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Frequent Questions About the Regulation of Used Cathode Ray Tubes (CRTs) and CRT Glass

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Frequent Questions

EPA prepared the below set of frequent questions to help ensure compliance with CRT regulations. To view answers, simply click on the questions below. Many of the answers include links to the Code of Federal Regulations (CFR) and various Federal Register notices (FR).

 
  • 1. How does U.S. EPA regulate recycling of used CRTs and CRT glass under the RCRA hazardous waste regulations?

    Under the CRT exclusion (also known as the “CRT rule”), used CRTs and CRT glass being recycled that meet the requirements of the exclusion are conditionally excluded from the hazardous waste regulations. As long as the used CRTs and CRT glass meet the requirements of this exclusion, they are not considered solid or hazardous waste under the Resource Conservation and Recovery Act (RCRA). See Title 40 of the CFR in section 261.4(a)(22) for more information.

    Please note that the CRT exclusion applies only in RCRA-authorized states that have adopted the exclusion and states where EPA administers the RCRA program. In addition, state agencies may have more stringent requirements than the federal government, so it is important to also check your specific state regulations. Facilities handling CRTs also may be subject to other federal and state laws and regulations, including those covering worker safety and transportation.

  • 2. Which materials are covered by the CRT exclusion?

    The CRT exclusion covers three different types of CRT materials:

    • used, intact CRTs - CRTs whose vacuum has not been released.
    • used, broken CRTs - CRT glass removed from the CRT housing or casing whose vacuum has been released. This category includes unprocessed CRT glass
    • processed CRT glass – CRT glass that has been sorted in preparation for recycling.

    Under the CRT exclusion, different requirements apply to different categories of CRT materials.

  • 3. What export requirements apply to CRTs and CRT glass?

    Used, intact CRTs sent for reuse are subject to an export notification requirement (40 CFR section 261.41). Exporters must send the notification to EPA’s Office of Enforcement and Compliance Assurance. The notice may cover exports occurring during a 12-month or lesser period and must include address and contact information about the exporter and foreign destination facilities, a description of the manner in which the CRTs will be reused, the planned frequency of export shipments, means of transport, total quantity of CRTs proposed to be shipped over the export period, and information about any transit countries. The exporters must keep copies of normal business records demonstrating that each shipment of exported CRTs will be reused. Exporters must retain records for three years. If the documents are written in a language other than English, CRT exporters of used, intact CRTs sent for reuse must provide both the original, non-English version of the normal business records as well as a third-party translation of the normal business records into English within 30 days upon request by EPA. For more information, see EPA’s website on export requirements for CRTs.

    Used CRTs (either intact or broken) exported for recycling are subject to export notice and consent requirements (See 40 CFR section 261.40 and 40 CFR section 261.39(a)(5) respectively). Exporters must send the export notice to EPA’s Office of Enforcement and Compliance Assurance at least 60 days prior to export. The notice may cover exports occurring during a 12-month or lesser period, and must include address and contact information about the exporter and foreign recyclers, a description of the recycling, the planned frequency of export shipments, means of transport, total quantity of CRTs proposed to be shipped over the export period, and information about any transit countries. Exporters shipping used CRTs for recycling under the CRT exclusion are prohibited from shipping until they have received an EPA Acknowledgement of Consent (AOC) letter documenting the consent EPA has received from the country of import and any transit countries. A copy of the AOC letter must accompany each export shipment. If a shipment cannot be delivered to the recycler listed in the notice for any reason, the exporter must notify EPA of the need to change the destination recycler and obtain consent prior to shipping to a different recycler. CRT exporters must file with EPA no later than March 1 of each year, an annual report summarizing the quantities (in kilograms), frequency of shipment, and ultimate destination(s) (i.e., the facility or facilities where the recycling occurs) of all used CRTs exported during the previous calendar year. Exporters must keep copies of each annual report for a period of at least three years from the due date of the report. For more information, see EPA’s website on export requirements for CRTs.

    Processed CRT glass exported for CRT glass making or lead smelting is not subject to the export requirements of the CRT exclusion. CRT glass destined for export must still, however, meet the requirements for processed CRT glass in 40 CFR section 261.39(c). Specifically, under the CRT exclusion, the generator must be able to demonstrate that the exported CRT glass is being used for CRT glass making or lead smelting and not disposed in the receiving country, and that it is not being speculatively accumulated prior to being exported.

    Processed CRT glass excluded under a different solid waste exclusion (for example, CRTs being used as an effective substitute as a fluxing agent at a copper smelter) is not subject to hazardous waste export requirements. (See question 13 for a discussion of permissible final uses for CRT processed glass). However, generators claiming a solid waste exclusion must be able to demonstrate that their CRT glass meets the terms of the exclusion (40 CFR section 261.2(f)).

  • 4. What other requirements apply to CRTs and CRT glass?

    Used, intact CRTs are conditionally excluded from hazardous waste regulation within the United States as long as they are not disposed or speculatively accumulated (i.e., accumulated with no assurance that they will actually be reused or recycled; see questions six through 12 for more information on speculative accumulation) (40 CFR section 261.4(a)(22)(i)).

    Used, broken CRTs destined for recycling are conditionally excluded from hazardous waste regulation within the United States if they are (1) stored in a building with a roof, floor and walls or placed in an container that meets the regulatory requirements, (2) labeled according to the regulatory requirements, (3) transported in a container that meets the regulatory requirements, (4) not speculatively accumulated, (5) processed only in a building with roof, floor and walls, and (6) do not undergo activities that use temperatures high enough to volatize lead from CRTs (40 CFR section 261.39(a) and (b)).

    Processed CRT glass is conditionally excluded from hazardous waste regulation under the CRT exclusion so long as (1) it is sent for recycling at a CRT glass manufacturer or a lead smelter, and (2) it is not speculatively accumulated (40 CFR section 261.39(c)).

  • 6. How are CRTs and CRT glass shown not to be speculatively accumulated?

    CRTs and CRT glass are not speculatively accumulated if (1) the person accumulating the used CRTs and CRT glass can show that the material is potentially recyclable and has a feasible means of being recycled and (2) that during the calendar year the amount of material that is recycled, or transferred to a different site for recycling, equals at least 75 percent by weight or volume of the amount of that material accumulated at the beginning of the period (40 CFR section 261.1(c)(8)). Further discussion of the speculative accumulation requirement can be found in the January 4, 1985 FR notice (50 FR 634).

  • 7. In the speculative accumulation regulation, what does it mean for a person to “show that the material is potentially recyclable and has a feasible means of being recycled”?

    In general, a material has a feasible means of being recycled if there is a known market for the material – that is, a person who is managing used CRTs or CRT glass under the exclusion has identified a recycler who will accept and recycle the material, or the person can recycle the material itself.

    On the other hand, all materials stored with a legitimate expectation of eventually being recycled but for which there is no known recycling market or disposition, or no feasible means of recycling, are considered wastes. (See 50 FR 634; January 4, 1985).

    A person accumulating hazardous secondary materials would have the burden of proving that there is a feasible means of recycling. This ordinarily will require identification of actual recyclers and recycling technology, location of the recycler, and relative costs associated with recycling. (See 50 FR 634; January 4, 1985).

    In addition, EPA believes that material for which generators could demonstrate that on-going developmental work will lead to recycling at a future date should be considered to be accumulated speculatively. EPA believes that materials that are not known to be recyclable (or not feasibly recyclable in the hands of a particular generator) are wastes immediately. (See 50 FR 635; January 4, 1985).

    Additionally, EPA notes that in order to demonstrate that used CRTs and CRT glass are not being speculatively accumulated, both parts of the provision must be met – that is, (1) the person accumulating the used CRTs and CRT glass can show that the material is potentially recyclable and has a feasible means of being recycled and (2) that during the calendar year the amount of material that is recycled, or transferred to a different site for recycling, equals at least 75 percent by weight or volume of the amount of that material accumulated at the beginning of the period.

  • 8. How is the minimum requirement of 75 percent material recycled in one year calculated?

    The minimum requirement of 75 percent material recycled applies to each material of the same type, which can be calculated either by weight or by volume, and is based on the total inventory of that material accumulated for recycling as of January 1. For example, a company with a total of 100 tons of CRT glass stockpiled for recycling on January 1 must recycle, or transfer for recycling, at least 75 tons of CRT glass before the end of the calendar year.

  • 9. What about the remaining 25 percent?

    CRTs or CRT glass that are not recycled during the calendar year count towards the total inventory for the purpose of speculative accumulation calculations for the following calendar year.

  • 10. How does the January 1 date work for CRT glass? If a shipment of CRT glass is received in February, by when does it need to be recycled?

    According to the speculative accumulation provision, a facility must recycle, or transfer to a different site for recycling, at least 75 percent of the weight or volume of the amount of material accumulated at the beginning of the period (commencing on January 1). Thus, a facility that has 0 tons on site on January 1 would not have to recycle any glass by the end of the calendar year (since 75 percent of 0 is 0). However, any CRTs or CRT glass that the company receives during the year count towards the total inventory for the purpose of speculative accumulation calculations for the following calendar year. Therefore, 75 percent of the CRT glass accumulated from between January 2nd and December 31st of the first year must be recycled by the end of the following year.

    For more information, see:

  • 11. If I transfer CRTs or CRT glass to another site, but no recycling occurs at that site, does the speculative accumulation time frame restart?

    No, the speculative accumulation provision at 40 CFR section 261.1(c)(8) states that the amount of material must be “recycled, or transferred to a different site for recycling….” Thus, moving hazardous secondary material from one site to another site for purposes of storing at that second site would not reset the calculation for speculative accumulation. In other words, the hazardous secondary materials stored at the second site would still be subject to the same speculative accumulation period that began at the first site. Also, the hazardous secondary material continues to be subject to the requirement that the person accumulating the material show that the material is potentially recyclable and has a feasible means of being recycled. See question seven for additional information.

  • 13. What are acceptable uses of processed CRT glass?

    Under the CRT exclusion, processed CRT glass can be sent for recycling at a CRT glass manufacturer or a lead smelter (40 CFR section 261.39(c)). In some cases, under a different exclusion, processed CRT glass may be used as an ingredient in an industrial process to make a product, provided that the materials are not being reclaimed, or it may be used as an effective substitute for a commercial product (40 CFR sections 261.2(e)(1)(i) and (ii)). For example, processed CRT glass may be used as an effective substitute for a fluxing agent at copper smelters. See EPA’s memo dated April 24, 2013 (PDF)(2 pp, 471 K, About PDF). Additionally, processed CRT glass may be used as a substitute for lead oxide in the production of ceramic tiles under the use/reuse provision at 40 CFR section 261.2(e) as long as that use is legitimate. See EPA's memo dated September 10, 2014 (PDF)(3 pp, 765 K, About PDF) and Frequent Question #14.

    To determine if a specific use for processed CRT glass is legitimate recycling, a company should evaluate whether:

    1. the processed CRT glass provides a useful contribution;
    2. the recycling process produces a valuable product or intermediate;
    3. the processed CRT glass is managed as a valuable commodity; and
    4. the product of the recycling process is comparable to a legitimate product.
       

    If processed CRT glass is being exported for a purpose other than legitimate recycling, then it is considered to be a hazardous waste and RCRA hazardous waste export regulations apply.

    In addition, if processed CRT glass is exported for use in a manner constituting disposal (i.e., used in a manner that results in the product made with CRT glass being applied or placed into or onto the land), then the CRT glass would be considered a hazardous waste regulated under 40 CFR part 266 subpart C and RCRA hazardous waste regulations apply to those exports.

  • 14. Can processed CRT glass be used as a substitute for lead oxide in the production of ceramic tiles?

    Processed CRT glass may be used as a substitute for lead oxide in the production of ceramic tiles under the use/reuse provision at 40 CFR section 261.2(e) as long as that use is legitimate. To determine if a specific CRT glass use is legitimate recycling, a company should evaluate whether:

    • the processed CRT glass provides a useful contribution,
    • the recycling process produces a valuable product or intermediate,
    • the processed CRT glass is managed as a valuable commodity and
    • the product of the recycling process is comparable to a legitimate product.

    One example of how these legitimacy factors apply to ceramic tile manufacturing can be found in EPA's memo dated September 10, 2014 (PDF)(3 pp, 765 K, About PDF). Note that companies exporting used CRTs, whether intact or broken, would still need to comply with CRT export requirements even if the glass from the CRTs will be reused in ceramic tile productions. Please see question three above.

    EPA approval is not required in order to recycle CRT glass. However, it is the responsibility of both CRT glass recyclers and the companies who send CRT glass to those recyclers to determine whether the recycling is legitimate. Companies may wish to consult with their state regarding the legitimacy of a specific CRT use.

  • 15. Is the use of processed CRT glass in aggregate for concrete an acceptable use by EPA? What requirements would apply?

    Use of processed CRT glass as aggregate in concrete that is applied or placed into the land would be considered a type of “use constituting disposal” (UCD) and would be considered an acceptable use in the United States only if it met the alternative hazardous waste management standards in 40 CFR part 266 Subpart C, per 40 CFR section 261.39(d) of the Resource Conservation and Recovery Act (RCRA) regulations. The UCD regulations require the hazardous material to be bound into the new product (i.e., inseparable by physical means) and must meet hazardous waste treatment standards for each hazardous constituent present (e.g., lead, cadmium, chromium, etc.) (40 CFR section 266.20).

    In addition, prior to being incorporated into the concrete, the processed CRT glass is subject to all applicable hazardous waste generation, transport and storage requirements (40 CFR sections 266.21, 266.22, and 266.23).

  • 18. What about used CRTs or CRT glass from households, or from businesses that generate less than 100 kg of hazardous waste per month?

    Used CRTs discarded by households are considered "household hazardous waste" and are exempt from hazardous waste regulations (40 CFR section 261.4(b)(1)). CRTs discarded by businesses that generate less than 100 kg (220 lbs) of (non-acute) hazardous waste per month are considered "very small quantity generator" (VSQG) wastes and are subject to reduced hazardous waste requirements (40 CFR section 261.5).

    However, if these materials - that is used CRTs or CRT glass from households or from VSQGs - are not kept separate from the conditionally excluded CRT materials, then the entire comingled pile would be subject to the CRT exclusion requirements or the hazardous waste regulations.

    The EPA generally encourages recycling of electronics products as they are made from valuable resources and highly engineered materials, including metals, plastics, and glass, all of which require energy to mine and manufacture them. Reusing and recycling consumer electronics conserves our natural resources and avoids air and water pollution, as well as greenhouse gas emissions that are caused by manufacturing virgin materials.

    Local municipality or solid waste collection programs, electronics manufacturers and retailers of electronics products may offer electronics collection programs or events for households. To find more information on electronics donation and recycling opportunities in your area, please visit, Where Can I Donate My Old Computer and Other Electronic Products?

    Moreover, entities that collect CRTs and CRT glass from households or VSQG businesses are subject to the general prohibition on open dumps (40 CFR part 257) and may become subject to RCRA, Superfund, or individual state clean-up authorities if mismanaged.

    Please note that state agencies may have more stringent requirements than the federal government regarding household hazardous waste and VSQGs, so it is important to also check your specific state regulations.

  • 19. If the CRT glass is accumulated in a building, does that eliminate any clean-up liability?

    Managing the CRT glass piles in a building reduces liability by preventing potential lead contamination of the environment, which can be costly to clean up. However, if the indoor CRT glass pile becomes abandoned (for example, if the recycler goes out of business), or if the CRT glass is released, or poses a threat of release, from the building, businesses or facility owners/operators may become liable for the removal and proper management of the glass under RCRA, Superfund, or state clean-up authorities.

  • 20. How can I make sure that the recycler is properly managing the CRTs and CRT glass I send there?

    Before you send your CRTs or CRT glass to a recycler, it is a good idea to take steps to verify they are an environmentally responsible recycler. Information that can help you decide whether a recycler will responsibly recycle hazardous secondary materials (including CRTs) includes whether the recycler can provide records for the final recycling of their hazardous secondary materials and can document that environmental, health, and safety management systems are in place to ensure environmentally sound management practices. For more information, see EPA's Choosing a Responsible Recycler: A Guide for Generators of Hazardous Secondary Materials.

    In addition, there are a range of tools specific to used electronics to help ensure they are recycled in an environmentally sound manner, including accredited third-party certification programs, best practices, and increased knowledge and transparency of the companies and practices along the recycling chain. Currently, there are two voluntary programs run by independent organizations that certify electronics recyclers: R2 Exit and e-Stewards Exit. References to specific certification websites is for informational purposes only and is not a reflection of EPA endorsement).

  • 21. The recycler where I was planning on sending my used CRTs or CRT glass is no longer accepting them. What can I do now?

    If circumstances prevent you from recycling 75 percent of your used CRTs or CRT glass inventory before the calendar year, but you will be able to recycle a sufficient amount the following calendar year, you may apply for a variance from the speculative accumulation prohibition using the provisions found at 40 CFR section 260.31(a). Variances are granted on a case-by-case basis by the authorized state; please contact your state environmental agency for more information.

    Otherwise, you must manage your used CRTs or leaded CRT glass as hazardous waste and send it for proper treatment and disposal in a RCRA hazardous waste permitted facility. CRT materials that are managed as hazardous waste do not count towards speculative accumulation limits, but would count towards the monthly total used to determine a facility's hazardous waste generator status per 40 CFR section 261.5(c) and (d) and, unless you are a VSQG, you must meet the applicable hazardous waste requirements in 40 CFR part 262.

  • 23. Do land disposal requirements (LDRs) apply to used CRTs and CRT processed glass?

    Land Disposal Requirements (LDRs) are found in 40 CFR part 268 and require waste handlers to treat hazardous waste or meet specified levels for hazardous constituents (e.g., lead) before disposing of or placing the waste into or onto the land. Therefore, LDRs would only apply if the used CRTs or CRT processed glass that fail the toxicity characteristic for hazardous waste are being disposed of on the land or will be placed into or onto the land (i.e., landfilled or recycled as "use constituting disposal" under 40 CFR part 266, subpart C).

    CRT processed glass (including glass fines) that exhibits the toxicity characteristic after sorting and prior to treatment are subject to LDRs when destined for land disposal. CRT processed glass that does not fail the toxicity characteristic for hazardous waste after sorting is not a hazardous waste and, therefore, LDRs do not apply even if the CRT processed glass is land disposed.

  • 24. What requirements apply to treatment of hazardous CRT glass?

    The generator of the used CRTs may treat their hazardous CRT glass to render it non-hazardous in an on-site hazardous waste generator accumulation unit (e.g., tank) without a hazardous waste permit provided they are in compliance with the applicable hazardous waste generator requirements in 40 CFR section 262.34, and provided that the treatment is not thermal treatment. Otherwise, treatment of the hazardous CRT glass is subject to the hazardous waste permitting requirements of 40 CFR parts 264, 265 and 270.

    Please note that state agencies may have more stringent requirements than the federal government regarding treatment in generator accumulation tanks or containers, so consider checking with your specific state regulations.

  • 25. Can treated CRT glass be disposed in a non-hazardous waste landfill?

    Hazardous CRT glass that has been treated to meet the applicable land disposal restrictions in 40 CFR part 268 and no longer exhibits a hazardous waste characteristic may be disposed in a non-hazardous waste landfill. However, state agencies may have more stringent requirements regarding disposal of CRT glass, so it is important to check your specific state regulations.

    (See frequent question 15 regarding used CRTs or CRT glass from households, or from businesses that generate less than 100 kg of hazardous waste per month).

  • 26. What is EPA’s policy on treated CRT glass used as alternative daily cover (ADC)? Does EPA consider this to be recycling?

    EPA’s primary concern is to ensure that any solid waste determined to be hazardous is appropriately managed under applicable RCRA regulations. In the case of treated CRT glass being considered for use as ADC, if CRT glass has been treated in accordance with RCRA’s land disposal restrictions and no longer exhibits hazardous characteristics, then it can be managed as non-hazardous solid waste under the relevant state program. EPA notes that, under the Agency’s municipal solid waste regulations, a state may approve use of treated CRT glass as ADC if it is demonstrated that cover material requirements set forth in the regulations are met; for example, ADC would need to control disease vectors, fires, odors, blowing litter, and scavenging without itself presenting a threat to human health and the environment.

    It is also EPA’s position that planning and direct implementation of solid waste programs remains largely a state and local function. With this in mind, for wastes that are no longer hazardous, such as treated CRT glass in this particular instance, the decision whether use of treated CRT glass as ADC does or does not constitute recycling is a decision best left up to individual states based on a consideration of specific circumstances.

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