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Material Classification: Hazardous or Universal Waste

Many of the components in discarded electronics contain toxic constituents. An average desktop computer (monitor, central processing unit and accessories) is made up of many different heavy metals and plastics. These include lead, mercury, antimony, silver, chromium, zinc, tin, copper, iron, aluminum, nickel, cobalt and lithium. The following table provides a component-based breakdown for various electronic products. These toxic materials can cause kidney, cardiovascular and central nervous system damage. US EPA estimates that currently half of all heavy metals found in U.S. landfills can be traced to discarded electronics.

(In percent of total generation)

Type of Consumer Electronics


Copper & Brass



Other Metals





Video Products










Audio Products










Information Products (computers, etc.)




















 *Source: Municipal Solid Waste in the United States: 2000 Facts and Figures. US EPA Office of Solid Waste and Emergency Response. June 2002, Pages 150-160.

Some electronics such as computer monitors, color TV tubes, and smaller items such as cell phones and other hand-held devices test “hazardous” under Federal law. If so, they are subject to special handling requirements under Federal law, but may be subject to certain exemptions. To facilitate more reuse and recycling of these products, EPA has less stringent management requirements for products bound for reuse and recycling.

Computer monitors and televisions sent for continued use (i.e., resale or donation) are not considered hazardous wastes.

EPA also encourages recycling of CRTs. Thus, CRTs sent for recycling are subject to streamlined handling requirements and, under certain conditions, are classified as Universal Waste. This is similar to rules governing the management of used florescent light tubes and lamp ballast.

The following information also appears in the Comprehensive Program for the Proper Handling of Covered Electronic Devices.pdf 

Many electronics, including CRT (cathode ray tubes) computer monitors, CRT TVs, and smaller items such as cell phones test “hazardous” under Federal law. As a result, they are subject to special handling requirements. At the same time, under certain circumstances, they may also be subject to exemptions. For example, computer monitors and televisions sent for continued use (i.e., resale or donation) or recycling are classified as Universal Waste and as such, are not considered to be hazardous wastes.

This situation was created under Federal Rule, 40 CFR Parts 9, 260, 261, et al, Cathode Ray Tubes, Final Rule, which streamlines management requirements for recycling of used CRTs and glass removed from CRTs under the Resource Conservation and Recovery Act (RCRA). The rule excludes these materials from the RCRA definition of solid waste if certain conditions are met. This is intended to encourage recycling and reuse of used CRTs and CRT glass.

Regulation of Circuit Boards: According to the US EPA, circuit boards are subject to a special exemption from Federal hazardous waste rules.

  • Whole unused circuit boards are considered unused commercial chemical products, which are unregulated.

  • Whole used circuit boards meet the definition of spent materials but also meet the definition of scrap metal. Therefore, whole used circuit boards that are recycled are exempt from the hazardous waste regulations.

  • Shredded circuit boards are excluded from the definition of solid waste if they are containerized (i.e., fiberpaks) prior to recovery. These shredded circuit boards cannot contain mercury switches, mercury relays, nickel cadmium batteries, or lithium batteries. If these materials are not treated this way, then they are considered hazardous waste and must be treated as such.

Mercury can be found in small quantities in batteries, backlights of LCD screens, switches and printed circuit boards. Mercury containing equipment was added to the list of items identified as Universal Waste (40 CFR Parts 9, 260, 261, et al) under RCRA, on August 5, 2005 and may be subject to special handling but are generally not considered to be hazardous waste if they are to be reused or recycled.

Wastes from facilities that generate over 100 kilograms (about 220 pounds) per month of hazardous waste are regulated under Federal law when the waste is disposed. CRTs from such facilities sent for disposal (as opposed to reuse, refurbishment or recycling) must be manifested and sent as “hazardous waste” to a permitted hazardous waste landfill.

Businesses and other organizations that send items for disposal (as opposed to reuse, refurbishment or recycling) less than 100 kilograms (about 220 pounds) per month of hazardous waste are not required to handle this material as hazardous waste. If a “small quantity generator” wishes to dispose of a small quantity of CRTs or other used electronics that test hazardous under Federal law, these materials can go to any disposal facility authorized to receive solid waste (e.g., a municipal landfill), unless state law requires more stringent management (e.g., West Virginia’s passage of SB 398 banning covered electronics from disposal in landfills after January 1, 2011).

Used computer monitors or televisions generated by households are not considered hazardous waste and are not regulated under Federal regulations. State laws may be more stringent in regards to electronics from households (e.g., WV SB 398).


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For information on SB 398 and the landfill ban on electronics, stakeholders meetings and general information on e-waste planning and e-Cycling:

Carol Throckmorton

304-926-0448, e 1671
Nicole Hunter
304-926-0448, e 1116
For information on the Covered Electronic Devices Grant program, manufacture registration and compliance,  and general information on e-Cycling:
Niki Davis
304-926-0499, e 1137
Lisa Facemyer

WV Solid Waste Management Board
601 57th Street, SE
Charleston, WV 25304
Phone: 304-926-0448
Fax: 304-926-0472
Toll Free: 866-568-6649