United States Solid Waste EPA530-F-00-0'\7
Environmental Protection and Emergency Response April 2000
Agency (5306W) www.epa.gov/cpg
<>EPA Environmental
Fact Sheet
EPA EXPANDS COMPREHENSIVE
PROCUREMENT GUIDELINE (CPG)
As part of its continuing program to promote the use of recovered materials, the U.S. Environmental Protection
Agency (EPA) is expanding the federal buy-recycled program by adding 18 new items to its Comprehensive
Procurement Guideline (CPG). This brings to 54 the number of recycled-content products designated for a purchasing
preference under the CPG. EPA originally issued the CPG and the non-regulatory Recovered Materials Advisory Notice
(RMAN) in May 1995. RMANs provide purchasing recommendations and guidance for the products designated in the
CPG and are updated periodically to reflect market conditions.
In November 1997, EPA updated the original CPG with the publication of CPG II and RMAN H covering an addi-
tional 12 items. In January 2000, EPA issued CPG HI and RMAN IE, covering 18 new items. Updated RMANs for
paper and paper products were published in May 1996 and June 1998. See page 4 of this fact sheet for all pertinent
Federal Register citations.
The CPG designates items in the following eight product categories: paper and paper products, vehicular products,
construction products, transportation products, park and recreation products, landscaping products, nonpaper office prod-
ucts, and miscellaneous products.
Why Did EPA Publish the CPG and RMANs?
To encourage the use of materials recovered through recycling, and thereby help to reduce the amount of waste that
must be disposed of, Congress directed government agencies to increase their purchases of recycled-content products.
Section 6002 of the Resource Conservation and Recovery Act (RCRA) requires EPA to designate products that can be
made with recovered materials and to recommend practices for buying tljese products. Once a product is designated,
procuring agencies are required to purchase it with the highest recovered material content level practicable. President
Clinton reinforced RCRA's buy-recycled requirements when he issued Executive Order (EO) 13101 in September 1998.
Who Is Required to Buy Recycled Products?
Under RCRA, the requirement to purchase an EPA-designated product containing recovered materials applies to
"procuring agencies" that spend more than $10,000 a year on that item. Procuring agencies include all federal agencies,
and any state or local agency or government contractor that uses appropriated federal funds. For example, if a county
agency spends more than $10,000 a year on an EPA-designated item, and part of that money is from appropriated federal
funds, then the agency must purchase that item made from recovered materials.
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CPG Categories and Designated Items
(Items in bold were designated in CPG III)
Paper and Paper Products
Vehicular Products
Engine Coolants
Re-refined Lubricating Oils
Retread Tires
Construction products
Building Insulation Products
Carpet
Carpet Cushion
Cement and Concrete Containing Coal Fly Ash
Cement and Concrete Containing Ground
Granulated Blast Furnace Slag
Consolidated and Reprocessed Latex Paint
Floor Tiles
Flowable Fill
Laminated Paperboard
Patio Blocks
Railroad Grade Crossing Surfaces
Shower and Restroom Dividers and Partitions
Structural Fiberboard
Transportation Products
Channelizers
Delineators
Flexible Delineators
Parking Stops
Traffic Barricades
Traffic Cones
Park and Recreation Products
Park Benches and Picnic Tables
Plastic Fencing
Playground Equipment
Playground Surfaces
Running Tracks
Landscaping Products
Food Waste Compost
Garden and Soaker Hoses
Hydraulic Mulch
Lawn and Garden Edging
Plastic Lumber Landscaping Timbers and Posts
Yard Trimmings Compost
Nonpaper Office Products
Binders (plastic covered, chipboard, and pressboard)
Office Recycling Containers
Office Waste Receptacles
Solid Plastic Binders
Plastic Clipboards
Plastic File Folders
Plastic Clip Portfolios
Plastic Presentation Folders
Plastic Desktop Accessories
Plastic Envelopes
Plastic Trash Bags
Printer Ribbons
Toner Cartridges
Miscellaneous Products
Awards and Plaques
Industrial Drums
Manual-Grade Strapping
Mats
Pallets
Signage
Sorbents
Affirmative Procurement Program
Affirmative procurement—or buying recycled— is an agency's strategy for maximizing its purchases of EPA-
designated items. The affirmative procurement program should also ensure that designated items purchased are com-
posed of as much recovered materials as possible. Programs should be flexible enough to incorporate newly designated
items, and must consist of the following components:
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• A recovered materials preference program.
• An agency promotion program.
• A program for requiring vendors to reasonably estimate, certify, and verify the recovered materials contentof
their products.
• A program to monitor and annually review the effectiveness of the affirmative procurement program.
Additionally, within one year following EPA designation of an item, procuring agencies must revise their specifica-
tions to require the use of recovered materials to the maximum extent possible without jeopardizing the intended end use
of the item.
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The May 1995 RMAN provides general guidance for developing affirmative procurement programs. In addition,
technical background documents and supporting analyses to each CPG update include detailed guidance on establishing
affirmative procurement programs. See page 3 of this fact sheet for infprmation on accessing these and other helpful
resources. '
Preference Program
A preference program is the system by which an agency implements its stated preference for purchasing products
containing recovered materials. RCRA identifies three options for preference programs:
• Minimum Content Standards specify the minimum amount of recovered materials that designated items should
contain. EPA recommends ranges of recovered materials content that are currently available, and procuring agen-
cies should establish their own standards based on these ranges.
• Case-by-Case Policy Development is used when a procuring agency determines that minimum content standards
are inappropriate for a specific procurement action. This option allows the procuring agency to establish a sepa-
rate recovered materials content requirement for the specific procurement action, while still enabling the agency to
procure the designated product with the highest amount of recovered materials practicable.
• Substantially Equivalent Approaches, such as establishing service contracts for product remanufacturing, are
used when minimum content standards are inappropriate. For example, procuring agencies may establish service
contracts for remanufacturing toner cartridges.
Promotion Program
Agencies must actively advertise their desire to buy recycled content products, both within their organizations and to
product vendors. Internal promotion usually is a broad-based employee education and outreach program that affirms an
agency's procurement policy through advertising, workshops, agency newsletters, and technical and staff manuals.
Examples of external promotion to suppliers include publishing articles in trade journals, participating in vendor shows or
trade fairs, placing statements in bid solicitations, and discussing an agency's procurement policy at bidders' conferences.
Estimation, Certification, Verification, and Monitoring
Agencies should use standard contract provisions to estimate, certify, and, where appropriate, reasonably verify the
recovered materials content in a product procured by an agency. Programs also must be monitored and tracked to ensure
that they are fulfilling their requirements to purchase items composed of recovered materials.
May an Agency Purchase CPG Items That Do Not Contain Recovered Materials?
Agencies may elect not to purchase designated items containing recovered materials when the cost is unreasonable-
inadequate competition exists; items are not available within a reasonable period of time; or items do not meet reason-
able performance specifications. Sections 402(c) and 502(c) of EO 13101 require agencies to provide written justifica-
tion for non-compliant procurements.
Does the Federal Acquisition Regulation (FAR) Address Purchasing of Products
Designated in the CPG?
Under RCRA section 6002, purchasing of EPA-designated items must be consistent with other federal procurement
requirements. The FAR is the primary regulation used by federal executive agencies in their acquisition of supplies and
services. On August 22, 1997, a final rule was published in .the Federal Register (62 FR 44809) amending the FAR to
reflect the federal government's preference for the acquisition of environmentally sound and energy-efficient products
and services and to incorporate the requirements of RCRA section 6002. The FAR revisions include solicitation provi-
sions, clauses for obtaining certifications and estimates of recovered materials content from contractors, and a require-
ment that agencies establish an affirmative procurement program for EPA-designated items. The FAR can be accessed
electronically at ; then select the section that includes Part 23.
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Are Items Designated in the CPG Environmentally Preferable Products?
EO 13101 directs federal agencies to identify and purchase environmentally preferable products, which are products
that have a lesser or reduced effect on human health and the environment when compared to other products and services
that serve the same purpose. Items listed in the CPG are designated based on recycled content, whereas the criteria for
environmentally preferable products include multiple attributes such as energy use; conservation of resources; impacts on
air, water, and land; and use of toxic or hazardous constituents.
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For More Information
This fact sheet and other documents on the CPG program are available on the Internet at . CPG
documents and copies of Federal Register notices are also available via e-mail from the RCRA Information Center.
Address e-mails to: rcra-docket@epamail.epa.gov. Include the requestor's name and mailing address on all orders.
» i. ' . • i
For additional information or to order paper copies of CPG documents, call the RCRA Hotline and reference the
EPA document number indicated in the table below. Callers within the Washington Metropolitan Area must dial 703-
412-9810 or TDD 703-412-3323 (hearing impaired). Long-distance callers may call 1-800-424-9346 or TDD 1-800-553-
7672. The RCRA Hotline operates weekdays, 9:00 a.m. to 6:00 p.m., est.
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Federal Register notices can also be found at . Search by specific day, by key-
words, or by accessing the Government Printing Office database.
Key CPG/RMAN Federal Register (FR) Notices
Title/Subject
CPG I
RMANI
RMAN I Clarification on Floor Tile,
Structural Fiberboard, and Laminated
Paperboard Recommendations
RMAN I Update on Polyester Carpet and
Plastic Batt Building Insulation
CPG II
RMAN II
CPGHI
RMANHI
Paper Products RMAN I
Paper Products RMAN n
Procedures for Submission of Recycled
Content Product Information to EPA
Publication Date
May 1, 1995
May 1, 1995
November 12, 1996
June 8, 1998
November 13, 1997
November 13, 1997
January 19, 2000
January 19, 2000
May 29, 1996
June 8, 1998
September 20, 1995
FR Citation
60 FR 21370
60 FR 21386
61 FR 58067
63 FR 31217
62 FR 60961
62 FR 60975
65 FR 3082
65 FR 3070
60 FR 26986
63 FR 3 1214
60 FR 48714
EPA Document Number
EPA530-Z-95-006
EPA530-Z-95-007
N/A
EPA530-Z-98-002
EPA530-Z-97-009
EPA530-Z-97-010
N/A
N/A
EPA530-Z-96-005
EPA530-Z-98-003
N/A
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