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
The DNR is developing rules to codify and clarify policies related to the E-cycle Wisconsin program and define requirements for Wisconsin electronics processing facilities. The DNR is accepting public comments on the draft rule through July 7 and has schedule a public hearing on the drfat rule for June 28 at 1 p.m. CDT via Zoom. Refer to the hearing notice below for a Zoom link and other hearing information
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 reduced solid and hazardous waste requirements if used electronics and their components are reused or recycled. The reduced requirements are based on the types of electronics and components involved, how they are managed, and who is managing them. The reduced requirements may include conditional exclusions from hazardous waste regulation and exemptions from solid and hazardous waste licensing requirements. Used electronics and components that are not managed properly and do not meet any of the exclusions or exemptions are regulated more stringently.
Limitations on electronics disposal
The following electronics are banned from incineration or landfill disposal in Wisconsin under s.287.07(5), Wis. Stats.:
- computers (desktops, laptops, netbooks and tablets);
- 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 (CRTs), 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, mercury-containing equipment and antifreeze. 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, K-12 public schools or 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. 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. Below are more details on specific requirements for devices containing cathode ray tubes (CRTs), bare CRTs and CRT glass; and batteries and devices with lithium batteries.
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.
CRT devices, bare CRTs and CRT glass
Under NR 661.39 and 661.40, Wis. Adm. Code, if CRT devices, 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 661.39 and 661.40 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 661.39, 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.’’
See NR 661.39 to 661.40 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.
- Management of universal waste in Wisconsin
- Call2Recycle battery safety information and training resources
- U.S. Department of Transportation information on safe battery transportation requirements
Best management practices for collection and storage
The DNR also recommends best management practices to ensure electronics and components remain recyclable and therefore avoid more stringent requirements, including all of the following:
- Protect electronics from the elements as much as possible — store indoors or in covered containers or move off-site frequently if stored outdoors.
- Minimize breakage and must follow requirements for broken CRT glass if breakage occurs.
- Move electronics off-site to a recycler regularly and follow packaging guidelines to protect electronics during transportation.
- Design security procedures to protect personal and confidential data stored on devices.
- Whenever possible, have a written contract with your recycler, and always maintain documentation confirming the electronics will be recycled or reused.
For more information on these and other best management practices, refer to:
- Collector Best Management Practices: Electronic Waste
- Collector Best Management Practices: Universal Waste and Used Oil
- Collection event tips
The DNR has created a video showing best management practices for electronics collection sites.
Requirements for transporting used electronics and components
No Wisconsin solid waste or hazardous waste transporter licenses are required if electronics are destined for reuse or recycling. However, specific labeling and packaging requirements apply for all of the following:
- CRT devices, bare CRTs and CRT glass;
- devices containing lithium batteries;
- universal wastes, such as lamps and batteries that have been collected separately from or removed from electronics; and
- appliances that contain refrigerants.
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.
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."
See NR 661.39 to 661.41 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. Department of Transportation 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 dismantling and sorting used electronics and components
Most simple dismantling, sorting, shredding and baling of used electronics for recycling is exempt from full hazardous waste requirements, if items like CRTs, circuit boards, batteries, lamps and mercury-containing components are properly managed.
If you dismantle discarded electronics, the DNR recommends the following:
- Review the requirements for storing electronics if the materials you work with are stored on your property before or after disassembly. There are specific requirements for items like CRTs, batteries and lamps.
- Keep records for at least three years to verify that electronics and components were legitimately recycled.
- Make arrangements with any downstream recyclers or commodity markets prior to dismantling discarded electronics — individual recyclers may require that the materials meet certain specifications.
- Check with Occupational Safety and Health Administration to ensure you are following all worker safety requirements that apply to your business. For more information, call (800) 321-6742.
Requirements for further processing of electronics and components
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 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 waste management facility license. If you are involved in this type of recycling activity, contact the DNR's electronics recycling program for more information.
If you are handling and/or processing CRT glass, see chs. NR 661.39 to 661.41, Wis. Adm. Code .