If certain electronic waste parts are hazardous under RCRA, why don’t I need a hazardous waste manifest?
When a customer ships used and non-functioning electronics to an ACR facility for evaluation, the components are still considered products and not waste. Resource Conservation and Recovery Act (RCRA) classifies electronics as hazardous when improperly disposed of. Once an asset recovery facility determines what is resale and what must be recycled, that facility becomes the generator of any waste. All processing facilities have EPA ID numbers and are capable of shipping outbound hazardous materials on a hazardous waste manifest when necessary.
