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Information for businesses that handle used electronics

There are certain regulations that anyone who collects, stores, transports, recycles or refurbishes electronics must follow, along with best management practices to protect worker health and prevent pollution. These are outlined below, by activity type.

If you are looking for information on how to recycle electronics your business no longer wants, see the DNR publication Managing Used Electronics [PDF]

Overview

Discarded electronics, often called electronic waste (e-waste) or electronic scrap (e-scrap), may include TVs and TV accessories; cell phones; computer monitors; computer processors; and computer accessories. Most electronics contain heavy metals (such as mercury, cadmium and lead) and chemicals (such as flame-retardant polybrominated diphenyl ethers, or PBDEs), that can pose risks to the environment and human health if not properly recycled or disposed of.

Basic regulatory requirements for electronics collection and recycling

To encourage legitimate recycling, the DNR has reduced regulations for individuals and businesses generating, transporting, and consolidating or storing electronics that are destined for recycling or reuse.

Individuals or businesses involved with e-waste processing activities—such as crushing, shredding or reclamation of electronic components—may be subject to full hazardous waste management regulations, including facility licensing. Applicable requirements are very site- and process-specific. State and federal hazardous waste laws set substantial monetary civil penalties as well as criminal penalties for violations. Those processing discarded electronics should contact your regional DNR hazardous waste specialist for more information.

Requirements for related materials

Many electronics contain batteries and light bulbs, which are regulated as universal waste. Learn more about requirements for properly managing these materials:

Many organizations that collect electronics also accept appliances, including those that contain freon. Make sure you or other organizations you work with are following requirements for safe transport and handling of refrigerants.

Optional participation in E-Cycle Wisconsin

Businesses that collect or recycle electronics from Wisconsin households, K-12 public schools or Milwaukee Parental Choice Program schools can choose to participate in E-Cycle Wisconsin and follow its requirements. To learn more, visit the E-Cycle Wisconsin collector and recycler pages. Collectors and recyclers who choose not to participate in this program do not need to register with the DNR.

Collection and transportation

Collecting and transporting electronics from businesses, governments and institutions

If you collect discarded electronics from businesses, governments or institutions and transport them to a site for consolidation and recycling, keep the following in mind.

  • Ensure the electronics are transported to a legitimate recycling facility.
  • Comply with all applicable U.S. Department of Transportation regulations, including proper packaging, marking and labeling; and truck placarding. For more information, call the DOT hotline at 1-800-467-4922.

If you collect discarded electronics from businesses or institutions and transport them to a site for disposal, keep the following in mind.

  • Ensure the electronics are transported to a licensed, permitted or approved hazardous waste management facility.
  • Comply with U.S. Department of Transportation regulations.
  • Obtain a solid or hazardous waste transportation license from the DNR, if required. Contact your regional DNR staff for more information.

Collecting and transporting electronics from households

If you collect and transport discarded electronics from households/residences, keep the following in mind.

  • You are strongly encouraged, but not required, to transport the items to a legitimate recycling facility. These items may not be transported to Wisconsin landfills or incinerators. Make sure residents understand whether or not their items will be recycled.
  • Comply with U.S. Department of Transportation regulations.
  • Handle equipment from home offices the same as electronics from any business.
  • Clean Sweep events (both temporary and permanent household hazardous waste collection facilities) must recycle discarded electronics or properly manage them as hazardous waste.

Additional information

The DNR has created a video showing best management practices for electronics collection sites.

Consolidation and storage

Consolidation and storage of electronics and electronic components

If you store discarded electronics prior to de-manufacturing and/or if you store components of electronics after they have been broken down, you must:

  • Ensure containers of discarded electronics or individual components are structurally sound and compatible with the contents.
  • Label containers to clearly identify the type of material.
  • Store broken or processed cathode ray tubes (CRTs) in a building with a roof, floors and walls or place in a container to minimize releases to the environment.
  • Clean up spills and manage any resulting residues promptly and appropriately.
  • Train employees on proper handling and response to emergencies.
  • Keep records of the length of time the discarded electronics and individual components have been stored on-site. You may store discarded electronics for up to one year for the purpose of consolidating sufficient quantities for economical shipments for recycling or disposal.

Note: if you collect or store more than 5,000 kg. (11,023 lbs.) of certain discarded electronics there may be some additional requirements, such as recordkeeping, personnel training and obtaining an EPA identification number. Contact your regional DNR staff for information on applicable requirements.

Additional information

Processing

Processing discarded electronics and electronic components includes a number of activities, among them disassembly or de-manufacturing and further processing or recycling of the individual electronic components.

Requirements for de-manufacturing and disassembly

De-manufacturing and disassembly mean to manually break down discarded electronics into individual components either for resale or reuse, or for further recycling or processing. Examples are removing and sorting batteries from discarded electronics and removing circuit boards and other individual components.

In general, there are no DNR hazardous waste approvals or licenses required for simple disassembly or de-manufacturing activities. However, DNR has the authority to conduct inspections to ensure that materials are being properly managed.

If you de-manufacture or disassemble discarded electronics:

  • Review the requirements for storing electronics if the materials you work with are stored on your property before or after disassembly.
  • Process within a building with a roof, floor and walls. No activities may be conducted that use temperatures high enough to volatilize lead or other metals from the electronic components.
  • Keep records for at least three years to verify that at least 75 percent of the discarded electronics collected was recycled each year.
  • Make arrangements with any downstream recyclers or commodity markets prior to disassembling discarded electronics—individual recyclers may require that the materials meet certain specifications.
  • Check with Occupational Safety and Health Administration (OSHA) to ensure that you are following all worker safety requirements that apply to your business. For more information call (800) 321-6742.

Requirements for further processing or recycling

Further processing or recycling of electronic components includes the following activities: reclaiming metals from batteries or circuit boards, shredding circuit boards or plastic cases from computers, and reclaiming lead from CRT glass. If you are involved in these types of activities you must, check to see if your facility requires a DNR hazardous waste management facility license.

Processing or recycling activities (other than processing CRT glass or certain battery processing activities) that change the physical or chemical make up of a hazardous electronic component may require a DNR hazardous waste management facility license. If you are involved in this type of recycling activity, contact your DNR regional staff for more information.

If you are processing CRT glass, see the publication Guidance for Safe Management of Cathode Ray Tubes Destined for Recycling [PDF].

Additional information

Last revised: Thursday March 09 2017