E-cycle_Content Page_Information for businesses that handle used electronics

Information for businesses that handle used electronics

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

For a full set of definitions, background information and detailed requirements, see Managing Used Electronics and Components: Requirements for Electronics Collection, Storage, Transportation, Recycling and Reuse .

If you are looking for information on how to recycle electronics your business no longer wants, see the DNR publication Managing Used Electronics: A Guide for Businesses, Institutions, Governments and Nonprofits

New electronics recycling rule

The DNR’s electronics recycling rule took effect July 1, 2023. The rule created requirements for collecting, storing, transporting and processing electronics. Most Wisconsin facilities that dismantle or further process electronics will need a solid waste processing approval and license from the DNR. The rule also clarifies and adds some requirements for E-Cycle Wisconsin participants.

Overview

Used 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.

There are several solid and hazardous waste requirements related to the collection, storage, transportation, recycling or disposal of electronics and components. Requirements are based on the types of electronics and components involved, how they are managed, and who is managing them. For some activities, there are conditional exclusions from hazardous waste regulations and exemptions from solid and hazardous waste licensing requirements.

Wisconsin regulations for electronics collection, transportation and processing changed effective July 2023. Review this page to make sure you are meeting current requirements.

Limitations on electronics disposal

The following electronics are banned from incineration or landfill disposal in Wisconsin under s.287.07(5), Wis. Stats.:

  • TVs;
  • computers (desktops, laptops, netbooks and tablets);
  • video game components that meet the definition of consumer computers;
  • desktop printers (including those that scan, fax and/or copy and 3-D printers);
  • monitors and e-readers;
  • other computer accessories (including keyboards, mice, speakers, external hard drives and flash drives);
  • DVD players, VCRs and other video players (i.e., DVRs);
  • fax machines; and
  • cell phones.

For devices not specifically listed above, disposal requirements depend on who generated the electronics and whether the electronics contain any components regulated as hazardous waste. Households are exempt from hazardous waste requirements and can dispose of electronics other than those listed above in the trash. However, this exemption does not apply once hazardous waste is separated for management at a collection facility regulated under subch. HH of NR 666, Wis. Adm. Code (such as a household hazardous waste collection facility). NR 662.011, Wis. Adm. Code, requires that non-households (e.g., businesses and institutions) determine if their waste is a hazardous waste. This requirement also applies to materials/components derived from electronics that a facility would like to dispose of.

Identifying and managing hazardous components

Nearly all electronics contain hazardous components that must be managed properly to comply with hazardous waste laws. Mismanagement of hazardous components can have serious consequences for the health of workers and the environment.

Hazardous components to be aware of when handling used electronics include the following:

  • Cathode ray tubes, found in TVs and monitors, which contain lead, barium, cadmium and other heavy metals.
  • Circuit boards, found in all electronics, which may contain lead solder, beryllium or other heavy metals.
  • Non-alkaline batteries, found in laptop computers, tablets, cell phones, MP3 players, digital cameras and other portable electronic devices. There are a wide variety of battery chemistries. These batteries typically contain heavy metals, such as cadmium, mercury and nickel. Many battery chemistries, particularly lithium ion, also pose a significant fire risk.
  • Lamps, found in flat-panel displays, including TVs and monitors, scanners and other imaging devices. Fluorescent lamps contain mercury vapor, while other light sources, such as LEDs (light-emitting diodes) may contain heavy metals such as lead or arsenic.
  • Mercury-containing equipment (e.g., electronics containing mercury relays and switches), including some appliances, telecommunications equipment and medical equipment.
  • Antifreeze/coolant (ethylene glycol), found in rear projection TVs.

Several of the components listed above are regulated as universal waste once removed from electronics. Universal waste is a specific subset of widely generated hazardous waste with reduced requirements for collection and management if properly recycled. Items classified as universal waste in Wisconsin include batteries, lamps and mercury-containing equipment. Learn more about requirements for properly managing these materials:

Additional requirements for appliances containing refrigerants

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  or K-12 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. Collectors and recyclers outside of the E-Cycle Wisconsin program must still follow all applicable solid and hazardous waste requirements.

Collection and storage

Requirements for collection and storage of used electronics and components

Individuals or organizations that collect, consolidate or store used electronics destined for reuse or recycling must follow conditions of any solid or hazardous waste exemptions or exclusions to avoid more stringent regulation.

Most sites do not need a hazardous or solid waste storage license for electronics destined for recycling. However, if a facility — such as an electronics processing facility — stores used electronics or components off-site (e.g., not in its main facility), it will likely need a solid waste storage license under NR 502.05, Wis. Adm. Code. Contact the DNR's electronics recycling program with questions.

Requirements for electronics drop-off sites

The DNR regulates public drop-off sites where electronics are hand unloaded from vehicles that have a capacity of one ton or less, under s. NR 502.07 (2), Wis. Adm. Code. To be exempt from needing a solid waste transfer facility license, sites must meet code requirements, including:

  • Containers or packaging material holding electronics must be:
    • adequate to prevent breakage and spills;
    • compatible with the contents; and
    • made of material that will remain structurally sound for the length of time material is stored. For example, a site should not use unprotected cardboard Gaylords to store electronics long-term outdoors, because they will fall apart if soaked by rain or snow.
  • Electronics must be stored in a manner that will prevent damage from weather, theft or vandalism. While this will look different for different sites, it generally means that all sites should store electronics in areas not accessible to the public, store valuable items ln a locked area, and protect electronics from the elements using a building, covered outdoor storage, covered containers or tarping.
  • Ship electronics off-site to a recycler at least once per year and label containers/keep records to demonstrate this.
  • For any part of your site where mechanical equipment (e.g., a forklift) is part of the operation, limit public access to only times when an attendant is on duty.
  • Clearly label the recycling area at your site.
  • Keep the area clean and free of litter.
  • Don’t burn electronics or other solid waste.
  • Provide means to control fires.
  • Maintain all-weather access road and parking.

Requirements for electronics consolidation points or transfer facilities not open to the public

A facility for the transfer of waste electronic devices intended for recycling that is not a public drop-off site does not need a solid waste transfer station license from the DNR if it is operated and maintained in a nuisance-free manner and complies with specific requirements. This may apply to facilities such as retailer distribution centers or facilities that consolidate electronics from public drop-off sites for events but are not open to the public themselves. Requirements are similar to public drop-off sites,

CRT devices, bare CRTs and CRT glass

Under NR 661.0039 and 661.0040, Wis. Adm. Code, if devices containing cathode ray tubes, bare CRTs and CRT glass are destined for specific types of legitimate recycling, they are conditionally excluded from full hazardous waste requirements, including storage licenses, if they meet the requirements of NR 661.0039 and 661.0040 and are not speculatively accumulated. If you have questions about whether a CRT end market qualifies for the exclusion, please contact the DNR's electronics recycling program.

If a site has broken CRTs or CRT glass, NR 661.0039, Wis. Adm. Code, requires that the site:

  • store broken CRTs or CRT glass in a building with roof, walls and floor; or
  • place the CRTs or CRT glass in a leak-proof container constructed, filled and closed to minimize potential for releases (e.g., a trailer sealed by U.S. Department of Transportation standards, or a closed 55-gallon drum). Containers must be labeled “‘Used cathode ray tubes — contains leaded glass” or “Leaded glass from televisions or computers.” AND “Do not mix with other glass materials.’’

Refer to NR 661.0039 to 661.0040 [exit DNR] for more information.

Devices with lithium batteries

There are several best management practices and safety requirements for those collecting and transporting products that contain lithium batteries. If you remove batteries, you also need to ensure compliance with universal waste requirements.

Requirements for transporting used electronics and components

Wisconsin solid waste or hazardous waste transporter licenses are not required if electronics are destined for reuse or recycling and the transporter meets the requirements outlined below. Beyond these requirements, the DNR recommends collectors and transporters work with recyclers and other receiving facilities to make sure electronics are packaged appropriately to minimize breakage and ensure worker safety.

Requirements to qualify for solid waste licensing exemptions

To qualify for the licensing exemption under s. NR 502.06 (2) (ag), Wis. Adm. Code, trucks carrying only waste electronic devices for recycling must meet all the following requirements:

  • Transport electronics to a licensed processing facility or an acceptable location exempt from licensing.
  • Use durable containers that will not cause electronics to spill out.
  • Comply with electronics disposal ban in s. 287.07 (5), Wis. Stats. 
  • Maintain cleanliness of electronics for recycling.
  • Keep records showing recyclable materials were delivered to brokers, processors or end users.

The DNR recommends collectors and transporters work with recyclers and other receiving facilities to make sure electronics are packaged appropriately to minimize breakage and protect worker safety.

Wisconsin electronics processing facilities must notify, in writing, any third-party haulers they contract with of these requirements, both when entering into the contract and annually after that.

CRT devices, bare CRTs and CRT glass

While no solid waste or hazardous waste license is required for transporting CRTs or CRT glass, shipping facilities and transporters should maintain records to show the materials are going to legitimate recycling activities. The DNR also recommends shipping facilities and transporters package intact CRTs to minimize breakage. Broken CRTs/CRT glass must be transported in leak-proof containers labeled “‘Used cathode ray tubes — contains leaded glass” or “Leaded glass from televisions or computers.” AND “Do not mix with other glass materials."

Refer to NR 661.0039 to 661.0041 [exit DNR] for more information.

Batteries, lamps and mercury-containing equipment

Some types of batteries contained in electronics present a fire risk, especially if damaged. The U.S. Department of Transportation has specific requirements for transporting lithium batteries and devices containing lithium batteries.

In addition, universal waste requirements apply to loose batteries, lamps and mercury-containing equipment, including electronics with mercury switches, relays or other mercury components.

Additional requirements for appliances containing refrigerants

If transporting appliances that contain freon, make sure you or other organizations you work with are following requirements for safe transport and handling of refrigerants. Anyone hauling appliances that are to be salvaged and still may contain refrigerants must annually certify to the DNR.

Hazardous materials transportation

In addition to specific battery-related requirements mentioned above, transporters should be aware of general requirements for transporting hazardous materials. Hazardous materials are substances or materials that the U.S. DOT has determined can pose an unreasonable risk to health, safety and property when transported in commerce. Hazardous material, as defined in 49 CFR 171.8, is subject to the applicable Hazardous Materials Regulations (HMR) in 49 CFR Parts 171 to 180. Those regulations apply to the classification, packaging, hazard communication, incident reporting, handling and transportation of hazardous materials.

Dismantling, sorting and other processing

Requirements for processing used electronics and components

Processing electronic devices for use in manufacturing or for recovery of usable materials is  a type of solid waste processing. Wisconsin facilities that process electronic devices or components derived from electronic devices by disassembling, baling, crushing, grinding, shredding or similar methods must obtain a solid waste processing approval and license from the DNR under s. NR 502.08, Wis. Adm. Code, unless it meets one of the limited exemptions.

A facility must renew its processing license each year. There is no fee for the plan review or license.

Activities that do not meet the definition of electronics processing and do not require a license include:

  • Reuse, repair, or any other process through which an electronic device is returned for use in its original form.
  • Removal of an electronic device from another device, such as from a major appliance or motor vehicle.
  • Hand disassembly of an electronic device in an educational setting for educational purposes.
  • Hand disassembly of a waste electronic device generated by a household on the property where it is generated.

If you are handling and/or processing CRT glass, refer to chs. NR 661.0039 to 661.0041, Wis. Adm. Code [exit DNR].

How to apply for a DNR electronics processing facility approval and license

Please contact the DNR if you believe you need an electronics processing approval and license. DNR staff will walk you through the process and required documents.

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