Sustainable Materials Management (SMM) Electronics Reuse and Recycling Forum September 23-24, 2014


Sustainable Materials Management (SMM)
Electronics Reuse and Recycling Forum

September 23-24, 2014
Arlington, VA

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Table of Contents

TABLE OF CONTENTS	1

INTRODUCTION	2

EPA Opening Remarks	2

2014 SMM Electronics Challenge Awards and Recognition Ceremony	4

CATHODE RAY TUBE fCRTl DISCUSSION	5

Problem Statement	5

5

Factors	6

Factors Contributing to the Problem	6

Factors Contributing to the Problem	7

Factors Contributing to the Problem	7

End Use Advantages/Challenges	8

CURRENT END-OF-LIFE LANDSCAPE	11

Community Action Areas	11

Top Community Action Area Details	13

CLOSING	18

EPA Closing Remarks	18

Participant Reflections	18

1.	Meeting Participants	19

2.	Ingredients Critical for Success	21

3.	Current State of Electronics End-of-Life Landscape	22

4.	Affinity Area Rankings	25

5.	Ideas for Near Term Actions	25

6.	List of Acronyms	27

Disclaimer:

This document summarizes discussions among various parties and is provided for
informational purposes only. EPA will consider these comments but is not committing to any
course of action. Any mention of product, vendor, or company names or services in this
document does not constitute EPA endorsement.

1

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Introduction

On September 23 and 24, 2014, the U.S. Environmental Protection Agency (EPA) hosted a forum to "harness
the collective power of the electronics community and identify shared priorities that will advance domestic end-
of-life electronics management." More than forty participants took part in this interactive discussion to identify
strengths and issues and brainstorm areas of focus to address the challenges of Cathode Ray Tube (CRT)
stockpiling and end-of-life electronics management.

Participants of the forum represented a cross-section of the electronics community, including:

Original Equipment Manufacturers
(OEMs)

Retailers

Trade Associations
Non-Governmental Organizations
(NGOs)

Standards Certification Bodies
Recyclers/Refurbishers
Academia/Universities
States
EPA





EPA had not hosted the electronics community for this type of "problem-solving" forum in over ten years. This
was a valuable opportunity to collaborate and network with peers, understand the issues from different
perspectives and brainstorm ideas for action.

Appendix 1 contains a list of attendees.

EPA Opening Remarks

The forum began with opening remarks from Lisa Feldt, Acting Deputy Administrator, EPA, and Barnes Johnson,
Director, EPA Office of Resource Conservation and Recovery.

Ms. Feldt acknowledged the importance of stakeholder dialogues, such as this Forum, as a means for the
electronics community to learn from one another and work collectively to address the safe and sustainable
management of used electronics. The last time a similar group was gathered was in 2005. She recognized that
this is a pressing issue and identified accomplishments of the past ten years. She encouraged the group that
whatever progress was to be made would have to happen collaboratively.

Mr. Johnson reaffirmed the significance of this gathering and walked through a brief timeline of events in end-
of-life electronics recycling, which appears on the following page.

2

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Many Changes - Short Span of Time

Consumer Electronics

become popular

Localized Event-based Collection
Programs become Available by
Manufacturers and Retailers

Electronics
Recycling rate is
19% nationwide

1990s

2003

2006

2009 2010

First Electronics
Recycling Law

Passed in California

CRT Regulation is

Finalized and in Force

Recycler Certification

becomes Available

EPEAT Registry Opens -
60 Computer Products
Available

Electronics Programs Expand and Grow

Twenty-four different
State Electronics
Recycling Laws are in

force

2011

National Strategy of

Electronics

Stewardship

Released

SMM Electronics Challenge

Launched; There are 1000's of
permanent collection points
available across the nation.

The number of Certified
Recyclers reaches 600;
Certified recyclers are found
in 44 states and 17
nations.

2012

2013

2014

EPEAT Registry Expands to

Include TV's and Imaging
Equipment

Electronics Recycling

rate for the nation
reaches 29%

There are 1000s of EPEAT
registered products
available

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2014 SMM Electronics Challenge Awards and Recognition Ceremony

A highlight of the forum was the first annual awards and recognition ceremony for the SMM Electronics
Challenge. In 2013, the combined efforts of the SMM Electronics Challenge participants achieved notable
environmental results.

By rethinking business as usual and committing to innovative and responsible end-of-life electronics
management, Electronics Challenge participants collectively:

•	Diverted 221,192 metric tons of end-of-life electronics from the landfill;

•	Sent 220,531 metric tons of end-of-life electronics to third-party certified recyclers; and

•	Avoided more than 41,000 metric tons of carbon dioxide equivalent in 2013 by increasing certified
recycling by 15,588 metric tons, or 7.6 percent since 2012.

This increase is equal to any one of the following:

•	Taking over 8,500 passenger vehicles off of the road for one year;

•	Saving enough energy to power more than 3,700 U.S. homes for one year; or

•	The amount of carbon sequestered annually by more than 33,500 acres of U.S. forest.

The Electronics Challenge offers participants two kinds of awards in recognition of their accomplishments: Tier
and Champion. Tier Awards are given to participants in recognition of achieving all of the requirements under a
Bronze, Silver or Gold Tier. The Tier requirements are the core of the Electronics Challenge, and participants
join at the level that best suits their organization, experience and ability. The second type of awards, the
Champion Award, is offered to those companies that go above and beyond the Tier requirements of the
Electronics Challenge by demonstrating the highest level of vision, coalition building, and execution of programs
and policies related to responsible used electronics management.

The Challenge award winners are listed below. More details are available on the SMM Electronics Challenge
Awards page at: http://www.epa.aov/smm/electronics/2014 ec awrd wnrs.htm

Best Buy Co., Inc

Gold Tier Award

Champion Award, Non-Product Category

Dell, Inc.

Gold Tier Award

Champion Award, Product Category

Sprint

Gold Tier Award

Champion Award, Non-Product Category

Samsung Electronics, USA

Gold Tier Award

Champion Award, Honorable Mention, Non-
Product Category

LG Electronics, USA ~

Gold Tier Award

Panasonic Corporation of North

Gold Tier Award

America



Sony Electronics, Inc.

Bronze Tier Award

Staples, Inc.

Gold Tier Award

4

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Cathode Ray Tube (CRT) Discussion

Problem Statement

The discussion of Cathode Ray Tube (CRT) recycling began with a presentation from EPA on the problem
statement, to which participants responded. The refined problem statement and notes from the ensuing
conversation are below.

CRT Problem Statement:

CRTs and CRT glass were once easily recycled into new CRTs; however, the demand for new CRTs has
collapsed in favor of new flat panel technologies. Because of rising costs, negative economic incentives, and
shifts in CRT glass markets, some CRT processors and recyclers are choosing to store the glass indefinitely
rather than send it for recycling (or disposal), which increases the risk of mismanagement and/or
abandonment of the CRTs.

Group Discussion on Problem Statement

•	There is a financial incentive for entities to get paid to collect CRTs and CRT glass and then not pay to
recycle (or dispose)

•	We should distinguish between CRTs that are being stored and properly managed versus CRTs that are
stored and being poorly managed or CRTs that are abandoned

•	There is still a market for CRTs going to reuse

•	Phosphors are also an issue with CRT recycling

•	There is a significant increase in the number of states who have mandated electronics recycling, while
the CRT market has diminished; this means more supply with a decrease in the demand for CRT glass

•	This is a short-term issue, as less CRTs will be collected in the future

•	Real and perceived liability and risk-management is also contributing to this issue

5

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Factors

In addition to the problem statement, EPA presented the following high-level framework for discussing the CRT
issue, to which participants responded. This refined framework, while not a complete picture of the issue,
served to guide the discussion.

a _

f—UouncPS r~l COLLECTION f\ ELECTRONICS
L_J SOURCES LJ po|NT RECYCLER

M OCMi |

MumofMl Caiecton
GweiwwuO PtcycWn
SC«cr Pragrwm IWtairrs

CERAMICS

GLASS
FURNACES

U»i»Itctriaty/pUtnu to
l«*d from gUst

GLASS TO GLASS/
CRT MANUFACTURING

T CONSUMER
U DISPOSAL

CONCRETE

LEAD
SMELTER

COPPER
SMELTER

CRT
REUSE

RETRIEVABLE
STORAGE

CHEMICAL
EXTRACTION

_ TREATMENT AND

1 DISPOSAL IN LANDFILL

*** (HAZARDOUS OR NON-HAZAWXX/Sl

TteATMENT AND U5£ AS

g ALTERNATIVE DAILY COVER

AT MUNICIPAL 5
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a

~ COLLECTION POINT

Factors Contributing to the Problem

Thousands of collectors are highly fragmented and hard to organize
No standard or requirements for a "collector"

Subsidies and manufacturer payments going to collectors rather than recyclers
Collectors have no solution for CRT glass

Breakdown in contracting/auditing for ensuring proper CRT glass disposition
Recyclers collecting without contracts with manufacturers
"Cherry picking" high-value parts lowers value down the chain
Lack of/varying levels of education about CRT regulation in different states
CRTs are heavy and pose a challenge to ship long-distance
Inconsistency in state programs

Lack of up-to-date information for consumers on which collectors will take CRTs
Hiring of recyclers sometimes leads to funding being split by two recyclers
Lack of rural route density increases cost per unit
Bad actors in the industry misrepresenting "air pounds"

Broken CRTs are harder to recycle

Shipments out of state can't be regulated by original jurisdiction

Use of pounds as basis for performance encourages CRTs to be collected

Ergonomic challenges of managing CRTs—physical wear and tear on people

ELECTRONICS RECYCLERS

Factors Contributing to the Problem

Financial incentive for entities to get paid to receive CRTs and then not pay to recycle (or dispose)

Lack of enforcement of CRT rule by states and EPA
Lack of tracking of CRTs to final disposition
Barriers to entry are low

Lack of awareness about phosphor, silica and lead hazards in the workplace
Certification is not assurance of compliance or responsible recycling

Stewardship organizations represent a monopsony and consolidate the control of contracts by selecting
vendors. This creates lack of competition, which in certain states raises costs. (Note: this has different
perspectives.)

Recyclers aren't charging enough to cover costs for recycling
Too many recyclers are exporting CRTs improperly

Whenever the state manages CRT recycling, it seems issues of mismanagement increase

Lack of knowledge about outlets for recycling CRTs

Lack of engagement of glass manufacturers who made the glass

Lack of adequate closure plans

Ergonomic challenges of managing materials—physical wear and tear on people

Costs are high to switch to new technologies

Lack of clear specs for recycling grade material

Need to ship trailer loads of CRTs/glass in order to be accepted

Thin operating margins, insufficient funds held

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End Use Advantages/Challenges

The following are the notes from the discussion of each known "end use" of CRTs—identifying advantages and

challenges for each.

CERAMICS

• Substitute for raw material

• Would likely require export

• Doesn't require energy to separate

• May not be able to export to non-OECD

lead from glass

countries

• Large global capacity potentially

• Shifts the lead to ceramics, which may

available

create legacy issue

• Proper firing required in order to

minimize exposure

• Needs regulatory certainty/acceptance

• Real capacity unknown

GLASS FURNACES

• Smaller and regional in scale;

• Very few in operation

(Uses

could be co-located with large

• High energy consumption; lifecycle

electricity/plasma to

piles of glass

assessment may be helpful

separate lead from

• Multiple furnaces would lower

• Needs longer timeframes to store glass

glass)

freight costs

• Small capacity

• Lead recovered from CRT glass

• Permitting/regulatory issues

• Disposition of slag

GLASS TO

• There is niche market for CRTs

• New CRTs will eventually need recycling

GLASS/CRT

• CRTs are inexpensive and are

• Lack of engagement with the glass

MANUFACTURING

more robust equipment for

manufacturers in recycling options for

variable power situations

CRTs

• Declining market

CONCRETE

• Huge capacity

• Shifts the lead to concrete products,

• Regional markets

which may create legacy issue

• Whether treatment process adequately

prevents leaching

• Permitting issues

• Potential stigma issues

LEAD/COPPER

• Existing process in operation

• Limited capacity and no growth potential

SMELTER

• Regulated

(Note: Different perspectives on this

• Large capacity (Note: Different

point)

perspectives on this point)

• Lead recovery may not be very efficient

• Disposition of slag

• Air emissions

• Variable commodity prices

• Permitting of new smelters is difficult

• Few smelters in North America accept

CRT glass

• Perception of taking in hazardous waste

• Needs longer term storage of glass

CRT REUSE

• There is niche market for CRTs

• Low demand in US

• CRTs are more robust equipment

• Hard to export; exports can be abused as

for variable power situations

"sham reuse"

• Inexpensive compared to LCDs

• Wiring diagrams are needed to refurbish

• Reused CRTs will eventually need

recycling

RETRIEVABLE

• Avoids irresponsible speculative

• Funding needed/Need to devise a

STORAGE

accumulation

financial structure to account for recovery

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End Use

Advantages

Challenges

• Allows material to be held until
solutions appear

• Quantify the amount of available
feed stock or supply

• May create a legacy issue

• Competes with viable recovery
technologies

• Hazardous waste permit and regulations
may apply

• Seen as a "kick the can down the road"
approach

CHEMICAL
EXTRACTION

• Potentially environmentally friendly

process

• Complete recovery of lead

• Not operational commercially

• Could be expensive

• Potentially slow and time intensive

• Limited capacity

TREATMENT AND
DISPOSAL IN A
LANDFILL

(HAZARDOUS or
NON-HAZAROUS)

• Large capacity likely

• State bans on landfilling CRTs

• Doesn't count toward state recycling
obligations

• Cost

• Not environmentally-friendly

• Potential stigma issues

TREATMENT AND
USE AS
ALTERNATIVE

DAILY COVER

• Large capacity likely

• Doesn't count toward state recycling
obligations

• ADC may be considered a form of
recycling by some, which discourages
other recycling options for CRT glass
(Note: Different perspectives on this
point)

• State approval required for use as ADC

• Potential stigma issues

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CRT Solutions Brainstorm

Having discussed the issues for CRT management, participants then conducted an initial brainstorm of solutions
to be explored in the future. The following solutions were captured during the discussion report-out and on flip
charts.

Potential Community Action Areas Generated from Stakeholder Meeting

• Work with R2 and e-Stewards to ensure compliance with the CRT rule, including speculative
accumulation, as a means of maintaining certification.

• Improve alignment of financial incentives to facilitate actual recycling, versus collection, of CRTs.

• Consistently and effectively enforce CRT rule and other regulations.

• Provide guidance for those engaging in contracts with electronic recyclers to ensure proper downstream
processing of CRT glass.

• Identify available recycling/recovery options and capacity and associated cost.

• Improve awareness of regulations (e.g., training) by states and electronics community.

• Improve tracking of CRTs to ensure proper recycling (or disposal) of glass and to reduce use of "air
pounds" to claim manufacturer credits.

• Grant variances, with performance management conditions (e.g., performance management standards,
financial assurance, payments to receive set aside for capital investment), for longer-term accumulation
of CRT glass by CRT glass processors.

• Conduct/invest in research, development, and lifecycle analyses of technologies to recycle CRT glass.

• Need to coordinate systems-wide approach to the issue.

• Improve consistency in interpretation and application of state law.

• Ensure accountability for mismanaged CRTs.

• Provide incentives for properly managing CRTs and for recycling CRT glass.

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Current End-of-Life Landscape

In order to identify actions that are relevant and realistic, it is important to first assess the current state. For
this reason, much of the discussion at the end of Day 1 and beginning of Day 2 focused on the current state of
end-of-life electronics reuse and recycling.

The following framework was used to guide the current state discussion. Though this framework is not an
attempt to fully capture the complexities and nuances of the entire lifecycle, it provided a constructive starting
point for discussion. It has been modified slightly, based on comments from participants, but still serves to
structure the conversation.

DESIGN

SUPPLY
CHAIN

Original Equipment
Manufacturers (OEMs) Materials
Original Design Parts

Manufacturers (ODMs)

SALE

Retailers
IT Service
Providers

USE

Consumers
Businesses
Institutions
Governments

-+U -t-
sa

COLLECTION

STORAGE

LANDFILL

REFURBISH Whole Units
and REUSE Parts

RECYCLE

RECOVERY

Plastics

Metal

Glass

OTHER

Participants discussed the strengths and issues with each of the three main phases of the lifecycle:
and SUPPLY CHAII ; SALE and USE; and COLLECTION, REFURBISH/REUSE, RECYCLE and
RECOVERY. The notes from this conversation are documented in Appendix 3.

Community Action Areas

Having completed a rigorous discussion of the current state, participants were then able to identify areas for
community action. Because addressing all the issues in the overall lifecycle is such a difficult task, it was
understood that the most effective approach would be to identify areas where participants in the room had the
most interest and energy. These "affinity areas" for community action are listed below, along with clarifying
notes under each main area.

A. Prevent improper management of hazardous materials (e.g., CRTs, mercury bulbs, and
batteries) and encourage best management practices. With new technologies in the
marketplaces comes the introduction of new materials that are potentially toxic to human health and
the environment. For both new and existing technology it is critical for the electronics community to
make strides to improve knowledge of material content and toxicity, enforce existing worker health and
safety regulations, and follow best practices to reduce human and environmental exposure to
potentially toxic materials. Key actions in this area may include, among others:
o Improve regulatory enforcement of existing federal and state laws,
o Establish a dialogue with EPA and States on this issue,
o Consider new permitting at legitimate facilities for long-term storage,
o Establish consistent national policy on variances regarding speculative accumulation.

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o Develop LCD/copier, etc. rule that would address mercury back lighting in the LCD screen and
copier machines (companion to CRT rule).

¦ Research can precede rule development if necessary,
o Create best practices to improve education.

o Create a best practices package to assess workplace exposure and plan for prevention.

Evaluate existing/new strategies for identifying hazardous materials within devices and
components.

o Create best practices for procurement standards that include end-of-life considerations.

B. Improve design for repair, reuse and recycling. Currently, electronics design and end-of-life
management are often seen as independent, rather than interrelated, parts of the electronics lifecycle.
By encouraging electronics designers to leverage the knowledge and experience of the reuse, repair,
and recycling community, we have the opportunity to build a business case for design for repair, reuse
and recycling that would optimize the safe and effective use of materials across the electronics lifecycle.
Key actions in this area may include, among others:

o Convene designers and recyclers/refurbishers and engage OEMs.

o Allow for efficient access to design information and encourage information-sharing across the

value chain (concerning parts, labeling, bill of materials, service manuals, etc.)
o Engage software manufacturers and app stores/developers in a discussion about product design

to prolong the life of electronics,
o Brand a program for recognizing design for recycling/disassembly (similar to Energy Star),
o Create best practices for procurement standards that include end-of-life considerations,
o Create new incentives for manufacturers to support a reuse, repair and recycling.

¦ Consider this as an alternative approach to Extended Producer Responsibility (EPR).

C. Identify best practices for verifying and selecting recyclers and refurbishers that adhere to
responsible end-of-life electronics management processes. Recyclers and refurbishers who do
not adhere to existing laws risk undercutting those that follow laws and that may be certified to one or
more third-party certified recycling standard. By encouraging accountability and enforcement of existing
regulations, we can level the playing field and provide incentives for the use of responsible electronics
recyclers and refurbishers. Key actions in this area may include, among others:

o Create a standardized mass balance/tracking system and method for confirming receipt of end-

of-life electronics equipment,
o Create sample procurement language for obtaining responsible recycling services,
o Compile materials use information,
o Establish quality assessment of certifications.

D. Research is needed to obtain a quantifiable understanding of issues surrounding
electronics recycling.

o Marketing and commercial issues

o Technical issues such as potential exposure experienced in recycling facilities,
o Behavior issues such as drivers for recycling

E. EPA could use its convener role to engage stakeholders on various electronics issues.

o Encourage harmonization of laws (e.g., take back laws).

o Engage retailers on electronics collection and recycling.

o Develop website/document of best practices (benchmarking, state-to-state, etc.).

F. Determine EPA's role and involvement in new laws and policies.

o Data security and locking laws [known as "kill switch"] laws designed to prevent cellphone
theft Second-hand dealer laws

G. Increase the effectiveness of the electronics recycling system at recovering valuable
resources.

o Identify how to recycle future critical materials that will need to be recycled and that aren't
currently.

o Increase the usage intensity prior to recycling (e.g., more reuse, more repair and longer
product use)

H. Perform a comprehensive inventory of laws and regulations relating to electronics reuse
and recycling to create tools and training to aid in compliance and enforcement.

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o Create tools and training to aid in compliance and enforcement
I. Perform an inventory of best practices for innovative business models that encourage
sustainable reuse and recycling.

o Capture financial benefits/business case
o Look at the consumer products sector for examples.

J. Develop a web portal related to used electronics management.

o Develop online, ongoing communication system (similar to EPA's Job Through Recycling (JTR)
initiative.

Top Community Action Area Details

After the initial brainstorm of community action areas, participants voted on the areas they were most
interested in, considering which would provide positive change across the lifecycle and which had the highest
probability of action. The results of the vote are documented in Appendix 4.

Three areas emerged as the top areas for discussion. Participants then looked at these three areas in more
detail, identifying ideas about how the issue could be addressed and who should be involved. The following
are the notes from this discussion.

Area Prevent improper management of hazardous materials and encourage best
management practices.

How to Address the Issue

• Create best practices to improve education.

• Improve regulatory enforcement of existing federal and state laws.

• Establish a dialogue with EPA and States on this issue.

• Establish new permitting at legitimate facilities for long-term storage.

• Develop LCD/copier, etc. rule that would address mercury back lighting in the LCD screen and copier
machines (companion to CRT rule).

o Research can precede rule development if necessary.

• Create a best practices package to assess workplace exposure and provide a plan for prevention.

o Provide guidance concerning lead/mercury and other hazardous materials,
o Evaluate existing/new strategies for identifying hazardous materials within devices and
components.

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• Compose an interpretation letter of how existing rules related to mercury lamps apply to this industry.

• Create a Center of Expertise (incorporating project management)

o Create a white paper to define these issues.

• Leverage studies by National Institute for Occupational Safety and Health (NIOSH) on dangers of
mercury and other hazards.

• Create a consistent national policy on when to grant variances on speculative accumulation, and under
what conditions.

• Create education program on hazardous materials for state agencies, especially about CRTs.

• Gather existing industrial hygiene monitoring from existing LCD teardown operations.

• Convene state enforcement officials to develop best practices for identifying stockpiling issues.

o Engage federal enforcement officials,
o Enforce existing laws and regulation.

Who Should Be Involved
Federal

• Occupational Safety and Health Administration (OSHA))

• National Institute for Occupational Safety and Health (NIOSH)

• US EPA

• National Enforcement Investigation Center (EPA)

• National Safety Council
State

• State enforcement officials

• Environmental health and safety professionals

• Certification programs
Associations and NGOs

• North American Hazardous Materials Management Association (NAHMMA)

• Clean Production Actions group

• Environmental NGOs

• International Electronics Manufacturing Initiative (iNEMI)

• Institute of Electrical and Electronics Engineers (IEEE)

• CHWMEG
Other

• Expertise on new materials being used and hazards (TBD)

• Original Equipment Manufacturers (OEMs)

• Recyclers

• Refurbishers

• Occupational Medical people, Industrial Hygienists and MDs

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Area B: Improve design for repair, reuse and recycling.

How to Address the Issue

• Create a best practices package for design for reuse/recycling to feed into procurement standards.

o Conduct face-to-face workshops.

• Improve information-sharing across the value chain (concerning parts, labeling, bill of materials, service
manuals, etc.).

• Engage software manufacturers and app stores/developers concerning design.

• Brand a program for recognizing design for recycling/disassembly (similar to/within Energy Star).

• Incentivize manufacturers to support a reuse ecosystem and design for recycling/disassembly.

o Consider as an alternative approach to Extended Producer Responsibility.

• Create a Center of Expertise.

• Enable efficient access to design information gleaned from OEMs on how to disassemble products and
identify toxins.

o E.g., Create a central database that would house:

¦ Disassembly procedures for recyclers
Repair manuals for repairers
o Explore social media tools

• Develop metrics on the reparability/durability of products.

• Develop a strategy for removing toxins from products.

• Screen new materials for toxicity concerns.

• Develop strategies for extending battery life and/or replacing batteries.

• Establish objective rating criteria/standard for products.

• Incorporate design for repair, reuse and recycling concepts into CAD software.

• Create a feedback loop between the recycle/refurbish/reuse community and design community during
the design process.

o E.g., Survey Monkey

o Develop a tool to assess economic recyclability of products.

• Explore an open approach to design that allows for unintended future uses (e.g.,
repurposing/upcycling).

• Raise awareness in the design community.

o E.g., Bring designers to the recycling facility.

• Compile information that's useful for materials choices for designers (e.g., EPA could do this).

• Address how to get parts in the repair ecosystem.

Who Should Be Involved
Industry

• Original Equipment Manufacturers (Product Designers, Managers, Warranties, Repairs/Returns,
Packaging)

• Original Design Manufacturers (ODMs)

• Recyclers

• Refurbishers

• Repairers, including individual repair shops and iFixit

• Parts providers/component manufacturers (e.g., AbNet, Arrow Electronics, Inc., Corning, Foxconn)

• Software manufacturers

• App stores (Amazon, Apple, Google, etc.)

• Major design groups (especially IDEO, frog, Lunar)

• Purchasers

• Autodesk (CAD)

Federal

• US EPA

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Associations and NGOs

• Standards organizations

• Universities (Mechanical Engineering and Design)

• Digital Right to Repair Association

• Environmental NGOs

• Electronic Frontier Foundation

• Public Knowledge

• I EC TCI 11 (Re: 62474 Standard)

• Partners for Award/Recognition (e.g. ITI, ISRI, CEA, GEC, iFixit)

• IEEE 1874

Area C: Identify best practices for verifying and selecting recyclers and
refurbishers that adhere to responsible end-of-life electronics
management processes.

How to Address the Issue

• Create a standardized mass balance/tracking system and method for confirming receipt of end-of-life
electronics equipment.

o There is a need for consistency in the mass balance approach.

• Create sample procurement language for obtaining responsible recycling services. Solicit/synthesize
existing contract language for contracting product take-back and recycling services—from private
companies and the federal government.

• Establish a quality assessment of certifications

o Tracking multi-year trends by facility.

o Provide both environmental and worker health and safety best practices for recycling and
handling specific products such as CRT glass, batteries, and mercury containing devices,
o Include more descriptive/prescriptive language around closure plans,
o Include accessible and sufficient financial assurance in the closure plans,
o Ensure consistency across all actors in the certification process,
o Provide better training for auditors regarding state laws (e.g. what is/is not allowed),
o Focus on quality of facilities, not quantity.

• Create a clearinghouse for recycler documentation (e.g., certification, insurance information, and
downstream vendors).

• List refurbishers who are doing the licensing properly.

• Create a "ready for reuse quality" website.

• Communicate with consumers, so they know which recyclers to use.

• Increase accountability to mitigate against recyclers who are not meeting standards.

o Ask recyclers: Why are you doing this? Who are you doing it for?
o Require CEO's signature on transactions,
o Make sure there are funding mechanisms in place.

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Who Should Be Involved

Federal

• US EPA

• National Center for Environmental Research (NCER)

• U.S. General Services Administration (GSA)

• Federal Electronic Stewardship Working Group (FESWG)

Industry

• Microsoft

• Original Equipment Manufacturers

• Refurbishers

• Recyclers

• Purchasers

Associations and NGOs

• Certification Programs

• Environmental NGOs

• Institute of Scrap Recycling Industries (ISRI)

• State Programs

• Compliance Schemes (e.g. MRM)

• Arizona State University (re: tracking)

• Non-Profit/Charity Collectors (e.g. Goodwill, etc.)

• International Association of TV Asset Managers (IAITAM)

• International WEEE organization

• Associations of Surplus Property Managers (State and other)

• Project Management Institute (for project management discipline, incorporated into all three areas)

Other Sector Examples

• Lawyers

• Auditors

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Closing

EPA Closing Remarks

Barnes Johnson, Director, EPA Office of Resource Conservation and Recovery, shared his closing thoughts to the
Forum. He acknowledged the desire to have meetings like this, with diverse stakeholder groups, more
frequently than once a decade. He reminded participants that these conversations will continue, beginning with
EPA-facilitated sessions at the E-Scrap conference in October, 2014. He also remarked on how having EPA's
Acting Deputy Administrator in attendance at the Forum signals the importance to EPA of improving end-of-life
electronics recycling management.

Participant Reflections

In closing, participants were asked to give a short response to the question: "How are you feeling about what
you accomplished leaving the Forum today?" Responses are captured below.

• Pleasantly surprised

• Thorough

• Thank you; maybe have these more than once
every 14 years?

• Good brainstorming

• Well organized, conceptually

• Well-facilitated

• Reaffirmed my view that this group of people
has a common vision; heading in the right
direction

• A lot of alignment of common interests

• Civil and cooperative

• Substantive

• We need to communicate this to a wider
audience: who, what, why, how, etc.

• Nice to see so many EPA representatives here

• Learning through listening

• Amazing thoughts

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APPENDIX

1. Meeting Participants

Consumer Electronics Association (CEA)

Alcorn

Walter

walcornOce.ora

Sprint

Beck

Darren

darren. d. beck@sprint. com

Closed Loop

Benham

Brent

bbenham@clrrusa.com

Novatec

Bolon

Tom

HOBI

Boswell

Craig

cboswell@hobi.com

Pennsylvania Recycling Markets Center

Bylone

Bob

ribl28@psu.edu

PC Builders and Recyclers

Cade

Willie

willie@pcrr.com

Association of State and Territorial Solid
Waste Management Officials (ASTSWMO)

Callahan

Kerry

kerrvc@astswmo.ora

LG Electronics USA, Inc. (Awards)

Cho

Jacob

Best Buy Co., Inc.

Dunn

Tim

Association of State and Territorial Solid
Waste Management Officials (ASTSWMO)

Forbeck

Mike

mforbeck@Da.aov

Information Technology Industry Council (ITI)

Goss

Rick

raoss@mC.ora

Nulife

Greer

Simon

simon@nulifealass.com

Minnesota

Hickle

Garth

aarth. h ickle@state. mn. us

Pennsylvania Recycling Markets Center

Himes

Jack

ilh587@psu.edu

Institute of Scrap Recycling Industries (ISRI)

Home

Scott

ScottHorne@isri.ora

Dell Inc.

Johnson

Beth

elizabeth iohnson@dell.com

US EPA Office of Resource Conservation and
Recovery

Johnson

Barnes

Johnson. Barnes@eDa. aov

LG Electronics USA, Inc.

Kang

Jane

Jane.kana@lae.com

Green-eyed Partners

Keogh

Kelley

kellev@areeneveDartners.com

Sims Recycling Solutions

King

Larry

Larrv.Kina@simsmm.com

US EPA Office of Resource Conservation and
Recovery

Kohler

Amanda

Kohler.Amanda@eDa.aov

Electronics TakeBack Coalition (ETBC)

Kyle

Barbara

bkvle@etakeback.ora

Regency Technologies

Levine

Jim

iimlevine@reaencvtechnoloaies.com

SERI(R2)

Lingelbach

John

linaelbach@r2solutions.ora

National Center for Environmental Research
(NCER)

Linnell

Jason

ilinnell@electronicsrecvclina.ora

Total Reclaim

Lorch

Craig

clorch@totalreclaim.com

The Sustainability Consortium

Mars

Carole

carole.mars@asu.edu

Maryland

Masood

Tariq

taria.masood@marvland.aov

Samsung Electronics

Moss

Mike

mikem@sea.samsuna.com

US EPA Office of Resource Conservation and
Recovery

Naples

Eileen

NaDles.eileen@eDa.aov

Universal Recycling Technologies

Orlowski

Paul

POrlowski@un iversa Irecvclers. com

Cascade Asset Management

Peters

Neil

nmichaud@cascade-assets.com

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Organization

Last

First

US EPA Office of Resource Conservation and
Recovery

Pollard

Karen

Pollard. Karen@eDa.aov

E-Scrap

Powell

Jerry

iDowell@resource-recvclina.com

e-Stewards

Puckett

Jim

iDuckett(a)ban.ora

US EPA Office of Resource Conservation and
Recovery

Resek

Liz

Resek. Elizabeth@eDa.aov

Green Electronics Council

Rifer

Wayne

WRifer@areenelectronicscouncil.ora

Association of State and Territorial Solid
Waste Management Officials (ASTSWMO)

Rodriguez

Dania

daniar@astswmo.ora

Transparent Planet

Roman

Lauren

lroman@transDarentDlanetllc.com

State Electronics Challenge

Rubenstein

Lynn

lynn@nerc.ora

Dell Inc. (Awards)

Sanders

Deborah

Sony Electronics Inc.

Smith

Doug

doualas.smith@am.sony.com

Kuusakoski

Takala

Anssi

anssi.takala@kuusakoski.us

Panasonic Corporation of North America

Thompson

David

thomDsond@us.Danasonic.com

Electronic Recyclers International

Watson

Mike

Mike.watson@electronicrecvclers.com

Best Buy Co., Inc.

Weislow

Scott

scott.weislow@bestbuy.com

iFixit

Wiens

Kyle

kyle@ifixit.com

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2. Ingredients Critical for Success

Upon reflecting on the accomplishments in electronics reuse and recycling to date, participants brainstormed
the key "ingredients"—i.e., community characteristics—that were essential for these accomplishments in the
past. The purpose was to identify anything that needs to be recreated for future efforts to be successful. Below
are the ingredients captured:

Market Incentives

• Development of secondary market

• Viable recycling markets

• Business opportunities for recyclers/refurbishers

• Entrepreneurial ingenuity and risk-taking in the private sector

• Healthy manufacturing sector

o Supply of materials

Stakeholder Participation/Alignment

• Having a shared agreement of "success"

• Awareness of all of the issues

• Having a broad representation in the industry

• Cooperation among parties (OEMs/recyclers, etc.)

• Publicly stated goals to drive accountability

Regulations/Policies

• Regulatory interest and pressure

• Clarity about the contents of the regulations and enforcement

• National/global product policies, including from private sector

• Certification

o Adoption
o Integrity

Drivers/Motivators

• Maintaining company reputation / being exposed / PR risk

• Rigorous academic review and research

Consumer Engagement

• Considering what the consumer wants

• Market-based incentives for consumers

• Increased public awareness and recognition of the need to recycle

• Increase in collection opportunities for consumers

Tools

• Information-sharing on the internet

• Improved or new/emerging technologies that lead to process innovation

• Integration of design through recycling

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3. Current State of Electronics End-of-Life Landscape

Participants discussed the strengths and issues with each major phase of the end-of-life recycling landscape.

SUPPLY CHAIN and DESIGN

Strengths

• Some manufacturers are making progress in reducing toxic materials in products and process—due to
innovation and advances in technology.

• There is excellent design for the Use and Sale phase, but design considerations don't go further down
the supply chain (to the Collection, Refurbish/Reuse, Recycle and Recovery phase).

• Dematerialization of products; there is less material going into products.

• Consumer needs are being met in an efficient/affordable way; there is a large volume of products
flowing through the system.

• Design is increasingly innovative.

• There are pockets of examples where designers redesigning for recycling.

o When this works, there is a very high return on investment, but this fact is not widely
understood.

Issues

• Due to the international nature of the supply chain, parts availability and validation of legitimate reuse
is limited.

• The presence of counterfeit items in the supply chain has a downstream impact on
recycling/reuse/recovery.

• There are not enough controls over small manufacturers (parts makers), so toxic materials may be
incorporated into the products.

o The process itself also may release toxic materials.

• New technologies are bringing new materials (e.g. nano materials) that may have an unknown
downstream effect.

• There is a general lack of information about the material contents of products coming down the supply
chain.

• There is the potential for diminished demand for recycled products in the supply chain.

• There are trends towards non-repairability/replaceability/reprogrammability in the design of products.

• Intellectual property rights—both physical and software-related—create constraints.

o E.g., there is no path for recyclers to unlock/remove the "kill switch" for devices with this
feature.

• Economic recyclability of products is an issue: the costs exceed what can be earned through recycling.

• The historical focus on OEMs to bear the cost is not sustainable over the long-term.

o Note: Consumers and others (e.g. taxpayers) also bear this cost.

• Designers aren't designing to solve the recycling problem.

o There needs to be a business case for this,
o States need to promote this level of engagement.

• There isn't buy-in to the problem from all parts of the supply chain, including consumers.

SALE and USE

Strengths

• Retailers have the connection/ability to talk to consumers; this is the strongest point of connection.

• Retailers can serve as an influencer on the market.

• Selling products as a service creates a captive audience and helps manufacturers get the product back.

o E.g., Set top box providers.

• Retailers are a natural collection point from, a consumer perspective.

o This can also be good for the retailer because it gets customers back in the store.

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• Retailers are subject to sales bans under state laws, which is an effective tool to get manufacturers to
comply with the law.

Issues

• Understanding consumer demand/behavior is difficult and essential for getting other initiatives off the
ground; barriers aren't well understood.

o Retailers who design for recycling aren't necessarily rewarded by the market.

• The "Sale" end of the market is changing rapidly; this makes it difficult to target where to be in the
future.

• There is a stigma that "green products" don't work as well; this needs to be overcome.

• There is a need for additional strong retailers to assist with collection.

• There is no specific fee on the product to go toward recycling.

• There is a perception that recycling should be free.

• There is a need to keep track of all manufacturers, to hold them accountable to state law.

• There are legal barriers to providing incentives for recycling or buy-back (second-hand dealer laws).

• Retailers have the opportunity to get more engaged in the effort.

• Retailers should provide more information to consumers about the environmental impacts of purchase
decisions.

• Retailers should seek consistency in how they contract with recyclers.

• Retailers should aim for consistency between the buyers' understanding/action and a company's
sustainability policies.

COLLECTION, REFURBISH and REUSE, RECYCLE, and RECOVERY

Strengths

• In some instances, communities are effective at collecting material.

• There are many different types of collectors and collection locations.

• Good manufacturers are doing their own audits of recyclers to identify those who are not complying—
rather than relying on certifications.

• Collecting small devices is relatively easy.

• Refurbishing/demanufacturing/pre-processing has very elastic capacity.

• GSA's existing due diligence system for contractors is very thorough and could be leveraged.

Issues

• There is a lack of harmonization between state programs.

• Local collection activity faces challenges; often it's not clear what to do with the material once it's been
collected

• Material collected is very diverse; high volumes are required to realize value.

• There is price volatility of commodities.

o Note: There was discussion that many of these issues are normal business pressures and are
the responsibility of business owners to address.

• There is a general lack of accountability in this phase.

• There is a need for enforcement of laws.

• Electronics recycling requires more education, research and effort on the part of consumers than
traditional recycling.

o Effective efforts are being made to engage consumers within 10 states.

• There is a need for better balance of convenience for collectors and efficiency of collection.

• There is scavenging from collection sites; not all valuable material makes it to the recycler.

• State regulations don't require manufacturer to be responsible for their own product type.

o There is concern for who takes ownership of other product types (e.g., CRTs).

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o There is an inconsistent/imperfect relationship between the weights of products being sold and
products being recycled.

• There is a lack of understanding of the factors that produce the best recovery rate.

• The storage period after the Use stage means that often materials are old and may be less valuable by
the time they get recycled.

• There is a need for a broad consumer education/communications campaign, especially for smaller
products (tablets etc.).

• There is a need for workable second-hand dealer laws (for state and local governments).

• There are recyclers who are not behaving responsibly (stockpiling, ghost pounds, etc.) This behavior
risks putting responsible recyclers out of business.

o There is a temptation to go with lowest price recyclers; there is no way to clearly identify the

responsible recyclers and legitimate markets/prices,
o This is a role for enforcement officials and certification officers to play,
o There is a lot of confusion about what constitutes a legitimate recycler and how to measure and
track this.

o It is unclear what EPA and states can do to address this issue.

• Some state laws put up barriers to reuse.

• Many states have no laws that can be enforced.

• Sensitive data, especially on smaller products, is a consumer concern.

• There is a need for a tracking system to see where materials go.

o How to accurately track is very difficult; this affects certification and enforcement.

• Having so many certified recyclers creates a false sense of security.

o Audits could reduce the risk.

• Rules and regulations often have unintended consequences.

o This community needs a voice.

o E.g., Activation locks ("kill switches") threaten the value of resale,
o E.g., Collectors bear the cost/burden of dealing with metal theft.

• There are health and safety concerns with recycling re: toxic materials.

• Flat screens with mercury bulbs potentially pose a future issue similar to CRTs.

o There are inadequate warnings/information about this issue.

• Precious metals and other valuable materials have low recovery rates.

o There is a role for EPA to convene parties to address these issues,
o Collection is the major part of this, but losses occur across the system.

• Reuse is an integral piece in the overall recycling value chain.

• Many state laws don't reflect the economics of the "compliance market" (vs. free market) and have
difficulty adapting to changes in products and markets.

• There is an increase in demand for information from stakeholders, especially:

o Manufacturers needing information about environmentally sensitive materials,
o Reuse/recyclers needing information for disassembly.

¦ There is a lack of information for recyclers to aid with manual disassembly, which could
make recycling easier and more profitable.

¦ There is currently no system to make it available.

¦ There is currently no central database,
o Recovery of rare earth materials.

OTHER (Cross-Cutting)

Issues

• There are not enough economic incentives to get the pieces in place to address system-wide issues.

• There are challenges with quantifying the problems.

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4. Affinity Area Rankings

A. Prevent improper management of hazardous materials and encourage best management
practices.

B. Improve design for repair, reuse and recycling

C. Identify best practices for verifying and selecting recyclers and refurbishers that adhere to
responsible end-of-life electronics management processes

D. Research is needed to obtain a quantifiable understanding of issues surrounding
electronics recycling

E. EPA could use its convener role to engage stakeholders on various electronics issues.

F. Determine EPA's role and involvement in new laws and policies.

G. Increase the effectiveness of the electronics recycling system at recovering valuable
resources

H. Perform a comprehensive inventory of laws and regulations relating to electronics reuse
and recycling to create tools and training to aid in compliance and enforcement.

I. Perform an inventory of best practices for innovative business models that encourage
sustainable reuse and recycling

J. Develop a web portal related to used electronics management

5. Ideas for Near Term Actions

At the conclusion of the Forum, participants were asked to write down any ideas about "near-term actions" that
could be accomplished in any of the areas discussed. Below are the ideas participants submitted, in their words.

Convene Stakeholders

Host/organize convene meeting/facilitated discussion of OEM designers and
recyclers

Organize/convene meeting of industry stakeholders

Organize/convene meeting of EPA and states to review program successes and
highlights

CRT

EPA should permit long term storage of CRT glass, with conditions, at glass
furnace facilities and possibly other processes that qualify

Convene meeting of EPA and state enforcement officials to discuss CRT rule
enforcement best practices. Include guidance on:

• How to detect stockpiling

• Conditions for issuing variances

Make CRTs a Universal Waste

Cut a my data set on hard drive storage times to hypothesize the effect of size on
storage time

Educate state agencies on CRT rule and problems

Create policies to make speculative accumulation variances more rigorous

CRT education to the states

Enforce existing laws/rules on CRTs

Variance for legitimate stockpiling of cleaned and sorted CRT glass. The US does
have capacity to separate and clean all CRTs generated. Once in this form, a
performance based protocol for stockpiling should enable safe long-term storage.

Use EPA technical knowledge and industry's business knowledge to find a way to
quickly deal with the CRT funnel glass situation. This issue is distracting many
people from focusing on the broader spectrum.

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Category

Comment

Design

Design for Recycling

EPA Actions

EPA Office of Resource Conservation and Recovery should identify what happened
to last set of computers they replaced in their office - it will be a good educational
awareness exercise

EPA promote (or continue to encourage) the use of certified recyclers that are on
the GSA schedule (as a means to demonstrate adequate responsibility and due
diligence and facilitate the contracting process for federal agencies and their IT
contractors to use for the refurbishing and recycling of their assets

Information

Sharing/Communications

Ask manufacturers about existence of service manuals and the current status of
information exchange with independent repairers and recyclers

Finalize creation of supply chain mapping diagram

Authorship/research/creation of an EPA guidance document on collection system
best management practices.

"Develop online ongoing communication system" is pretty easy (although no
interest)

Create an industry glossary of terms. Purpose: to further a common
understanding and facilitate progress

Laws/Regulations

Work to stop any kill switch/lock laws

Perform comprehensive inventory of laws

Engage with other agencies to influence/end kill switch legislation and other anti-
reuse regulations/laws

Participating in the "kill switch" discussion and issuing a position on the potential
environmental impact.

Provide input to the copyright office on cell phone and other device unlocking.
Process starts now - November 5th.

Change kill switch laws that prevent reuse

Kill switch laws that need action - EPA needs to be vocal to other agencies, such
as FCC and Justice to slow down adoption of "kill switch" or "locking laws" that
eliminate reuse of cell phones

Comprehensive inventory of laws and regulations through possibly third party
expert (consultant)

Enforcement. Enforcement. Enforcement. There is no excuse that current laws are
simply not being enforced This would put an end to bad practices in very short
order and eliminate many of the bottom-feeders who are damaging responsible e-
recycling businesses and the health of the industry as a whole.

Select & Verify "Good"
Recyclers/Refurbishers

Assist in creation of National Tracking System

Sample model contract/procurement templates

List of certified recyclers with capabilities

Quality review of certification programs

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6. List of Acronyms

ADC

Alternative Daily Cover

CEA

Consumer Electronics Association

CRT

Cathode Ray Tube

EPA

US Environmental Protection Agency

EPR

Extended Producer Responsibility

FESWG

Federal Electronic Stewardship Working Group

GSA

General Services Administration

IAITAM

International Association of TV Asset Managers

IEEE

Institute of Electrical and Electronics Engineers

iNEMI

International Electronics Manufacturing Initiative

ISRI

Institute of Scrap Recycling Industries Inc

JTR

Job Through Recyling

LCA

Lifecycle assessment

LCD

Liquid-crystal display

NAHMMA

North American Hazardous Materials Management Association

NCER

National Center for Electronics Recycling

NGO

Non-governmental organization

NIOSH

National Institute for Occupational Safety and Health

ODM

Original Design Manufacturer

OECD

Organisation for Economic Co-operation and Development

OEM

Original Equipment Manufacturer

ORCR

Office of Resource Conservation and Recovery

OS HA

Occupational Safety and Health Administration

SMM

Sustainable Materials Management

USITC

United States International Trade Commission

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