Buy-Recycled Series
MISCELLANEOUS PRODUCTS
COMPREHENSIVE
PROCUREMENT
GUIDELINES
M
(MISCELLANEOUS
ore and more procure-
ment officials are
realizing that buying
recycled is an easy, cost-effi-
cient, and earth-friendly alter-
native. Today's products made
from materials recovered for
recycling offer the strength,
durability, and perfor-
mance equivalent to
those made from virgin
materials. That is why
businesses and public
sector buyers across the
country are buying and
using recycled-content
products.
Buying recycled products...
...conserves natural resources
...saves energy
...reduces solid waste
...reduces air and water pollutants
...reduces greenhouse gases
...creates new jobs
SEPA
EPA530-F-07-043
www.epa.gov/osw
October 2007
To make it easier to
buy recycled, the U.S.
Environmental Protec-
tion Agency (EPA) pe-
riodically updates the
Comprehensive Procure-
ment Guidelines (CPG).
Through the CPG, EPA
designates items that
must contain recycled
materials when pur-
chased with appropri-
ated federal funds by
federal, state, and local
agencies, or by govern-
ment contractors. Sever-
al miscellaneous prod-
ucts are among these
items. These are items that do
not correspond to any of the
other seven CPG product cat-
egories. EPA's research shows
that the items designated in the
CPG are of high quality, widely
available, and cost-competitive
with virgin products. EPA also
issues nonregulatory compan-
ion guidance—the Recovered
Materials Advisory Notice
(RMAN)—that recommends
levels of recycled content for
these items.
Why Buy Recycled?
Recycling is more than just
dropping off your cans, bottles,
and newspapers at the curb or
at a local collection facility.
Diverting recyclables from the
waste stream is only the first
of three steps in the recycling
process. The second step oc-
curs when companies use these
recyclables to manufacture new
products. The third step comes
when you purchase products
made from recovered materials.
Buying recycled products re-
sults in many environmental
benefits. It supports local re-
cycling programs by creating
markets for the collected mate-
rials that are processed and used
to manufacture new products.
This creates jobs and helps
strengthen the economy; con-
serves natural resources; saves
energy; and reduces solid waste,
air and water pollutants, and
greenhouse gases that contrib-
ute to global warming.
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What Is CPG?
The Resource Conservation and Re-
covery Act (RCRA) requires procur-
ing agencies to buy recycled-content
products designated by EPA in the CPG. Is-
sued in May 1995, the first CPG designat-
ed 19 new products and incorporated five
previously designated items in eight prod-
uct categories. The first CPG update (CPG
II) was published in November 1997 and
designated an additional 12 items, includ-
ing pallets. A second CPG update (CPG III)
was published in January 2000 and des-
ignated an additional 18 items, including
sorbents, awards and plaques, industrial
drums, mats, manual-grade strapping, and
signage. The third CPG update (CPG IV),
published in April 2004, designated seven
new products, including bike racks and
blasting grit. The fourth CPG update (CPG
V), published in September 2007, desig-
nated one new item and revised another
designation, but did not designate any new
miscellaneous products. For more informa-
tion, visit .
Procuring agencies include all federal agen-
cies, and any state or local government
agencies or government contractors that
use appropriated federal funds to purchase
the designated items. If your agency spends
more than $10,000 per year on a product
designated in the CPG, you are required to
purchase it with the highest recycled-con-
tent level practicable. The CPG also ap-
plies to lease contracts covering designated
items. Executive Order (E.O.) 13423 and the
Federal Acquisition Regulation also call for
an increase in the federal government's use
of recycled-content and environmentally
preferable products.
Once any new items are designated in a
published CPG update, an agency has 1 year
to develop an affirmative procurement pro-
gram (or revise an existing one) to include
these new items. In previous years, agencies
have had to revise their affirmative procure-
ment programs to incorporate buy-recycled
requirements for items such as pallets,
sorbents, awards and plaques, industrial
drums, mats, manual-grade strapping, and
signage. Agencies must have revised their
affirmative procurement programs to in-
clude the new items designated in CPG IV
by April 30, 2005. This effort might have
involved reviewing specifications for these
items and eliminating provisions that pose
barriers to purchasing them with recycled
content (such as aesthetic requirements
unrelated to product performance).
The CPG acknowledges that specific cir-
cumstances might arise that preclude the
purchase of products made with recovered
materials. Your agency may purchase des-
ignated items that do not contain recov-
ered materials if you determine that: 1) the
price of a given designated item made with
recovered materials is unreasonably high;
2) there is inadequate competition (not
enough sources of supply); 3) unusual and
unreasonable delays would result from ob-
taining the item,- or 4) the recycled-content
item does not meet the agency's reasonable
performance specifications.
MISCELLANEOUS PRODUCTS
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How Do I Purchase Recycled-
Content Miscellaneous Products?
EPA issues purchasing guidance in
RMANs, which are designed to make
it as easy as possible to buy the des-
ignated items. The RMANs recommend re-
cycled-content levels to look for when pur-
chasing miscellaneous products, as shown
in the table below. Following the RMANs'
recommended levels will help ensure your
affirmative procurement program and stan-
dards meet the buy-recycled requirements.
The RMANs also provide other purchasing
guidance. Please refer to for more information
on individual products.
Rather than specifying just one level of
recycled content, the RMANs recommend
ranges that reflect actual market condi-
tions. The recommendations are based on
market research identifying recycled-con-
tent products that are commercially avail-
able, are competitively priced, and meet
buyers' quality standards.
Access EPA's online recycled-content prod-
ucts database by going to and selecting "Supplier Database." See
the last section of this resource guide for
other helpful resources.
EPA's Recommended Content Levels for Miscellaneous Products
MISCELLANEOUS
PRODUCT
Awards and Plaques1
Industrial Drums1
Mats1
Pallets1
MATERIAL RECOVERED
Glass
Wood
Paper
Plastic and Plastic/Wood
Composite
Steel2
Plastic High-density
Polyethylene (HDPE)
Fiber (paper)
Rubber
Plastic
Rubber/Plastic Composite
Wood
Plastic
Thermoformed
Paperboard
POST-CONSUMER
RECOVERED
CONTENT
75-100%
40-100%
50-100%
16%
30-100%
100%
75-100%
10-100%
100%
95-100%
100%
25-50%
50%
TOTAL
RECOVERED
CONTENT
100%
100%
95-100%
25-35%
85-100%
100%
MISCELLANEOUS PRODUCTS
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MISCELLANEOUS
PRODUCT
Signage1
Sorbents1
Manual-Grade
Strapping1
MATERIAL RECOVERED
Plastic3
Aluminum
Plastic Sign Posts/Supports3
Steel Sign Posts/Supports4
Paper
Textiles
Plastics
Wood5
Other Organics/
Multimaterials6
Polyester
Polypropylene
Steel4
POST-CONSUMER
RECOVERED
CONTENT
80-100%
25%
80-100%
16%
67%
90-100%
95-100%
50-85%
16%
67%
TOTAL
RECOVERED
CONTENT
25-30%
100%
100%
25-100%
100%
100%
10-40%
25-30%
100%
1 EPAS recommendations do not preclude procuring agencies from purchasing miscellaneous products manufactured using other materials. EPA simply recom-
mends that procuring agencies, when purchasing miscellaneous products designated in the procurement guidelines, purchase these products containing
recovered materials.
2 The recommended recovered materials content levels for steel in this table reflect the fact that the designated item is generally made from steel manufactured
in a Basic Oxygen Furnace (EOF). Steel from the EOF process contains 25-30 percent total recovered steel, of which 16 percent is post-consumer steel.
3 Plastic signs and sign posts are recommended for nonroad applications only, such as, but not limited to, trailway signs in parks and directional/informational
signs in buildings.
4 The recommended recovered materials content level for steel in this table reflects the fact that the designated items can be made from steel manufactured
from either a EOF or an Electric Arc Furnace (EAF). Steel from the EOF process contains 25-30 percent total recovered materials, of which 16 percent is
post-consumer steel. Steel from the EAF process contains a total of 100 percent recovered steel, of which 67 percent is post-consumer.
5 "Wood" includes materials such as sawdust and lumber mill trimmings.
0 Examples of other organics include, but are not limited to, peanut hulls and corn stover. An example of multimaterial sorbents would include, but not be
limited to, polymer and cellulose fiber combination.
7 The recommended recovered materials content levels for steel in this table reflect the fact that the designated item may contain steel manufactured in either
a EOF or an EAF, or a combination of both. Steel from the EOF process contains 25-30 percent total recovered steel, of which 16 percent is post-consumer.
Steel from the EAF process contains 100 percent total recovered steel, of which 67 percent is post-consumer. According to industry sources, blasting grit con-
taining a combination of EOF and EAF steel would contain 25-85 percent total recovered steel, of which 16-67 percent would be post-consumer. Since there
is no way of knowing which type of steel was used in the manufacture of the item, the post-consumer and total recovered material content ranges in this table
encompass the whole range of possibilities, i.e., the use of EAF steel only EOF steel only, or a combination of the two.
MISCELLANEOUS PRODUCTS
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How Can I Get More Information?
T
his resource guide and the following publica-
tions on buying recycled-content products are
available on the Internet.
Information Available
From EPA
The CPG: . This site de-
scribes EPA's effort to facilitate the procurement
of products containing recovered materials,
including information on CPG and RMANs, and
an online database of manufacturers and suppli-
ers of designated items.
EPA CPG Program: . EPA's EPP program encour-
ages and assists federal agencies in purchasing
environmentally preferable products and ser-
vices. The site explains EPA's proposed guiding
principles for including environmental per-
formance in purchasing decision-making, and
includes case studies of successful pilot projects
in both the public and private sectors.
Jobs Through Recycling: .
EPA's Jobs Through Recycling program stimulates
economic growth and recycling market develop-
ment by assisting businesses and supporting a
network of state and regional recycling contacts.
This Web site provides information on financing
and technical assistance for recycling businesses,
as well as other market development tools.
Municipal Solid Waste: .
This site includes information on recycling,
source reduction, and reuse. It contains state
municipal solid waste data and the latest facts
and figures on waste generation and disposal.
WasteWise: . Waste-
Wise is a free, voluntary EPA program through
which organizations eliminate costly municipal
solid waste, beiiefitting their bottom line and the
environment. The program provides hands-on
assistance to members to help them purchase or
manufacture recycled-content products, prevent
waste, and recycle solid waste materials.
Federal Register (FR): and . Notices
promulgating CPG I (60 FR 21370) and RMAN
I (60 FR 21386), May 1, 1995. FR notices
promulgating CPG II (62 FR 60961) and RMAN
II (62 FR 60975), November 13, 1997. FR notices
promulgating CPG III (65 FR 3070) and RMAN
III (65 FR 3082), January 19, 2000. FR notices
promulgating CPG IV (69 FR 24028) and RMAN
IV (69 FR 24039), April 30, 2004. FR notices
promulgating CPG V (72 FR 52475) and RMAN
V (72 FR 52561), September 14, 2007.
Other Government
Sources
U.S. General Services Administration (GSA)
Environmental Products Overview: . GSA offers a variety of
environmental products and services to its federal
customers to assist them in their efforts to com-
ply with procurement responsibilities outlined in
federal environmental laws and regulations. This
overview contains information about environ-
mentally oriented products and services in the
Federal Supply Service Supply System. To access
GSA Advantage!, GSA's Internet-based ordering
system, and order any GSA product, visit .
MISCELLANEOUS PRODUCTS
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Environmental Products Guide: . This
guide is designed to help procurement of-
ficials identify environmentally preferable
products and services. It contains nearly
3,000 items, including many recycled-con-
tent products.
Office of the Federal Environmental Executive
(OFEE): . OFEE's mission is to
advocate, coordinate, and assist environmental
efforts of the federal community in waste preven-
tion, recycling, affirmative procurement of CPG
items, and the acquisition of recycled and envi-
ronmentally preferable products and services.
Greening the Government: A Guide to
Implementing Executive Order 13101:
. This guide
provides detailed information on the require-
ments of E.O. 13101, which established a
process for amending the CPG and issuing
RMANs. E.O. 13101 preceded E.O. 13423
and established many requirements and
definitions that are still in effect. Updated
in February 2001, the E.O. is available from
OFEE at .
Executive Order 13423: Strengthening
Federal Environmental, Energy, and Trans-
portation Management: . Published in January
2007, this Order replaced E.O. 13101 and
requires federal agencies to purchase green
products and services, including recycled
content products, energy- and water-efficient
products, biobased products, and environ-
mentally preferable products and services.
Although E.O. 13423 revoked E.O. 13101,
EPA continues to follow certain procedures
of E.O. 13101 since they are consistent with
the requirements of RCRA 6002(e).
Federal Green Purchasing Program: . The Federal Trade
Commission issued Guides for the Use of Envi-
ronmental Marketing Claims in May 1998.
California Recycled-Content Product Database:
. This site contains
information on reasons to buy recycled-content
products and how to procure them, and pro-
vides access to a database with information on
products, as well as manufacturers, distributors,
reprocessors, mills, and converters across the
country who procure or produce these products.
King County Recycled Product Procurement Pro-
gram: . This
site describes the tools and techniques developed
by King County, Washington, agencies for pur-
chasing recycled products.
Additional Sources
Buy Recycled Business Alliance: . The Alliance includes over 3,200
companies and organizations committed to
increasing their use of recycled-content prod-
ucts and materials in their day-to-day opera-
tions. The Alliance offers educational materi-
als, a quarterly newsletter, and product-specific
guides. Public purchasing entities can join for
free. For more information, contact the Nation-
al Recycling Coalition.
Official Recycled Products Guide: . This
directory lists more than 5,000 manufacturers
and distributors of recycled-content products.
Plastic Lumber Trade Association (PLTA):
. PLTA is a nonprofit
membership organization working to promote
the interests of the recycled plastic lumber
industry. Its work includes collaborating with
ASTM to set industry-wide standards for recy-
cled plastic lumber.
Recycled Plastic Products Source Book: . This booklet lists
more than 1,400 plastic products from approxi-
mately 300 manufacturers, including pallets.
MISCELLANEOUS PRODUCTS
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Product Information—industrial
Drums
• Reusable Industrial Packaging Association:
. This association
represents about 100 container recoiiditioners.
• The Society of the Plastics Industry: . This trade association
represents the fourth largest manufacturing
industry in the United States.
Product Information—Pallets
• National Wooden Pallet and Container Asso-
ciation (NWPCA): . This
international trade association represents manu-
facturers, recyclers, and distributors of pallets,
containers, and reels. NWPCA also developed
the Uniform Standards for Wood Pallets as a
resource for pallet users and suppliers.
• Sustaining Business & Jobs Through Pallet
Repair & Reuse: . This report lists pallet reuse
and recycling operations across the country and
highlights case studies of model reuse programs.
MISCELLANEOUS PRODUCTS
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