If you generate scrap circuit boards as a waste, you may be unaware of your options for disposal or recycling under USEPAs hazardous waste regulations.  The purpose of this article is to identify and briefly explain your options for the management of scrap circuit boards.

The first step is to ensure that they are destined for recycling.  If you intend to dispose of them as a waste (e.g., landfill), they would be subject to the requirements for a hazardous waste determination under 40 CFR 262.11.  Given that circuit boards may contain a variety of heavy metals (lead, cadmium, barium, silver, etc.), mercury switches, or lithium, mercury, or NiCad batteries it is likely that they will be determined a hazardous waste, subject to full regulation under RCRA.  A better option is to ensure they are destined for recycling or reclamation, this opens up several possibilities that are exempt entirely or excluded from most regulation under RCRA.

1. Whole unused circuit boards are considered unused Commercial Chemical Products (CCP’s).  Pursuant to 40 CFR 261.2, CCP’s are not solid waste when they are reclaimed.  A material is “reclaimed” if it is processed to recover a usable product, or if it is regenerated.  If not a solid waste, then it is not subject to any of the RCRA regulations.
2. Whole used circuit boards meet the definition of spent materials:  “any material that has been used and as a result of contamination can no longer serve the purpose for which it was produced without processing”; but also meet the definition of scrap metal at 40 CFR 261.6(a)(3)(iii).  Therefore, whole used circuit boards with minimal relays, switches, or batteries, sent for recycling in protective packages are exempt from the hazardous waste regulations.  Check with your scrap metal recycler to ensure their acceptance of your circuit boards.
3. Shredded circuit boards being recycled are excluded from the definition of solid waste at 40 CFR 261.4(a)(14) if they are stored in sturdy, non-leaking containers.  These shredded circuit boards cannot contain mercury switches, mercury relays, nickel cadmium batteries, or lithium batteries.  If not a solid waste, then it is not subject to any of the RCRA regulations.
4. One final option depends upon the regulations of your state.  Since states with an authorized hazardous waste program are allowed to add to the five universal wastes identified by USEPA (aerosol cans were added 02.07.20), some states manage scrap electronics and e-waste as a universal waste.

More information on the above can be found in the EPA’s RCRA On-line FAQ’s or it’s e-cycling website.

Advantages to using any of the above options for your scrap circuit boards include: reduced cost, reduced cradle-to-grave responsibility, and…since scrap circuit boards managed under any of the above options are not a hazardous waste, there may be a reduction in your hazardous waste generator category which itself will result in additional benefits.