Frequent Questions

How are circuit boards regulated under RCRA?

Shredded circuit boards being recycled are excluded from the definition of solid waste when recycled provided they are stored in containers sufficient to prevent a release to the environment prior to recovery and are free of mercury switches, mercury relays, nickel-cadmium batteries, and lithium batteries (40 CFR §261.4(a)(14)). There is no federal rule about when the boards must be shredded, but the wastestream must meet the exclusion criteria before it can take advantage of the exclusion (62 FR 25998, 26011-12; May 12, 1997)

Whole circuit boards may also meet the definition of exempt scrap metal (§261.6(a)(3)(iii)). The scrap metal exemption applies to circuit boards with minimal relays, switches, or batteries when being sent for further use, reuse, or recovery and when provided with protective packaging (63 FR 28629, 28630; May 26, 1998).

In addition, unused circuit boards are typically regulated as commercial chemical products (CCPs). Pursuant to §261.2, CCPs are not solid waste when reclaimed.

The May 12, 1997, Federal Register is available at the following URL: 
www.epa.gov/fedrgstr/EPA-WASTE/index.html

The May 26, 1998, Federal Register is available at the following URL: http://www.epa.gov/epawaste/hazard/tsd/ldr/ldrmetal/ 

Additional clarification on these provisions is provided in the following memoranda: 
Memo, Cotsworth to Isaacs; August 8, 1997 (RCRA Online #14155
Memo, Lowrance to Directors; August 26, 1992 (RCRA Online #11689
Monthly Call Center Report Question; August 1991 (RCRA Online #13490)
Monthly Call Center Report Question; March 1990 (RCRA Online #13356

These memoranda are available in the at the RCRA Online database.

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