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Recyclers and Transporters of Electronic Waste

Any company that handles, stores, or processes unwanted electronics has regulatory duties associated with that material.  Some of those duties maybe under regulations that are outside of Part 173, Electronics.

Businesses that generate unwanted electronics are required to characterize their waste to determine which regulations apply to that waste stream. Transporters of electronics have notification and possible registration requirements depending on the weight handled.

Companies collecting electronics that are outside of the electronics takeback program (commercial or industrial electronics) need to follow the requirements. Companies that recycle any amount of consumer electronics should notify EGLE that they are recycling residential or small business material and determine if they need to register as an electronics recycler under the program.

Below are some links and information on how Michigan regulations apply to companies that are managing end-of-life consumer and commercially sourced electronics. For more information on the requirements contact the Coordinator of the Electronic Waste Takeback Program.       

Notification Requirements for:

  • Notification requirements:

    Notify the Waste and Hazardous Materials Division when electronic equipment from residents is collected, stored, processed, or dismantled, in excess of 1,000 pounds, on-site at any one time. Submit the form EQP5205 at least two weeks prior to conducting the activity.

    Memorandum: Regulation of Electronic Waste (September 20, 2002)

    For recyclers collecting electronics from anyone besides residential clients: Notify as a large quantity universal waste handler when handling 11,000 pounds or more of electronics and other universal waste collected from entities other than households and obtain a site identification number.

    Notifications may be done by mailing in the form EQP5150. There is a $50 application fee. To check if a site identification number has already been assigned to a collection site, go to the Waste Data System and select advanced search. It is recommended to search using the street number in the address field and zip code in the postal code field. If you need assistance looking up a number or filling out the application, call the Environmental Assistance Center at 800-662-9278.

    The following Michigan regulatory guidance documents contain specific information about electronic waste.

    Since "recycling" can mean different things, discuss if your recycling operations would be subject to the industrial storm water program with the Water Resources Division District Office. See the industrial storm water program information including sample Storm Water Pollution Prevention Plans (SWPPPs) and links to the storm water operator certification.

    Water Resources Division Industrial Storm Water Contacts

    U.S. EPA approved CRT recycling exporters. This website contains the list of U.S EPA approved exporters of CRTs destined for recycling per the CRT rule.

  • Non-residential generators include Businesses, Schools, Agencies, Institutions, and Other Regulated Generators of electronic waste. These generators must determine whether or not their waste is hazardous. They must also determine the amount of all hazardous waste they generate within one month. The U.S. EPA and the State of California Notifihave tested electronic products and many have failed the standard test for toxicity called the Toxicity Characteristics Leaching Procedure. Rather than sending waste to be tested, many generators find it more economical to manage their electronic waste as hazardous due to the lead, mercury, and other materials in them.

    In Michigan, EGLE has promulgated rules allowing common electronic products containing circuit boards and cathode ray tubes (CRTs) (containing leaded glass) to be managed as universal waste. Universal waste is more easily recycled than hazardous waste.

    For businesses handling 11,000 pounds or more of electronics and all other universal waste, notify as a large quantity universal waste handler when handling 11,000 pounds or more and obtain a site identification number.

    Notifications may be done by applying online through MiTAPS or by mailing in the form EQP5150. There is a $50 application fee. To check if a site identification number has already been assigned to a collection site, go to the Waste Data System and select advanced search. It is recommended to search using the street number in the address field and zip code in the postal code field. If you need assistance looking up a number or filling out the application, call the Environmental Assistance Center at 800-662-9278.

    The following Michigan regulatory guidance documents contain specific information about electronic waste.

    Other Need-To-Know Information

    • Desktop Computer Displays: A Life-Cycle Assessment. This 2001 report was sponsored by the US EPA and published by the University of Tennessee Center for Clean Products and Clean Technologies. Included in the study is a detailed look at three components of cathode ray tubes and laptop computers: lead, mercury and liquid crystals.
    • Electronic Industries Alliance. "The Electronic Industries Alliance is a federation of Associations and Sectors operating in the most competitive yet innovative industry in existence. They are the critical players in their industries. Each has their own members, their own mission, their own autonomy. United under EIA, they form the premier high technology organization in the world."
    • ElectronicsRecycling.org is the result of stakeholders involved in a dialogue surrounding the recycling of thermoplastics in electronic equipment. These stakeholders come from the Gordon Institute of Tufts University.
    • Federal Electronics Challenge (FEC). The FEC is a new voluntary partnership program that encourages federal facilities and agencies to: Purchase greener electronic products. Reduce impacts of electronic products during use. Manage obsolete electronics in an environmentally safe way. This site contains useful tools for any large organization or government to use to make their use of electronics (computers, cell phones, etc.) more environmentally friendly.
    • Greenpeace Guide to Greener Electronics. This guide, "ranks leading mobile and PC manufacturers on their global policies and practice on eliminating harmful chemicals and on taking responsibility for their products once they are discarded by consumers."
    • International Association of Electronics Recyclers. This trade association offers many member benefits as well as providing a searchable on-line database for finding electronic recyclers, manufacturers and other companies related to the electronics industry.