A case study in regulatory approaches to CRT recycling

The electronics industry is under strong and increasing pressure from governments, environmental groups and the public to increase the recycling of its products. Manufacturers and recyclers are analyzing dozens of approaches to identify cost-effective, environmentally sound methods of managing end-of-life electronics. An important aspect of these analyses is the identification ofthe environmental regulations-particularly those under the Federal Resource Conservation and Recovery Act (RCRA) and its state counterparts-that would apply. Regulatory costs, burdens and risks are particularly important because companies may be unwilling to invest in a heavily regulated enterprise when the value of some of the recycling streams is relatively low and markets for such materials are still developing. The applicability of hazardous waste regulations to particular electronics components, the onerous and inconsistent requirements potentially imposed by such regulations, and reform proposals that would encourage rather than impede electronics recycling have been debated for years. Nevertheless, companies still face a patchwork of different approaches that make it difficult to accomplish their objectives in an economical manner, free from the threat that regulators will assert violations of hazardous waste requirements.