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Comprehensive Procurement Guidelines (CPG) Product Designation Criteria and Process

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Origin of Selection Criteria and Information Requirements

EPA's method for identifying, proposing, and designating CPG products was developed based on the statutory requirements of RCRA section 6002 and the process set up in Executive Order 13101 section 502, now revoked. After incorporating RCRA and Executive Order guidance, EPA consulted with federal procurement officials to identify additional criteria to consider when selecting items for designation. Below is a summary of EPA's selection criteria.

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Criteria for Selecting Items for Designation

  1. Use of Materials Found in Solid Waste - All products must be manufactured with materials that are recovered or diverted from the solid waste stream. Particular attention is paid to those items produced from materials that are a significant component of the waste stream.
  2. Economic and Technological Feasibility and Performance - EPA conducts research to verify that the product is available containing recovered materials and that the product is likely to meet government specifications and performance requirements. It also is important for the product to be priced competitively and for there to be more than adequate competition among suppliers of the product.
  3. Impact of Government Procurement - EPA considers the potential impact that government purchasers might have in minimizing the solid waste stream if they purchase a product made with recovered materials. For example, although widgets might be made from 100 percent postconsumer materials, if the government does not buy widgets, EPA is not likely to designate them because designation would not contribute to a reduction in the solid waste stream.
  4. Availability and Competition - The items EPA selects for designation are available from national, regional, or local sources. The relative availability of an item influences the ability of a procuring agency to secure an adequate level of competition when procuring it.
  5. Other Uses for Recovered Materials - EPA also considers the possibility of one recovered material displacing another recovered material as feedstock, thereby resulting in no net reduction in materials requiring disposal; the diversion of recovered materials from one product to another, possibly creating shortages in feedstocks for one or both products; and the ability of manufacturers to obtain recovered materials in sufficient quantity to produce the item under consideration.
  6. Other Considerations - Price is a factor affecting the availability of a recovered material, including the availability and costs of material feedstocks, energy costs, labor costs, rate of return on capital, transportation charges, and the quantity of the item ordered. In addition, EPA does not intend to designate experimental or developmental products until it can be shown that they meet all of EPA's selection criteria. EPA also considers comments from end users, manufacturers, distributors, the general public, and other interested parties through a formal rulemaking process to designate items.

This entire process usually spans at least one year.

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Product Designation Process

An overview of the product designation process from initial research to final designation is below:

  1. Suggestions from the Public/Research of Publicly Available Information
  2. Evaluation against Designation Criteria
  3. Meets Evaluation Criteria - If the product does not meet the evaluation criteria, it is dropped from consideration at this stage. Otherwise, the process continues as follows:
  4. Additional Product Research
  5. CPG Workgroup Review
  6. CPG and Recovered Materials Advisory Notice (RMAN) Proposal in Federal Register
  7. Public Comment Period
  8. Additional Research to Respond to Public (if necessary)
  9. Federal Register Notices: CPG Final Rule and RMAN Notice of Availability
  10. Designations Codified in Title 40 of the Code of Federal Regulations in Part 247

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