corporation survey, as well as a green paper issued by the United Nations University, which all discuss the significant positive changes in both U.S. and foreign practices involving electronics recycling and exports – including new recycling technologies, environmental, health and safety certification standards, new regulations and greater enforcement. The ITC found that only 5.1 percent of all used electronics products (UEPs) collected each year in the U.S. are currently at risk for improper recycling and disposal.  The U.S. market is recycling over 80 of all the UEPs being collected.  And the vast majority of exports are either shipped as commodity grade materials or tested fully functioning devices.

ISRI’s government relations department has been actively meeting with members of Congress over the issue, and according to Harris, “When [members of Congress] looked at the issue, they said, ‘What’s the problem?’” The bill is currently not on any legislative calendars.  In the unlikely event the bill were to pass, Harris made the case that it would violate a number of U.S. trade obligations by discriminating against developing countries and economies in transition and move the industry into hazardous waste management.  Peters-Michaud argued the potential regulations is necessary to put domestic processors on a level playing field with less sophisticated overseas processors.  Harris challenged the assertion asking, is this about protecting the environment or about protecting certain commercial interests?  Many are starting to suspect that it is the latter.

ISRI to State the Case Why RERA is Not the Solution

The 2013 E-Scrap Conference will close later today with Institute of Scrap Recycling Industry’s Eric Harris laying out the facts as to why the “Responsible Electronics Recycling Act” (RERA) is not the solution. Despite its misleading name, Harris will point to a body of evidence showing the legislation is quite the opposite of responsible.

H.R. 2791, introduced this summer by Rep. Gene  Green (TX-29) will negatively influence recycling efforts by undermining existing policies and initiatives, such as those proposed by the Obama Administration and the Interagency Task Force on Federal Electronics Stewardship, and will also violate  international trade laws by unilaterally and arbitrarily banning exports to certain countries.

“The recycling industry applauds the Coalition for American Electronics Recycling (CAER) and Congressman Green for introducing legislation with the goal of advancing responsible electronics recycling, but like H.R. 2791’s predecessors, the bill is fatally flawed,” said Robin Wiener, president of ISRI. “This bill will do nothing to end irresponsible recycling, and further, will limit any opportunity to promote environmentally sound electronics recycling standards in other countries by perpetuating the outdated approach of identifying environmental risk based simply on geographic location rather than responsible operating practices.

“The determination of whether one can export UEPs to a given recycler or refurbisher should turn upon the basis of the receiving facilities’ qualifications to handle the material in an environmentally-sound and safe manner, not the arbitrary happenstance of whether the facility happens to be located in an OECD country, the EU or Lichtenstein.”

The recycling industry supports efforts that contribute to responsible recycling globally and job creation within the U.S.  The best way to accomplish this is through strict enforcement of current laws – domestic and international; restrictions (such as notification, recordkeeping and due diligence requirements) on the export of unprocessed, non-working UEPs to any country for the purpose of recycling, reuse or refurbishment; a ban on the export of UEPs for landfill or incineration for disposal; and the promotion of global trade in tested, working UEPs for reuse and commodity grade e-scrap for recycling by industrial consumers worldwide.

“We support shutting down bad actors that refuse to recycle responsibly, but we fundamentally disagree with the approach of H.R. 2971 and do not believe that onerous regulations based on misinformation, as clearly stated in the U.S. ITC report, will address the problem,” said Lane Epperson, president and co-founder of HiTech Assets, Inc., an IT asset disposition provider in Oklahoma City, OK, and Memphis, TN.

A March 2013 report on the export of UEPs by the U.S. International Trade Commission, as well as a recent green paper issued by the United Nations University, both discuss the significant positive changes in both U.S. and foreign practices involving electronics recycling and exports – including new recycling technologies, environmental, health and safety certification standards, and new regulations and greater enforcement – since the initial NGO anecdotes on the informal sector were released more than 10 years ago, and should have never been relied upon.

Unfortunately, H.R. 2791 does just that – it relies upon the false premise that up to 80 percent of UEPs collected in the U.S. are exported and dumped in non-OECD countries located outside the EU – a statistic unchanged and put forward by CAER and the Basel Action Network repeatedly before the earliest versions of H.R. 2791 were introduced back in 2009.  In contrast, the ITC found that only 5.1 percent of all UEPs collected each year in the U.S. are currently at risk for improper recycling and disposal.

“The legislation relies on an outdated, disproven model that fails to reflect the reality of the present or future global market,” said Joe Pickard, ISRI’s chief economist. “Moreover, supporters of this bill are trying to fabricate jobs out of a market that simply does not exist. In reality, H.R. 2791will actually reduce domestic competition and lead to job losses.  Even the ITC makes it clear throughout its recently completed report that the export of refurbished UEPs for reuse as well as for commodity materials from recycling plays a very positive role both for the U.S. and the importing countries.”

According to the report, “Assessment of Efforts to Restrict the Trade of Electronic Scrap on Electronic Scrap Recycling Industry Jobs and Exports,” by John Dunham and Associates, many smaller firms would be forced out of business and workers let go should H.R. 2791 pass. As the findings state, a ban “will crowd out small existing businesses and inhibit the entry of newer businesses.”

The session takes place from 1 – 2:30 p.m. in the National Ballrooms C-D.

Consumer Electronics and Recycling Industries Announce the Winners of the Second Recycling CRT Glass Challenge

During a session yesterday at the E-Scrap Conference, the Consumer Electronics Association(CEA)®, the Institute of Scrap Recycling Industries Inc. (ISRI)®, and InnoCentive, the pioneer in crowdsourcing and open innovation, announced the winners of the second “CRT Challenge” to develop compelling economic and environmentally preferable solutions for recycling old cathode ray tube (CRT) televisions and monitors. The winning solution proposed using recycled CRT glass as a component for vitrification of nuclear waste. Vitrification involves the melting of nuclear waste materials with glass-forming additives so that the final vitreous product incorporates the waste contaminants.

There are significant volumes of nuclear waste currently planned to be vitrified, especially in the U.S. Dr. Thomas Engelhardt, who is a senior executive advisor to a major international investment fund and holds a doctoral degree in physical chemistry, developed the proposal. His graduate and postgraduate studies at various international research facilities have focused on the characterization of molecular liquids with X-ray, neutron and EXAFS spectroscopy. Dr. Engelhardt will receive a $10,000 award for his CRT Challenge solution.

The runner-up proposed a two-step solution: (1) conducting an extensive literature review on manufacturing processes for using CRT-related waste glass, including cost analysis (raw materials transport) and the impact on the environment; and, (2) creating an approach for developing a property/composition model for using CRT glass waste forms to treat nuclear wastes, by making chemical durable borosilicate glasses geologically stable. Dr. Mariano Velez, a senior research engineer at Mo-Sci Corp., will receive $5,000 for the runner-up solution. Dr. Velez holds a Ph.D. in ceramic engineering and has conducted glass research for more than 30 years, focusing on glasses with very high chemical durability, glass-reinforced polymer composites, materials manufacturing, design and properties optimization, use of nanoparticles and nanofibers, and evaluation of recycled and waste materials.

“These award-winning ideas are the latest step in determining how to responsibly recycle billions of pounds of lead-heavy CRT glass as consumers switch from CRT electronics to liquid crystal, light-emitting diode (LED) and plasma displays,” said Walter Alcorn, CEA vice president for environmental affairs and industry sustainability. “We applaud the winners and thank everyone who participated. CEA will continue to work with government agencies, manufacturers, retailers and recyclers to explore these and other emerging solutions throughout the industry.”

“The innovative solutions provided by the CRT Challenge present a great opportunity to expand and develop new markets for recycled CRT glass and help recyclers as the industry transitions from CRTs to newer display technologies,” said Robin Wiener, president of ISRI. “We applaud the winners and all those who participated, and thank CEA for their partnership in addressing this critical issue in the recycling industry.”

“It’s gratifying to see CEA and ISRI banding together to find more effective ways to recycle cathode ray tubes, some of the biggest offenders when it comes to the growing e-waste issue in America,” said Alpheus Bingham, Ph.D., founder and board member of InnoCentive. “The most recent CRT Challenge, as well as the winning responses, are a testament to the power of crowdsourcing solutions to difficult environmental problems. We look forward to following the progress of these proposed new approaches.”

CEA and the Environmental Defense Fund (EDF) sponsored the first CRT Challenge in 2011, and it yielded three winners. Mario Rosato proposed a closed-loop process for separating lead from glass in a form with high market value for a variety of industries. Nulife Glass Processing Ltd. proposed a solution that utilizes an extremely energy efficient electrically heated furnace, uniquely designed to produce minimal emissions; and operates these furnaces in New York and the UK. The third winner was Robert Kirby, who submitted an idea for combining CRT glass with cement to create tile and bricks that are tested, labeled and sold specifically for applications where lead shielding is required, such as X-ray and fluoroscopy rooms.

CEA and ISRI will work with the winners of this year’s CRT Challenge to further understanding of these solutions among CRT stakeholders, with the goals of raising awareness, helping to create market demand for used CRT glass, and encouraging government consideration of these approaches.

ISRI Steps Up Safety Efforts in Light of Pending NIOSH Reports

ISRI’s electronics division leadership has agreed to step up ISRI’s safety efforts for facilities with potential high risk exposure for certain heavy metals such as lead.  The leadership has asked ISRI staff, Eric Harris, Director of Government and International Affairs and John Gilstrap, Director of Safety, to reach out to NIOSH (The National Institute for Occupational Safety and Health) while at E-Scrap to better understand a pending workplace health hazard evaluation (HHE) expected to be released from NIOSH in the coming months.

The pending HHE is based on a voluntary NIOSH inspection at an e-stewards certified facility that processes CRT glass.  Notwithstanding the HHE report, ISRI’s leadership is committed to ensuring that the industry has the proper awareness training and guidance to protect the health and safety of its workers.  Initial feedback from NIOSH supports the need to focus ISRI’s safety efforts on preventing initial exposures.  Moreover, when there is a reasonable possibility that workers may be exposed to such risks, electronics recyclers have an affirmative obligation to prove that their workers are not being exposed.

As part of ISRI’s “Safely or Not at All” policy, the electronics division is committed to preparing additional education and awareness training opportunities and further guidance to its members to identify and prevent risks and protect workers from such potential exposures.

ISRI’s Director of Safety, John Gilstrap, will be offering a webinar on lead exposures on September 19, 2013, at 4 p.m. EST.

Video: Congressional Update on Cell Phone Unlocking

In this short video from the E-Scrap Conference in Orlando, Kyle Wiens of iFixit discusses efforts in Congress to reverse the Library of Congress’ decision to make cell phone unlocking illegal. Legislation that makes cell phone unlocking legal, at least temporarily, has a promising future as it moves forward on this issue that is of high importance for ISRI members.

EPA Releases Updated FAQ on Cathode Ray Tubes

The EPA’s Office of Resource Conservation and Recovery is pleased to announce the release of an updated set of Frequently Asked Questions (FAQs) on the existing cathode ray tube (CRT) regulation. This set of FAQs includes both new and updated questions that have been added to the original set of CRT FAQs that were released April 2013.   EPA first published the CRT FAQs to assist entities that collect, manage, and recycle used CRTs and CRT glass with understanding the federal regulations that apply to these materials.

Several specific updates include:

(1) What RCRA requirements apply to CRT panel glass (which generally does not fail TCLP), and

(2) What it means for a person to “show that the material is potentially recyclable and has a feasible means of being recycled” under the speculative accumulation provision.

For additional information about this FAQ and CRT recycling, please contact ISRI staff Eric Harris, director of government and international affairs,  at 202-662-8514 and David Wagger, director of environmental management, at 202-662-8533.

A bottle bill, but no PC bill

“Bottle Bills” have been on the books in Massachusetts and Iowa for years. Everyone in America who’s purchased a drink in a plastic or glass container in recent decades is familiar with the 5- or 10- cent deposit paid on each bottle or can. This small fee is returned to the consumer to help insure the container is brought back to collection centers for recycling.

These programs cut down on litter and reduce solid waste in the states’ landfills. The Container Recycling Institute, which advocates for the expansion of container recycling in the U.S., reports a beverage container recovery rate of 85 percent in 2012.

“There are over 40 container deposit systems in place around the world and, for the past four decades, these systems have consistently achieved superior recycling rates,” Susan Collins, President of the Container Recycling Institute, said in a published report on the organization’s web site.

“CRI has found that these other systems have excellent litter reduction and outstanding environmental performance compared to all other forms of recycling. CRI has also seen that the high quality and high quantities of recyclables support manufacturing jobs in the aluminum, plastic, and glass industries. Those same recycling benefits could be realized here in the U.S. and help create higher employment rates, which CRI would like to see grow in Vermont.”
Consumers aren’t really getting free money when they take carefully hoarded cans and bottles to collection points – it’s money they’ve already spent without thinking about it, added at the time of purchase.

What’s interesting about Iowa and Massachusetts is they are the only two states in the U.S. that have bottle bills – but no Extended Producer Responsibility laws for electronics.

Would a similar get-paid-to-recycle bait and switch work in states that have bottle bills, but no electronics recycling laws? In many states with electronics recycling laws, consumers pay a fee at the time of purchase of new electronics to subsidize recycling of obsolete equipment. In non-Extended Producer Responsibility states, consumers often have to pay a fee to recycle TVs and computers.

But what about a refundable deposit on electronics? Something that the consumers pay up front, and then get back when they bring recyclable materials to collection points?

This system may not work well for large items with extensive use lives – things like TV sets, computer monitors that last for years – but for smaller items like mobile phones, which many people keep for two years or less – or tablet PCs and laptops.

While a deposit-return system may not be practical for electronics, Californians pay an Advanced Recycling Fee at the time of purchase for many different types of electronic products. The state has one of the strongest electronics recycling infrastructures in the nation – and it might be due, in part, to residents wanting to get the recycling service they’re paying for at the time of purchase. Such fees serve a double purpose – they make consumers aware of the costs of recycling their old products, and they help to support and develop an industry where capricious commodity pricing and dwindling end markets for CRT glass make profitable electronics recycling challenging for recyclers.

Industry leaders testify at U.S. ITC electronics reuse hearing

Representatives from across different segments of the U.S. and international electronics recycling and reuse industry testified before the U.S. International Trade Commission in Washington May 15.

Early next year, the U.S. International Trade Commission hopes to produce a definitive, unbiased report on how much electronics recyclers are exporting to foreign markets for reuse and recycling.

The U.S. ITC is a bi-partisan, independent federal commission, created in the 1916, which operates in part as a think tank for Congress and the U.S. Trade Representative on trade-related issues. The major operations of the ITC include conducting anti-dumping investigations, studying performance and global competitiveness of U.S. industries and the impact changes in trade policy might have, trade information services and trade policy support. The office plays no role in the development of trade policy and makes no recommendations on policy, only studies the impact policies have or might have for the federal government.

The U.S. ITC is seeking information on:

-the type, volume and value of, and foreign markets of significance for, exports of used U.S. electronic products.

– the forms and activities, with respect to used electronic products, enterprises receiving U.S> exporters shipments; most common end uses of exports in the foreign market; and the extent of cross-border, intra-firm shipments by U.S. exporters;

– the characteristics of used electronic products exported from the U.S. including product condition, composition of shipments and the extent to which exports are processed before export; and

– the forms, activities and characteristics of U.S. exporting enterprises.

If possible, the U.S. ITC is also trying to determine volumes of used electronic products from U.S. companies that are sold for export, sold to U.S. firms, processed by exporting companies and disposed of by exporters.

To see the charge given the U.S. ITC, click Here:

One thing Laura Bloodgood of the U.S. ITC says researchers have observed is a dichotomy in the industry between those who think exports should be encouraged and those who do not.

“At the ITC, we’ve always been geared towards the idea that exporting, international trade is good,” Bloodgood says. However, in the electronics recycling industry, “It does seem to us that people who do want to repair computers, and do want to refurbish them for resale, are very strongly communicating the idea that there are lots of good reasons to export. More than one person has told us U.S. electronics and access to used phones and computers contributed to the Arab Spring.”

For a full list of testimony at the hearing, click HERE.

During the May 15 hearing, Joseph Pickard of the Institute of Scrap Recycling Industries testified on the global nature of scrap trade and how electronic scrap fit into that picture.
“The demand for scrap as feedstock by industrial consumers and manufacturers is truly global in nature. In 2011, the U.S. scrap industry exported scrap to more than 160 countries worldwide while generating nearly $40 billion in export sales and positively contributing to our balance of trade in the amount of almost $33 billion. Taken as a whole, scrap exports were among the top five exports by value from the U.S. last year,” he said.

HiTech Assets reported, that reuse comprises 91% of its annual revenue, and that 595,000 pounds of electronics were exported in 2011.

The top market for its exports was China, which generated 52% of the company’s resale income. Another 28% was generated by Africa and the Middle East, with 9% of the company’s resale income generated from North and South America.

Epperson testified that the company’s electronics sold for reuse are sold in fully working and documented condition.

Willie Cade, of PC Rebuilders and Recyclers, testified that his company has observed electronics deemed ‘unusable’ in the U.S. are still highly useful elsewhere in the globe.

“PCs in the United States are underutilized and well made,” he wrote to the U.S. ITC. According to his company’s internal tracking, sampling more than 15,000 units, “25% of the PCs are used less than 500 hours when they are categorized as “End of Use.”

PCs made for the United States market are known to have significantly higher quality than other markets. This is due principally to the preference given by U.S. buyers to high quality brands.”

Cade also said he felt much of the negative attention on recycling and reuse of electronics overseas is outdated.

“Much progress has been made recently to assure that this equipment is sent for reuse and/or material recovery within formal operations both within and outside the U.S. These formal operations are far more likely to responsibly process these materials notwithstanding  the state of the country’s  economy.  One of a number of factors that has lead me to this conclusion is that there are 202 facilities that are certified to the new R2 or Responsible Recycler Standard as of this writing.  Most of the negative press reports have come from the informal processing of “End of Life” electronics also known as “back yard recyclers.”

Pickard added that exporting used electronics for reuse is ethically sound.

“There is an increasing presence of reuse markets in developing countries, especially Asia, Africa, and South America, where the majority of the population simply cannot afford to purchase the latest available technology. It is both environmentally and socially responsible to help bridge the existing digital divide and continue to export these viable products that make basic technologies and communications available where they would otherwise potentially not be,” he said. “It is critical that the responsible, legitimate trade of commodity grade scrap generated from the recycling of electronics, as well as the trade in functioning, reusable electronic equipment be differentiated from illegal exports to informal recycling sectors.”

He added, “In addition to promoting legitimate international trade, the focus must be to promote responsible recycling globally and concentrate efforts towards enhancing and promoting environmentally capable facilities that will receive and properly handle recycled materials anywhere in the world.”

Witnesses at ITC hearing:


HiTech Assets, Inc., Oklahoma City, Okla., Lane Epperson, President and CEO

Forever Green By Way of Recycling, Inc., Chantilly, Va., Gordon F. Scott, Owner

LifeSpan Technology Recycling, Boston, Ma., Dag Adamson, President

Regency Technologies, Twinsburg, Ohio, Jim Levine, President

Sims Recycling Solutions, Roseville, Ca., Renee St. Denis, Vice President of Business Development


TechSoup Global, San Francisco, Ca., Jim Lynch, Director of GreenTech & Electronics Recycling & Reuse Programs, Seattle, Wash., Charles Brennick, Director

American Retroworks, Inc., Middlebury, Vt., Robin Ingenthron, President

PCRR Rebuilders & Recyclers, Chicago, Willie Cade, Owner

iFixit ,  Atascadero, Ca., Kyle Wiens, CEO


Umicore USA Inc., Raleigh, N.C., Holly A. Chapell, Director of Governmental Affairs

International Precious Metals Institute, Cheshire, Ct., John Bullock, Chair, Environmental and Regulatory

Affairs Committee

Coalition of American Electronics Recycling, New York City, Wendy Neu, Executive Vice President, Hugo

Neu Corporation

National Center for Electronics Recycling, Parkersburg, W.Va., Jason Linnell, Executive Director

Institute of Scrap Recycling Industries, Inc., Washington, D.C., Joseph Pickard, Chief Economist and Director of Commodities

Jade Lee: Data security is an important part of electronics recycling

Data security is an important part of electronics recycling, one that many people overlook, says Jade Lee, president of Supply-Chain Services. She tells the story of a client involved in handling sensitive health data for individuals.

“The client had strict protocols for data security and protecting the information of the data inside its operations,” she said. However, when it came time to dispose of the technology that managed the sensitive data, such vigilance lapsed.

Jade Lee

“The procedure was to set the equipment out on the loading dock for pickup,” she said. Policies for   tracking and documentation of security stopped once equipment had been identified for recycling.

Technology can include multitudes of personally sensitive data in its disks and drives: credit card and bank account information, contact numbers, health data, family histories, in fact nearly everything identity thieves or other criminals could need to steal identities or access to financial data. For corporations, sensitive business information can be left behind that should not be released to the public, for competitive or liability concerns.

Supply-Chain Services, based in Lombard, Ill., firm is a leader in electronics recycling, asset management and other essential services for large companies.  The company holds six certifications relating to recycling and asset management: ISO 9001: Quality Management System, ISO 14001: Environmental Management System, OHSAS 18001: Occupational Health & Safety, National Association for Information Destruction (NAID): Certified on Electronic Data Sanitization and Destruction, R2: EPA’s “Responsible Recycling” standard and RIOS™ the  Recycling Industry Operating Standard® that incorporates the key operational controls for Environment, Health and Safety and Quality, which is also an accredited management system standard   developed for the entire recycling industry.

Lee said she wants her clients and the general public to consider what will happen to their technology assets after it leaves their hands. Even people who bring their electronics into state or manufacturer sponsored electronics recycling programs should consider what happens to their sensitive data after it leaves their possession.

“People do not know, behind the scenes, what happens to their electronics, and that worries me a lot,” says Lee. “You would think data would be taken care of from computers, but it is not.”

Governments who operate electronics recycling programs for their residents should also take care to ask difficult questions of their service providers. They should visit the facilities where electronics will be handled and audit their service providers to ensure data security measures are in place.

For more information on responsible recycling and data security, visit


Clearing up the CRT rules

The proposed changes to rules governing the recycling of Cathode Ray Tubes were a topic of hot conversation in Las Vegas last month.

William Damico, a Region 5 EPA Enforcement Officer, spoke at the recent Institute of Scrap Recycling Industries’ annual Convention and Expo in Las Vegas, hoping to offer the EPA’s viewpoints on the rule and to clear up any confusion on what the government agency is trying to accomplish by revising its regulations.

The electronics recycling industry is currently operating under a CRT rule passed on July 28, 2006.

“There was a misconception that the rule brought the cathode ray and other monitor tube devices in the realm of regulation of hazordous waste,” Damico said. “Actually, they always were. We weren’t very active in enforcing those rules.”

The rule didn’t clearly address many of the realities of exporting CRTs for recycling, Damico said.. A revision by the EPA in 2011 hopes to clarify the government’s position on management of the materials and how the EPA plans to enforce the regulation.

“CRTs are a limited commodity, not going to be with us forever and it’s possible the market will disappear before amount of CRT disappears,” Mark Murray, Californians Against Waste. “It’s not just about CRTs, it’s about other hazardous materials we can use in this way.”

In order for others to utilize those recyclable items, it’s a must for recyclers to dismantle the product before shipping it out of the United States’ borders, Murray said. He noted his organization is supporting barring the trans-state shipping of non-dismantled CRTs for recycling.

“The recycler won’t get paid unless they’ve demonstrated they’ve dismantled the device or demonstrate sending to an approved dismantler.”

If that isn’t done, some recyclers may just hold on to those items for an infinite amount of time and, if enough stack up enough, they might be on the next episode of A&E’s “Hoarders.”

Leaded glass found in the CRTs must be included in the recycling loop, but the markets for the material are drying up. Prices have declined drastically in recent years, said David Cauchy of Closed Loop Recycling.

“It’s a significant change economically,” Cauchy said. “The market hasn’t adjusted to it, in my opinion. It’s a serious issue, when you talk about the tonnage that’s available and the technologies that are available to recycle it. It’s a serious issue in the e-waste industry.”

Cauchi said the CRTs need to be recycled as a whole and not just end up a fodder for a landfill.

“We feel there should be places where CRTs are processed in their entirety and make a profit at that facility so it could compete with landfills,” he said.

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, ISRI says.